This Privacy Policy explains what personal data the Scrollwell learning portal collects, why we use it, who we share it with, how long we keep it, and your rights under India's Digital Personal Data Protection Act, 2023 and other laws. It is part of our Terms & conditions.
In short
- We collect what we need to register you, run your programmes, take payments, and issue invoices and certificates.
- We do not sell your personal data or use it for advertising by others.
- WhatsApp messages and emails about future programmes are your choice, and you can stop them at any time.
- You can see and correct your details in My profile, and you can ask us for a summary of what we hold or to erase it.
- Questions or complaints: our Grievance Officer at jyoti@scrollwell.com.
This summary does not replace the full policy below.
Contents
- Who is responsible for your data
- The personal data we collect
- Why we use it
- Who we share it with
- Where it is stored
- How long we keep it
- Your rights and choices
- How we protect it
- Cookies and browser storage
- How we count use of the portal
- Referring a colleague
- Children
- Changes to this policy
- Contact and Grievance Officer
1. Who is responsible for your data
Scrollwell Edutech LLP ("Scrollwell", "we", "us") decides why and how your personal data is used in the portal, so under the Digital Personal Data Protection Act, 2023 we are the "Data Fiduciary". This policy covers the portal at scrollwell.com/academy, its registration and payment pages, the verification of certificates issued through it, and the emails and WhatsApp messages we send about your programmes. Our other websites and apps may have their own policies. Our contact details are in section 12.
2. The personal data we collect
| What | Details | Where it comes from |
|---|---|---|
| Your profile | Full name, email address, mobile number, institution, designation, department, city, state and country, and your participant ID. | You, when you sign up or edit My profile. Scrollwell staff or your institution, when they add you to a programme. Scrollwell's certificate records, if you already hold a Scrollwell certificate. |
| Signing in | One-time sign-in codes and your password, if you set one (both stored only in scrambled, one-way form); when you last signed in and from which IP address; which version of the terms you accepted, and when. | Created when you use the portal. |
| Registration and invoice details | The programme; your state (for GST); and, if you ask for an institution invoice, the institution's name, GSTIN and address. The IP address used to register. | You. |
| Payments and refunds | Amounts and GST; Razorpay order, payment and refund numbers; status and time; and a short description of the payment method (for example, the card network and last four digits, or the UPI ID). We never receive your full card number, CVV, UPI PIN or banking passwords. | You and Razorpay. |
| Learning records | Enrolments; attendance (with the IP address and a scrambled code for your browser when you mark yourself present); when you open a session's joining link; quiz answers and scores; feedback ratings and comments, and any testimonial; Activity Zone answers and links, and our reviews of them; Learning Hour bookings; the certificate details you confirm; and certificates issued. | Your use of the portal, and Scrollwell staff (for example, attendance marked by staff). |
| Messages and choices | Emails we send you (address, subject and whether they were sent); your WhatsApp choice and when you made it; WhatsApp messages we send you (number, type of message, and whether it was delivered or read); your choice about emails on future programmes; and corrections or help requests you send us. | You, the portal, and Meta (WhatsApp delivery updates and STOP replies). |
| Technical and security | A session cookie (section 9); IP addresses in activity and security logs; scrambled IP addresses used to limit repeated attempts; error logs. | Collected automatically. |
We do not ask for sensitive information such as health details, religion or caste. Please do not include it in feedback or Activity Zone work.
3. Why we use it
| What we use it for | Why we may do so |
|---|---|
| Creating your account, signing you in and keeping it secure | You gave us these details in order to use the portal. |
| Registering you, taking payment, issuing GST invoices and credit notes, and handling refunds | To provide what you asked for. Tax and accounting laws also require us to issue invoices and keep these records. |
| Running your programmes: schedules, joining details, materials, recordings, attendance, quizzes, feedback, Learning Hours and the Activity Zone | To provide what you asked for. |
| Issuing certificates and letting others verify them by their ID | To provide what you asked for. Verification is what makes a certificate trustworthy. |
| Service emails: sign-in codes, confirmations, reminders, schedule changes and invoices | Needed to provide the service. |
| WhatsApp messages with your joining details, schedule changes and session reminders | You gave us your mobile number for your registration and chose to receive them. You can say no on the registration form, on Home or in My profile, or reply STOP at any time. |
| Emails about future Scrollwell programmes | Your choice: every such email has an unsubscribe link, and you can switch them off in My profile. |
| Publishing your testimonial on the programme's public page, signed with your first name and institution | Only if you tick the box that allows it, and only after a member of staff chooses it. Untick the box and it comes down. |
| Counting how the portal is used (section 9a) | Our legitimate interest in running the portal well. Nothing counted identifies you. |
| Measurement by Google, if we ever switch it on | Your consent, asked for on the banner before anything of Google's loads. |
| Showing your Activity Zone work to other learners of the programme | Only if you choose to show it. |
| Improving our programmes | Part of providing a good service. Wherever we can, we use totals and summaries that do not identify you. |
| Preventing misuse, fraud and attacks, and fixing problems | To keep the portal and your data safe. |
| Meeting legal duties, answering lawful requests and handling disputes | Required by law. |
We do not sell your personal data, and we do not use it for advertising by others.
4. Who we share it with
- Razorpay (Razorpay Software Private Limited), to take your payment: your name, email address and mobile number (to fill in the payment window), the amount and your registration number.
- Meta Platforms (the WhatsApp Business Platform), only if you chose WhatsApp messages: your mobile number and the message itself — for example your name, programme, dates, joining link, meeting ID and passcode. Meta's own terms and privacy policy also apply.
- Our hosting and email providers (including Hostinger), which store the portal and its data and deliver the emails we send.
- Google Fonts. Portal pages load fonts from Google, so your browser sends Google your IP address and basic browser details.
- Services you open from the portal. When you open a joining link (Zoom, Google Meet or YouTube) or a WhatsApp or Telegram group link, you use that service directly and its own privacy policy applies. When you play a recording inside the portal, YouTube's player loads in its privacy-enhanced mode (youtube-nocookie.com).
- People at Scrollwell. Staff and programme operators see what they need for the programmes they run; accounts staff see payment and invoice records; trainers see names and questions during live sessions.
- Other learners. Your name, with Activity Zone work you choose to show; and your name and messages in live sessions and chats.
- Anyone with a certificate ID. The verification page shows the name the certificate was awarded to, the programme, the institution, the certificate type and the date awarded.
- Others, when needed: professional advisers such as auditors, chartered accountants and lawyers, under a duty of confidentiality; government authorities, courts or police when the law requires it; and a buyer or successor if Scrollwell's business is transferred, who must follow this policy.
5. Where it is stored
The portal and its data are stored on servers used by our hosting provider. Some service providers (for example Google and Meta) may process data outside India. We transfer data only as Indian law allows, including any restrictions notified by the Government of India.
6. How long we keep it
| Data | How long |
|---|---|
| Your account and profile | While you use the portal. If you ask us to erase your data, we do so, except for the records below that we must keep. |
| Payments, invoices, credit notes and refunds | For as long as tax and accounting laws require — under GST law, about eight years from the end of the financial year of the payment. We keep them even if you ask us to erase your data. |
| Certificates and verification records | For as long as the certificate is valid, so that it can still be verified. |
| Learning records | While your account exists, so that we can issue or reissue certificates and answer your questions. If your data is erased, what remains (such as scores, ratings and attendance) no longer shows your name or contact details. |
| Sign-in codes | Each code works for 5 minutes and is stored only in scrambled form. |
| Your signed-in session | Ends when you sign out or close your browser, or after 12 hours without activity. |
| Records of emails and WhatsApp messages, and activity and security logs | At least one year, to keep the portal secure. If your data is erased, your personal details are removed from them. |
| Backup copies | The portal keeps a small number of recent backup copies, which are replaced automatically. Erasing your data also removes it from these copies. |
| After your data is erased | Only a scrambled, one-way code made from your email address, so that we do not invite you again because of certificates held in our certificate records. The code cannot be turned back into your address. |
7. Your rights and choices
- See your data. My profile, Payments & invoices and My certificates show most of what we hold. You can also ask us for a summary of the personal data we hold about you, how we use it, and who we have shared it with.
- Correct and update it. Change your details in My profile. Your name can be changed there until your programme ends; after that, use "Something wrong?" to correct a certificate. Ask us for any other correction.
- Erase it. Ask us to erase your personal data and we will do so within 30 days — except payment, invoice and credit-note records we must keep by law, and certificates already issued, which stay verifiable. Erasing your data also closes your account.
- Change your mind. Stop WhatsApp messages in My profile or by replying STOP; stop emails about future programmes with the unsubscribe link or in My profile; withdraw permission for a testimonial by unticking the box on your feedback form, which takes it off the programme page straight away; and make Activity Zone work private at any time. This does not affect what was done before, and it does not stop the service messages your registration needs.
- Nominate someone. You can name another person to use these rights for you if you die or become unable to use them. Write to our Grievance Officer to do this.
- Complain. Please contact our Grievance Officer first. We acknowledge a complaint within 48 hours and aim to resolve it within one month. If you are not satisfied with our answer, you can complain to the Data Protection Board of India.
To use any of these rights, use "Something wrong?" in the portal while signed in, or email jyoti@scrollwell.com from your registered email address. We may ask you to confirm who you are. There is no charge.
The law also asks you to give accurate information, not to pretend to be someone else, and not to make false or frivolous complaints.
8. How we protect it
- The portal uses encrypted connections (HTTPS).
- Sign-in codes and passwords are stored only in scrambled, one-way form, and the keys for payments and WhatsApp are stored encrypted.
- Card, UPI and banking details are handled by Razorpay, not by the portal.
- Data folders cannot be reached from the web. Staff see only what their role allows, and staff actions are recorded in an activity log.
- Repeated sign-in attempts are limited.
No system is completely secure. If a breach affects your personal data, we will tell you and the Data Protection Board of India, as the law requires.
9. Cookies and browser storage
- SCRLMS — a cookie that keeps you signed in. It is strictly necessary, and it is deleted when you sign out or close your browser.
- Scrollwell staff get a similar cookie when they sign in to the admin area.
- Browser storage on your device remembers the pages you recently opened from quick search, and which schedule-change notices you have closed. It stays on your device.
- lms_consent — set only if we ever switch on measurement by an outside company (section 9a), and only to remember whether you said yes or no. It holds one word and no identifier, and it lasts a year.
- We use no advertising cookies, and we never sell or share what we count. When you pay, Razorpay's payment window may use its own cookies, and fonts load from Google Fonts (section 4).
9a. How we count use of the portal
We keep a simple count of how the portal is used, so we can see which pages help and which get in the way. This counting is done by the portal itself, on our own server.
What is counted: a search made in the portal's search box, a file downloaded, a link followed to another site (for example Zoom or YouTube), an address typed or followed that does not exist, a fault in the page itself, a page that took an unusually long time to load, and a registration being completed.
What is stored with it: what happened, the page it happened on, whether it was a learner, a member of staff or someone who was not signed in, and the date. Nothing that identifies you — no name, no email address, no phone number, no IP address, and no account number. Search text has email addresses and numbers removed before it is stored. These rows are deleted after six months.
If a link brought you here from a campaign (an address carrying utm_source, utm_medium, utm_campaign, or a Google or Facebook click identifier), we keep those words for your visit, and — if you go on to register — with that registration, so we know which announcement brought you. They describe the link, not you.
Measurement by an outside company. Scrollwell may switch on Google Analytics. When it is off — which is how the portal is delivered — nothing of Google's loads and you are asked nothing. When it is on, you are asked once, plainly, before anything of Google's loads: say no and nothing loads, and the portal works exactly the same. If you say yes, Google receives the pages you visit with your IP address shortened, under Google's own privacy policy. You can change your mind by clearing your browser's cookies for this site, which brings the question back.
9b. Referring a colleague
Scrollwell may run a refer-a-colleague scheme. It is off unless we have switched it on, and while it is off nothing described here happens and nothing about it is shown to you.
Your own link. If the scheme is running, your account is given a short code, and a link that carries it. The code is a random string of letters and numbers — it is not made from your name or your email address, and it says nothing about you to anyone you send it to.
What we record when somebody uses your link. If a colleague opens your link and creates an account, we store a link between your account and theirs: who referred whom, when, the code used, the points the referral will pay, and the internet address the new account was created from. We keep that record so we can pay the points, answer a question about them, and look into a scheme that is being abused.
What each of you can see. On your own page you see your colleague's first name only, the date they joined, and whether the referral has paid out. They are never told what you earned, and we never show them to each other beyond that. Our staff can see both accounts, as they can for any other record.
Points. Every movement of points — earned, spent on a fee, expired, or changed by our staff — is kept as a line in your own list, with the reason, so the balance can always be explained. Points are not money, cannot be transferred or cashed out, and have no value outside this portal. If we set an expiry, the number of days is shown on your page before you earn them.
If you do not want to take part, simply do not share your link. To have the record of a referral removed, write to us at info@scrollwell.com and we will remove it along with the points it paid.
10. Children
The portal is for adults (18 or over) and is not meant for children. If we learn that we hold a child's personal data without verifiable consent from a parent or guardian, we will erase it.
11. Changes to this policy
The version of this policy, and the date it took effect, are shown at the top of this page. When we change it, we update the version and ask you to accept the new version the next time you sign in.
12. Contact and Grievance Officer
For any question or complaint about your personal data, contact our Grievance Officer:
- Jyoti Singh, COO
- Scrollwell Edutech LLP
- 5th Floor, B-HUB, Maurya Lok Complex, Dak Bungalow Road, Patna, Bihar – 800001.
- Email: jyoti@scrollwell.com
- Phone: +91 975 975 1070
Our company details:
- Scrollwell Edutech LLP
- 5th Floor, B-HUB, Maurya Lok Complex, Dak Bungalow Road, Patna, Bihar – 800001.
- GSTIN 10AEFFS3410M1ZB
- Email: info@scrollwell.com
- WhatsApp: +91 975 975 1070