Privacy policy

Draft pending legal review. This text describes how the product handles data but has not been approved by counsel. Do not publish it as final. Items in [square brackets] need real details.

Last updated: [date]. This policy is issued by [legal entity name], trading as Noventraq, of [registered address] (“Noventraq”, “we”).

Who this covers

This policy covers two different situations, and the rules differ between them.

  • Visitors to this website. People who read our pages or ask for a demo.
  • People whose data is held in the platform. Students, parents, faculty and staff of a university that uses Noventraq. For them, the university decides why and how their data is used, and we process it on the university’s behalf.

Visitors to this website

What we collect

If you request a demo we collect the university name, your name, your work email address, your phone number and an approximate student count. We use them to reply to you and to arrange the demo, and for nothing else.

Cookies and tracking

This website does not include analytics or advertising scripts. [Confirm whether the hosting provider’s own analytics are switched on for this site and update this paragraph to match.]

How long we keep it

We keep demo requests for [retention period] and then delete them, unless you become a customer, in which case the details become part of your account record.

People whose data is held in the platform

The university is the data fiduciary under the Digital Personal Data Protection Act, 2023. Noventraq is its data processor: we store and process the data to provide the service, following the university’s instructions and the agreement we have with it. If you are a student, parent or member of staff, your university’s own privacy notice explains why your data is collected and what it is used for, and is the first place to raise questions.

What the platform holds

Whatever a university chooses to record: identity and contact details, admissions, enrolment, attendance, examination results, fees and payments, hostel, library and transport records, and, for staff, employment and payroll details. Some fields, such as Aadhaar and PAN numbers, bank details and the text of certain complaints, are encrypted at the field level.

Where it is stored

On AWS in Mumbai, India.

Who can see it

People at the university, according to the roles the university gives them. The console our staff use to manage universities does not give access to student, staff or finance records, and actions taken in it are logged. [Describe the support access process, if any, that lets our team view a university’s data to resolve a problem, and the approval it needs.]

Other companies involved

  • Amazon Web Services, for hosting.
  • [Email delivery provider], for system emails. [Confirm provider and where it processes data.]
  • The payment gateway and any government integrations a university chooses to connect, using that university’s own accounts and credentials.

Your rights

Under the Act you may ask to see the personal data held about you, to have it corrected or erased, to withdraw consent where consent is the basis, and to complain. Academic records such as results and degrees are kept as long as a university needs them, so an erasure request cannot always remove them. Students and parents should start with their university. To ask us about this website or about our own handling of data, write to [privacy contact email].

Grievances

Our grievance officer is [name], reachable at [email] and [postal address]. We aim to respond within [period].

Children

Some students are under 18. Universities are responsible for obtaining any parental or guardian consent the law requires before they enter a student’s data. [Counsel to confirm the wording.]

Security

See our security page for how we protect data and what is not built yet.

Changes to this policy

We will post changes here and update the date above. Where a change affects how a university’s data is handled, we will tell the university directly.