PRIVACY POLICY

SHIXA COACHING MANAGEMENT PLATFORM

Last Updated: April 16, 2026

This Privacy Policy ("Policy") governs the collection, processing, storage, disclosure, and protection of personal information and data by Shixa managed by Suprabhat Jana and Subhrajyoti Sahoo (hereinafter referred to as "Company," "we," "us," or "our"), the owner and operator of the Shixa platform ("Platform" or "Shixa"), accessible through web application and mobile application.

This Policy is published in accordance with the provisions of the Information Technology Act, 2000 ("IT Act"), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("SPDI Rules"), the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and other applicable laws in India.

By accessing or using the Shixa Platform, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy.

1. DEFINITIONS

• 1.1. "Coaching Institute" or "Institute" means any educational coaching center, tutorial, academy, or similar institution that registers and subscribes to use the Shixa Platform for managing its operations.
• 1.2. "Data Controller" means the Coaching Institute that determines the purposes and means of processing Personal Data of Students and other Users through the Platform.
• 1.3. "Data Processor" means Shixa (operated by the Company), which processes Personal Data on behalf of and under the instructions of the Coaching Institute.
• 1.4. "Personal Data" or "Personal Information" means any information relating to an identified or identifiable natural person, including but not limited to name, contact details, identification documents, photographs, educational records, and financial information.
• 1.5. "Sensitive Personal Data or Information" ("SPDI") means Personal Data consisting of information relating to:
  • (a) Passwords and financial information such as bank account details, credit card details, debit card details;
  • (b) Biometric information;
  • (c) Any detail relating to the above as provided to the Platform for providing services;
  • (d) Any information received under the above by the Platform for processing or storage.
• 1.6. "Student" means any individual enrolled or registered with a Coaching Institute that uses the Shixa Platform, including minors below the age of eighteen (18) years.
• 1.7. "Teacher" or "Educator" means any individual employed by or associated with a Coaching Institute who uses the Platform to conduct teaching, assessment, or administrative functions.
• 1.8. "User" means any person or entity accessing or using the Shixa Platform, including Coaching Institutes, Teachers, Students, parents, guardians, and administrators.
• 1.9. "Services" means all features, functionalities, and services provided through the Shixa Platform.

2. SCOPE AND APPLICABILITY

• 2.1. This Privacy Policy applies to all Users of the Shixa Platform, including but not limited to:
  • (a) Coaching Institute administrators and owners;
  • (b) Teachers and educators;
  • (c) Students;
  • (d) Parents and legal guardians of Students;
  • (e) Any other person accessing the Platform.
• 2.2. This Policy applies to Personal Data collected through:
  • (a) The Shixa web application;
  • (b) The Shixa mobile application (Android and iOS);
  • (c) Application Programming Interfaces (APIs);
  • (d) Any other medium through which the Platform may be accessed.
• 2.3. This Policy does not apply to third-party websites, applications, or services that may be linked to or integrated with the Platform.
• 2.4. The territorial scope of this Policy extends to all data processing activities conducted within India and, where applicable, to cross-border data transfers.

3. INFORMATION COLLECTED

3.1. PERSONAL INFORMATION OF STUDENTS

• (a) Identity Information: Full name, date of birth, age, gender, photograph;
• (b) Contact Information: Email address, phone number, residential address;
• (c) Educational Information: Class, batch, course enrolled, roll number;
• (d) Academic Records: Attendance records, test scores, examination results;
• (e) Financial Information: Fee payment records, transaction history;
• (f) Guardian Information: Parent or guardian name, contact details;
• (g) Documents: Identification documents, certificates, or other records uploaded.

3.2. PERSONAL INFORMATION OF TEACHERS AND EDUCATORS

• (a) Identity Information: Full name, date of birth, gender, photograph;
• (b) Contact Information: Email address, phone number, address;
• (c) Professional Information: Qualifications, subjects taught, employment details;
• (d) Account Credentials: Username, encrypted password;
• (e) Activity Data: Classes conducted, attendance marked, assessments created.

3.3. PERSONAL INFORMATION OF COACHING INSTITUTES

• (a) Institution Details: Name, registration details, address;
• (b) Administrator Information: Name, email, phone number;
• (c) Business Information: Number of students, batches, subscription plan;
• (d) Payment Information: Bank account details, GST number, billing address.

3.4. TECHNICAL AND USAGE INFORMATION

• (a) Device Information: Device type, operating system, identifiers;
• (b) Usage Data: Pages accessed, features used, time spent;
• (c) Log Data: IP address, access times, error logs;
• (d) Location Data: Approximate geographic location derived from IP address.

4. PURPOSE OF DATA PROCESSING

4.1. SERVICE DELIVERY: To provide, maintain, and improve the Platform and Services; to enable Coaching Institutes to manage students, batches, attendance, and fees; to facilitate communication; to process fee payments.

4.2. ACCOUNT MANAGEMENT: To create and manage User accounts; to authenticate Users and maintain security; to provide technical support.

4.3. COMPLIANCE: To comply with applicable laws and protect safety and rights.

6. DATA CONTROLLER AND PROCESSOR RELATIONSHIP

6.1. COACHING INSTITUTE AS DATA CONTROLLER: Each Coaching Institute acts as a Data Controller. The Institute determines what data to collect and the purposes for processing. They are responsible for obtaining necessary consents, including parental consent for minors.

6.2. SHIXA AS DATA PROCESSOR: Shixa acts as a Data Processor, processing Personal Data only in accordance with documented instructions from the Coaching Institute and maintaining confidentiality and security.

14. CHILDREN'S DATA AND PROTECTION OF MINORS

Coaching Institutes are responsible for verifying the age of Students and obtaining verifiable parental or legal guardian consent. Shixa does not knowingly collect Personal Data directly from children without such consent. Parents or guardians have the right to review, correct, or delete their child's Personal Data.

15. USER-GENERATED CONTENT

Users are responsible for ensuring they have the legal right to upload study notes, documents, and media. Shixa acts as a neutral platform provider and does not claim ownership or assume responsibility for the legality of uploaded content.

17. GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by the laws of India. The courts of Bhubaneswar, Odisha shall have exclusive jurisdiction.

19. CONTACT INFORMATION

COMPANY NAME: Shixa managed by Suprabhat Jana and Subhrajyoti Sahoo

ADDRESS: Bhubaneswar, Odisha - 751024, India

EMAIL: jsubhra502@gmail.com

GRIEVANCE OFFICER: Subhrajyoti Sahoo (Founder) - jsubhra502@gmail.com

21. ACKNOWLEDGMENT AND CONSENT

By accessing the Shixa Platform, you acknowledge you have read and consent to this Privacy Policy. If you do not agree, please do not access or use the Platform.

Authorized Signatory: Subhrajyoti Sahoo (Founder)

Date: 16.04.2026

END OF PRIVACY POLICY