Privacy Policy

This Policy applies to the Varsity website hosted under the interviewbit.com domain and to any related websites, mobile applications, portals, learning environments, assessment tools and communications operated by us in connection with Varsity (collectively, the “Platform”).

This Policy does not apply to:

• third-party websites, applications or services that we do not own or control, even where they are linked to or accessible through the Platform; or

• separate products or services offered under the InterviewBit or Scaler brands that are governed by separate privacy policies.

Where a university, academic institution, industry partner or other institution associated with a Program (“Partner Institution”) processes your Personal Data independently for its own purposes, its privacy policy or privacy notice may also apply.

“Personal Data” means information relating to an identified or identifiable individual and includes any information treated as personal data or personal information under applicable law.

“Processing” means any operation performed on Personal Data, including collection, recording, organisation, storage, use, disclosure, sharing, transfer, alteration or deletion.

“Program” means a course, program, certification, learning offering or other educational or upskilling offering made available through Varsity.

“Program Collaterals” means the applicable Program brochure, enrolment page, offer or enrolment communication, Program-specific terms, policies or other materials made available in connection with a Program.

Terms such as “Data Principal”, “Data Fiduciary” and “Data Processor” shall have the meanings assigned to them under the DPDP Act where and when those provisions are applicable.

We may collect Personal Data:

1. directly from you when you register, apply, enrol, make a payment, participate in a Program, undertake an assessment, interact with an AI-enabled feature or contact us;

2. automatically when you access or use the Platform;

3. from Partner Institutions in connection with admissions, eligibility, Program administration, assessments or credentials;

4. from third-party services that you use in connection with Varsity, such as authentication, payment or communication providers; and

5. from our affiliates, business partners or other lawful sources where permitted by applicable law.

Where required by applicable law, we will provide an appropriate notice at or before collection and obtain consent or rely on another lawful basis available to us.

Depending on the Program and the manner in which you use Varsity, we may collect the following categories of Personal Data.

A. Identity and Contact Information

This may include:

• name;

• email address;

• telephone number;

• date of birth;

• gender;

• residential or correspondence details; and

• other information reasonably required to identify or communicate with you.

B. Academic and Professional Information

This may include:

• educational qualifications;

• academic records;

• employment or professional information;

• resumes or curriculum vitae;

• eligibility information; and

• documents or information required by the applicable Partner Institution for admission, assessment, certification or other Program administration.

C. Payment and Transaction Information

We may collect information relating to:

• Program fees;

• instalments;

• billing;

• refunds;

• payment status; and

• transaction references.

Payments may be processed through third-party payment service providers. We do not require you to provide us with information that a payment service provider is required to retain exclusively under applicable banking or payment-system requirements.

D. Learning and Assessment Information

Depending on the Program, this may include:

• coursework;

• submissions;

• assignment and assessment responses;

• grades, scores and performance information;

• attendance and participation information; and

• feedback and learning interactions.

Where a Program includes online proctoring, we may also process webcam footage, audio, screen activity, device or browser signals and related information required for identity verification and assessment integrity.

E. AI Feature Information

Where you use an AI-enabled feature made available through Varsity, we may process information that you provide to or generate through that feature, including resumes, prompts, responses, interview answers and related interactions.

F. Communications

We may process communications you send to us, including support queries, feedback, complaints and grievance correspondence.

G. Device and Usage Information

When you access the Platform, we may automatically collect information such as:

• IP address;

• browser type;

• operating system and device type;

• pages or features accessed;

• date and time of access;

• referral or exit information;

• approximate location derived from technical information; and

• cookies or similar identifiers.

We may process Personal Data for purposes including:

• creating and administering your Varsity account;

• verifying identity, eligibility or admission requirements;

• facilitating enrolment into Programs;

• providing learning content, assessments and Program services;

• facilitating interaction with Partner Institutions;

• administering examinations and assessments;

• supporting issuance of certificates, degrees or other credentials where applicable;

• providing AI-enabled learning and career-assistance features;

• processing fees, instalments, refunds and transactions;

• providing customer support and grievance redressal;

• sending essential Program, service and administrative communications;

• sending promotional or marketing communications where permitted by applicable law and, where consent is required, only after obtaining the required consent;

• improving and personalising the Platform and Programs;

• analysing use of the Platform;

• maintaining Platform and information security;

• detecting, preventing and investigating fraud, misuse or unlawful activity;

• complying with legal, regulatory and contractual requirements;

• establishing, exercising or defending legal claims; and

• carrying out other purposes notified to you or permitted by applicable law.

Where promotional communications are sent, you may use the unsubscribe or opt-out mechanism provided in the relevant communication, subject to communications that are necessary for delivery or administration of a Program. Where applicable law requires prior consent for direct marketing, including in certain jurisdictions outside India, we will seek such consent separately and will provide a reasonably accessible mechanism to withdraw or opt out of marketing communications.

Depending on the applicable Program, Varsity may provide one or more AI-enabled features designed to assist your learning or career preparation.

These may include:

• AI-assisted resume review;

• AI-enabled mock interviews;

• an AI chatbot or teaching assistant; and

• other learning or career-support features identified in the applicable Program Collaterals.

Such features may involve automated processing of information that you provide to them. Their purpose is to provide assistance, feedback or support. They do not replace any formal academic evaluation or credential decision of a Partner Institution where such evaluation or decision applies.

Certain Programs may include proctored assessments. Where proctoring applies, the applicable assessment may require access to your webcam and may capture audio, screen activity or similar signals for identity verification, assessment integrity, fraud prevention and related administration.

We will disclose the use of material proctoring or monitoring mechanisms where required by applicable law.

We may share Personal Data with the following categories of recipients where reasonably necessary for the purposes described in this Policy.

A. Partner Institutions

We may share relevant Personal Data with the Partner Institution associated with your Program for purposes such as:

• admission;

• eligibility verification;

• Program delivery;

• academic administration;

• assessments;

• examination integrity;

• certification or credential administration; and

• other activities described in the applicable Program Collaterals.

Depending on the applicable Program and processing activity, a Partner Institution may process Personal Data independently in accordance with its own privacy notice or in accordance with arrangements entered into with us.

B. Service Providers

We may engage service providers for services such as:

• cloud hosting and storage;

• learning-platform technology;

• payment processing;

• proctoring;

• communications;

• customer support;

• analytics;

• security; and

• other technology or operational functions.

Where these service providers process Personal Data on our behalf, we require them to process it for authorised purposes and subject to appropriate contractual and security requirements.

C. Affiliates and Group Companies

We may share Personal Data with our affiliates or group companies where reasonably necessary to operate, support or administer Varsity, subject to applicable law.

D. Legal and Regulatory Disclosures

We may disclose Personal Data where reasonably necessary to:

• comply with applicable law or a lawful request from a court, governmental, law-enforcement or regulatory authority;

• enforce our contractual or legal rights;

• investigate or prevent fraud, security incidents or unlawful activity; or

• protect our users, our business or other persons.

E. Corporate Transactions

Personal Data may be transferred in connection with a merger, acquisition, restructuring, financing, sale of business or assets, or similar corporate transaction, subject to applicable law.

Varsity may use service providers, infrastructure or systems located in India or other countries.

Accordingly, Personal Data may be processed or stored outside the country in which you reside.

Where cross-border processing or transfer is subject to legal requirements or restrictions, we will process Personal Data in accordance with applicable law and implement such measures as may be required in the relevant circumstances, which may include contractual transfer safeguards, standard contractual clauses, approved transfer mechanisms or other measures recognised under the applicable law.

We retain Personal Data for as long as reasonably necessary to:

• provide the Platform or applicable Program;

• maintain your account;

• administer academic or transactional records;

• fulfil the purpose for which the Personal Data was collected;

• comply with applicable legal, accounting, tax or regulatory requirements;

• resolve disputes; or

• establish, exercise or defend legal claims.

Retention periods may differ depending on the type of Personal Data, the Program and the applicable legal or operational requirement.

When Personal Data is no longer required, we may delete, anonymise or otherwise dispose of it in accordance with applicable law and our retention practices.

Residual copies may remain temporarily in backups or logs maintained through ordinary systems processes.

We maintain reasonable technical, organisational and administrative safeguards designed to protect Personal Data against unauthorised access, use, alteration, disclosure, destruction or loss.

These measures may include access controls, secure hosting, encryption where appropriate, logging, monitoring and internal security processes.

However, no method of transmission, processing or storage can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your account credentials and should notify us if you believe your account has been accessed without authorisation.

Depending on the law applicable to you and the relevant processing activity, you may have rights relating to your Personal Data, including rights to:

• obtain information regarding Personal Data processed about you;

• access Personal Data;

• correct inaccurate or incomplete Personal Data;

• update out-of-date information;

• request deletion or erasure;

• withdraw consent where processing is based on consent;

• object to or restrict certain processing;

• request a portable copy of information where applicable;

• opt out of certain forms of marketing, advertising or data disclosure where applicable;

• raise a grievance or complaint; and

• exercise any other right provided under applicable law.

Where applicable Indian law provides a right to nominate another individual to exercise specified rights in the event of death or incapacity, that right will be facilitated in accordance with law.

These rights are subject to applicable legal conditions, exemptions and limitations.

You may submit a privacy request or grievance by contacting us using the details in Section 19.

We may need to verify your identity before acting on a request.

We will respond to valid requests within the period required under applicable law.

If applicable law provides a right to escalate a grievance to a regulator, authority or data-protection body, you may exercise that right after following such grievance-redressal requirements as may apply.

Varsity is presently intended for persons aged 18 years and above.

We do not knowingly permit individuals under the age of 18 to enrol in Varsity Programs unless a particular Program is expressly made available to them in accordance with applicable law.

If we become aware that Personal Data of a child has been processed without the consent or other safeguards required by applicable law, we will take appropriate steps in accordance with law.

If Varsity introduces Programs for individuals below 18 years of age, additional notices, consent mechanisms and safeguards may apply.

We may use cookies and similar technologies to:

• enable Platform functionality;

• maintain sessions and account access;

• remember preferences;

• understand Platform usage;

• measure performance;

• improve the Platform; and

• support analytics or advertising activities where permitted.

You may be able to manage cookies through your browser or through preference or opt-out controls made available on the Platform.

Disabling certain cookies may affect Platform functionality.

Where applicable law requires consent or other controls for non-essential cookies or similar technologies, those controls will be provided as required. Where applicable law requires us to recognise a legally valid universal opt-out preference signal or provide an opt-out from the sale, sharing or use of Personal Data for targeted advertising, we will provide or honour the applicable mechanism as required by law.

The Platform may contain links to or integrations with third-party websites, applications or services.

We do not control the content, security or privacy practices of independent third parties and are not responsible for their practices.

You should review the relevant third party’s privacy notice before providing Personal Data to it.

If we become aware of a Personal Data breach or security incident, we may take appropriate measures to investigate, contain, remediate and mitigate the incident.

Where applicable law requires notification to affected individuals, governmental authorities, regulators or other bodies, we will make such notification in accordance with applicable requirements.

We may update this Policy from time to time to reflect changes in Varsity, our processing practices or applicable law.

The date at the top of this Policy indicates when it was last updated.

Where a change materially affects your rights or the manner in which we process Personal Data and applicable law requires notice or consent, we will provide such notice or obtain such consent as required.

For privacy-related queries, requests or grievances, please contact:

Grievance Officer: Saurabh Saxena

Email: saurabh@interviewbit.com

Registered Office: Cabin Termed as “Operating System” on the 5th floor premises of Surya Park – II, 5th Floor, Survey No. 91/1, 91/2, 91/3, Veerasandra Village, Hosur Road, Bangalore South, Electronics City, Bengaluru – 560100, Karnataka, India

For general support relating to Varsity:

Email: hello@interviewbit.com

We will address grievances and requests in accordance with applicable law.

This Policy is intended to operate subject to the privacy and data-protection laws applicable to the relevant processing activity. If you reside outside India, additional mandatory privacy rights or obligations may apply to our processing of your Personal Data.

Nothing in this Policy is intended to exclude, waive or restrict any privacy or data-protection right that cannot lawfully be excluded, waived or restricted.

20.1 United Arab Emirates

If you are located in the United Arab Emirates and UAE data-protection law applies to our processing, you may have additional rights in relation to your Personal Data, including rights relating to access or information, correction, erasure, restriction of processing, data portability and certain automated processing, subject to applicable legal conditions and exemptions. Cross-border transfers of Personal Data will be handled in accordance with applicable UAE transfer requirements.

20.2 Kingdom of Saudi Arabia

If you are located in the Kingdom of Saudi Arabia and the Saudi Personal Data Protection Law applies to our processing, you may have additional rights under that law and its implementing regulations. Where required, we will obtain consent before processing Personal Data for direct marketing, provide an accessible mechanism to stop such marketing, and implement applicable safeguards for transfers of Personal Data outside the Kingdom.

20.3 United States

Residents of certain U.S. states may have additional rights under applicable state privacy laws, which may include rights to know or access, correct or delete Personal Data and, where applicable, to opt out of the sale or sharing of Personal Data, targeted advertising or certain profiling. Where a legally valid universal opt-out preference signal is required to be honoured, we will do so in accordance with applicable law. These rights apply only to the extent the relevant law applies to us and to the applicable processing activity.

This Policy should be read together with the Varsity by InterviewBit Terms of Use and any applicable Program Collaterals.