In addition to our Terms and Conditions, Top One Percent respects your privacy and is committed to protecting your personal data. This Privacy Policy (“Policy”) explains how BOLD Education Private Limited, a company incorporated under the laws of India (“Top One Percent”, “Company”, “we”, “us”, or “our”), collects, uses, shares, stores, and protects personal data of individuals (“you”, “your”, or “User”) who access or use our website, application, products, or services (“Services”).

This Policy is framed in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and applicable rules thereunder.

By accessing or using our Services, or by providing your personal data, you acknowledge that you have read and understood this Policy.

A. APPLICABILITY

This Policy applies to all Users who:

• Visit our website or application
• Inquire about our courses or services
• Enroll in any program offered by Top One Percent

We process personal data only for lawful purposes and in a manner that is fair, transparent, and compliant with applicable data protection laws.

B. DATA FIDUCIARY

For the purposes of the DPDP Act, Top One Percent is the “Data Fiduciary”, meaning the entity that determines the purpose and means of processing your personal data.

C. PERSONAL DATA WE COLLECT

1. Personal Data

“Personal Data” means any data about an individual who is identifiable by or in relation to such data.

We may collect the following categories of personal data:

• Name
• Email address
• Phone number
• Age
• Gender
• City / location
• Photograph (if voluntarily provided)
• Communication details shared with us


2. Usage and Technical Data

We may automatically collect limited technical data such as:

• Browser type
• Device information
• IP address
• Operating system

This data is used only for analytics, security, and service improvement purposes.

D. PURPOSES OF PROCESSING

We process your personal data only for the following purposes:

1. To respond to inquiries and provide requested information
2. To enroll you in courses and deliver our Services
3. To communicate important service-related information
4. To improve user experience and platform functionality
5. To send marketing communications only where you have provided consent
6. To comply with legal or regulatory obligations
7. To establish, exercise, or defend legal claims

E. LEGAL BASIS FOR PROCESSING

We process personal data based on one or more of the following lawful grounds under the DPDP Act:

1. Consent

Where required, we collect your free, specific, informed, and unambiguous consent before processing your personal data.

You may withdraw your consent at any time by contacting us (see Section K).

2. Legitimate Uses

We may process personal data without consent where permitted under the DPDP Act, including:

• For performance of a contract
• For compliance with legal obligations
• Where you voluntarily provide personal data for a specified purpose

F. SHARING OF PERSONAL DATA

We do not sell or rent your personal data.

We may share personal data only with:

• Authorized service providers (technology, payment, CRM, analytics)
• Professional advisors (legal, accounting, auditors)
• Government or regulatory authorities where legally required

All such sharing is subject to contractual confidentiality and data protection obligations.

G. DATA RETENTION AND DELETION

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable law.

Personal data is securely deleted or anonymized once:

• The purpose of processing is fulfilled, and
• There is no legal requirement to retain it further

H. DATA SECURITY SAFEGUARDS

We implement reasonable technical and organizational security measures to protect personal data, including:

• Access controls
• Encryption where appropriate
• Secure servers
• Internal data access restrictions

I. DATA BREACH MANAGEMENT

In the event of a personal data breach, we shall:

• Take prompt remedial action
• Notify the Data Protection Board of India and affected Users, where required under law

J. YOUR RIGHTS AS A DATA PRINCIPAL

Under the DPDP Act, you have the right to:

• Access information about your personal data
• Request correction or erasure of personal data
• Withdraw consent for processing
• Seek grievance redressal
• Nominate another individual to exercise your rights in the event of death or incapacity

Requests can be made as per the details in Section K.

K. GRIEVANCE REDRESSAL

If you have any concerns or requests relating to your personal data, you may contact us at info@top-one-percent.com

We will respond to grievances within the timelines prescribed under applicable law.

L. THIRD-PARTY LINKS

Our Services may contain links to third-party websites. We are not responsible for the privacy practices of such third parties. You are encouraged to review their privacy policies independently.

M. CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in law, technology, or business practices. Updated versions will be posted on our website with the revised effective date.

Continued use of our Services after such updates constitutes your acknowledgment of the revised Policy.