1)Users Outside the Geographical Limits of India

The Services offered through the Platform are intended for Institutions offering programs within India. Data shared with CollegeLinkr is primarily processed in India and such other jurisdictions where a third party engaged by CollegeLinkr may process the data on its behalf. By agreeing to this Policy, You provide CollegeLinkr Your explicit consent to process personal information for the purposes defined herein.

If You have any concerns about the processing of such data and wish to withdraw Your consent, You may do so by writing to privacy@collegelinkr.com. Please note that withdrawing Your consent may impact Our ability to continue providing certain Services to the Institution, including listing programs, processing Applications, or settling Service Charge and application fee payouts.

2)Type of Information We Collect and Its Legal Basis

The information detailed below is collected so that We can provide the Services the Institution has requested and fulfil Our legal obligations and obligations towards third parties as per Our Terms & Conditions.

1. Registration on the Platform

Information provided while registering the Institution on the Platform, including but not limited to the Institution's legal name, brand/operating name, registered address, and contact details.

2. Authorised Representative Information

Information relating to the individual(s) authorised to represent the Institution on the Platform, including their name, designation, email address, and phone number.

3. Other Information

We may also collect other information and documents, including but not limited to:

• Course, program, fee, eligibility, scholarship, application form creation and charges collection, USP, Service Charge Structure/Amount and admission-timeline information uploaded to the College Dashboard.
• Brochures, images, and other promotional or informational material uploaded by the Institution.
• Information relating to Student Applications and Enrollments processed through the Platform, to the extent necessary to track and report status to the Institution.

How Long Do We Keep This Information?

CollegeLinkr will retain this information on its servers for as long as is reasonably necessary for the purposes listed in this Policy. In some circumstances, We may retain information for longer periods where required by applicable legal, regulatory, tax, or accounting requirements. Where information is no longer required, We will ensure it is either securely deleted or stored in a manner such that it is no longer used for business purposes.

Please note that information sought to be removed may remain with Us in archival records for compliance with statutory requirements or any other lawful purpose.

3)Authorised Signatory & Bank Account Information

As the Institution both pays Service Charge to CollegeLinkr and receives application-fee payouts from CollegeLinkr, this section describes how We handle information relating to the Institution's authorised representative and bank account.

What We Collect: The name, designation, and contact details of the Institution's authorised signatory/representative; and the Institution's bank account details (account holder name, account number, IFSC code, and branch name) and invoice/billing information.

Purpose: This information is used to verify the authority of the individual representing the Institution on the Platform, to process invoicing and settlement under the Terms & Conditions and any applicable MoU, and to disburse any application-fee payout owed to the Institution.

Storage & Security: This information is stored with appropriate technical and organisational security measures, with access restricted to authorised CollegeLinkr personnel involved in account management, invoicing, and payment processing.

Retention: We retain this information for as long as the Institution's account remains active on the Platform and for any additional period required under applicable financial, tax, or audit requirements.

The Institution is responsible for ensuring that the authorised signatory and bank account information it provides is accurate and kept up to date, as set out in the Terms & Conditions (including Clause 33 — Transfer to Next Authoritative Person).

4)Information Collected Automatically

The following information is collected about the Institution's use of the Platform and the devices used to access it:

• Activity on the College Dashboard, including listings created or updated, and Application/Enrollment status viewed;
• Interactions with Our customer support via email, messages, or calls;
• Device IDs and other unique identifiers, such as IP address, browser type and version, and network service provider details;
• Device and software characteristics, connection information, and statistics on page views.

5)How We Use This Information

The information collected may be used to:

• Verify and onboard the Institution and its authorised representative(s) on the Platform;
• Display and maintain the Institution's program and course listings;
• Process and track Student Applications and Enrollments in connection with the Institution;
• Process invoicing, Service Charge settlement, and application-fee payouts;
• Communicate with the Institution regarding its account, listings, or transactions;
• Customise the College Dashboard experience;
• Validate and authenticate account access to prevent misuse or abuse;
• Detect and prevent fraud, including in connection with Application/Enrollment attribution.

6)Surveys

We value feedback from Our Institutional partners and may conduct surveys from time to time. Participation is entirely optional. Information received is typically aggregated and used to improve the Platform and Our Services.

7)Marketing Promotions, Research and Programs

As a registered Institution, You may occasionally receive updates from Us about Platform features, admission-cycle updates, or other noteworthy items, in accordance with Your communication preferences set out in the Terms & Conditions. CollegeLinkr may also share information in anonymised and/or aggregated form with a third party engaged to perform certain tasks on Our behalf, such as data hosting or data processing.

8)Student Data — Your Obligations as an Institution

In the course of using the Platform, the Institution will have access to personal information relating to Students who apply through the Platform, including their contact and academic details. This information is made available to the Institution solely to process and evaluate the relevant Student's Application and admission.

As set out in the Terms & Conditions (Clause 19 — Confidentiality) and any applicable MoU, the Institution must comply with applicable data protection and privacy laws in handling Student personal data shared with it, must use such data solely for purposes connected with the Student's Application and admission, and must not use such data for any purpose outside the scope of the Institution's engagement with CollegeLinkr.

9)Related Services

We may share information across Our different Services and with Our affiliated group entities within the Sawara Solutions Private Limited group, to provide and develop Our Services. We may combine information internally across Services covered by this Policy to help make Our Services more relevant and useful to the Institution.

10)Service Providers

We use others to help Us provide Our Services (e.g., maintenance, analysis, audit, payments, fraud detection, and development). They will have access to information as reasonably necessary to perform these tasks on Our behalf and are obligated not to disclose or use it for other purposes.

11)Legal Disclosures

It is possible that We will need to disclose information when required by law, subpoena, or other legal process, or if We have a good-faith belief that disclosure is reasonably necessary to: (1) investigate, prevent, or take action regarding suspected or actual illegal activities, or to assist government enforcement agencies; (2) enforce this Policy or the Terms & Conditions; (3) investigate and defend against any third-party claims or allegations; (4) protect the security or integrity of Our Services; or (5) exercise or protect the rights and safety of CollegeLinkr, Our Users, personnel, or others.

12)Change in Control or Sale

We may share information as part of a sale, merger, or change in control of CollegeLinkr, or in preparation for any such event. Any entity that acquires Us or part of Our business will have the right to continue using such information, but only in the manner set out in this Policy, unless otherwise agreed.

13)Cross-Border Data Transfers

We process data both inside and outside of India and rely on legally provided mechanisms to lawfully transfer data across borders where applicable. Countries where We process data may have laws different from, and potentially less protective than, the laws of the Institution's own jurisdiction.

14)Lawful Bases for Processing

We only collect and process personal data where We have a lawful basis to do so. Lawful bases include consent, contractual necessity (where processing is necessary to provide the Services requested, including under an applicable MoU), and Our legitimate interests. For any questions regarding the lawful bases on which We collect and use personal data, please contact Our Grievance Officer named below.

15)Direct Marketing and Do-Not-Track Signals

We currently do not share personal data with third parties for their own direct marketing purposes without prior permission.

16)Cookies and Session Data

CollegeLinkr uses cookies, similar to many other reputable online platforms, to personalise the College Dashboard experience. Cookies are small pieces of information stored by Your browser on Your device, which allow Us to serve You better and more efficiently, including logging You in without requiring You to re-enter credentials each time.

A cookie may also be placed by Our advertising servers or third-party advertising partners, used to measure the effectiveness of advertising served on the Platform or elsewhere. Such information is collected in an anonymous form through industry-standard technology and does not, on its own, identify an individual.

Automatic Logging of Session Data: Each time the Institution accesses the Platform, session data is logged, including IP address, device/browser type, and activities conducted on the Platform. This helps Us analyse usage patterns, diagnose technical issues, and administer Our systems.

17)With Whom Your Information is Shared

1. Sharing and Disclosure of Information

We may allow access to Institutional information to third parties with whom CollegeLinkr has a direct legal and confidentiality arrangement, for the limited purpose and period necessary to provide the Services, including account provisioning, customer support, and payment processing. To the extent possible, We shall enter into confidentiality arrangements with such third parties on a best-effort basis.

CollegeLinkr and Our service providers may disclose and otherwise use Institutional information where reasonably believed necessary to meet or satisfy any applicable law, regulation, governmental request, or legal process; to enforce the Terms & Conditions or any applicable MoU; to address and investigate any illegal activity; and to protect Ourselves against harm or misuse.

2. Companies in the Same Group

We may, under controlled and secure circumstances, share Institutional information with Our affiliate or associate entities within the Sawara Solutions Private Limited group, to provide relevant information about Our Services and address requests relating to the Institution's account.

3. Institution-Submitted Content and Documentation

We collect the documents and information the Institution provides, shares, or uploads to the Platform, such as brochures, course materials, and images. Such documentation is used solely for the purposes set out in this Policy.

18)How Can You Opt Out of Receiving Our Promotional Communications?

You will occasionally receive updates from Us about Platform features or other noteworthy items. If You wish not to receive them, please follow the unsubscribe instructions in the relevant communication. Please note that You cannot opt out of Service-related correspondence, such as messages regarding Applications, Enrollments, invoicing, or settlement.

19)How We Protect This Information

The College Dashboard is secured through industry-standard measures, including HTTPS encryption. The Platform has security measures in place to protect against the loss, misuse, and alteration of information under Our control, including the additional safeguards described in the Authorised Signatory & Bank Account Information section above. Once information is in Our possession, We adhere to strict security guidelines to protect it against unauthorised access.

20)Withdrawal of Consent and Permission

You may withdraw Your consent to the processing of information covered by this Policy at any time. Where You choose to do so, Our ability to provide certain Services to the Institution, including settlement of Service Charge or application-fee payouts, may be limited. You may withdraw Your consent by writing to privacy@collegelinkr.com.

21)Your Rights Qua This Information

At all times, You have the right to access, update, or correct information We hold about the Institution and its authorised representatives, through the College Dashboard or by writing to Our support team. We retain information as required or permitted by applicable law, including to meet billing, invoicing, and regulatory requirements as specified in this Policy.

22)Data Security

We implement security safeguards designed to protect data, such as HTTPS, and regularly monitor Our systems for possible vulnerabilities. However, We cannot warrant the security of any information sent to Us, and there is no guarantee that data may not be accessed, disclosed, altered, or destroyed despite Our safeguards. We employ reasonable technical, organisational, logical, physical, and administrative measures to protect information against unauthorised access, modification, or use.

23)Changes to the Privacy Policy

We reserve the right to revise this Policy from time to time to suit various legal, business, and customer requirements. We will duly notify You as may be necessary. You may submit concerns regarding this Policy by writing to privacy@collegelinkr.com.

24)Grievance Officer

In accordance with the Information Technology Act, 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below:

If You have questions or complaints regarding this Policy, please contact CollegeLinkr online or by physical mail using the details above.