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Privacy Policy





  1. This website and the domain name, stratoedu.com (the “Website”) is owned by Stratosphere Education Private Limited, a private company limited by shares, incorporated and organized under the Companies Act, 2013 having its registered office at 166/C/505 Lake Gardens, Kolkata – 700045, State West Bengal, India (hereinafter referred to as “SEPL”).


  1. This electronic record publishes the privacy policy (the "Privacy Policy") of this Website as required under:
  • Section 43A of the Information Technology Act, 2000 (the "ITAct");
  • Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the "Rules"); and
  • Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 (“Intermediaries Rules”).

       The aforesaid provisions require publishing rules and regulations, privacy policy and terms of use for access or usage of this Website. The Act, the Rules and the Information         Technology (Intermediaries Guidelines) Rules, 2011, shall hereinafter be collectively referred to as "IT Laws".

  1. This document is an electronic record in terms of the IT Act and Rules thereunder as applicable and as amended from time to time, and also an electronic record within the meaning of all applicable statutes as amended by the IT Act. This electronic record is generated by a computer system and stored therein and does not require any physical or digital signatures. In accordance with the provisions of Section 4 of the IT Act, this Privacy Policy which shall be deemed to be an integral part of the Terms of Use, a contract between the User and SEPL, which shall be deemed to have been received, accepted and formed at Kolkata (wherein the registered office of SEPL is situated).


  1. This Privacy Policy shall be deemed to be an integral part of the Terms of Use of this Website and users (the "Users") of the Website shall be deemed to have accepted the terms of this Privacy Policy and agreed to adhere to the same by the act of accessing the Website for using the products or services provided in the Website or consummates a transaction on the Website, including without limitation, during:
  1. General browsing of the Website;
  2. Placing a request for further information in relation to the products and services of SEPL (“Request for Further Information”)
  3. Placing an order on SEPL for availing of the products and/or consultancy and/or other services of SEPL through this Website (“Business”);
  4. During submission of personal information by any User in relation to the Business of this Website.

Reference to the term you/your shall mean the User of the Website and the term we/us refer to SEPL.

  1. By accessing, downloading, installing or use of this Website, the User is deemed to have perused and accepted the Privacy Policy contained herein and as revised from time to time, which is, for an indefinite period and the User understands and agrees that the User is bound by the Privacy Policy till the time the User accesses or uses the facilities on the Website. If the User does not agree to all of the terms of this Privacy Policy, the User may not access, use or access any part of the Website.
  1. SEPL reserves the right to change and/or amend the Privacy Policy from time to time without any obligation to inform the User and it is the responsibility of the User to peruse the Website and more particularly this Privacy Policy from time to time. For the aforementioned purposes, the Parties hereby agree that Privacy Policy being concluded and executed at Kolkata (wherein the registered office of SEPL is situated).


  1. The protection of the privacy of the Users of our Website is a very important principle for SEPL. SEPL understands clearly that the User’s Personal Information is one of SEPL’s most important information assets. SEPL stores and processes User Information including any sensitive financial information collected (as defined under the IT Act), if any, on computers that are protected by physical as well as reasonable technological security measures and procedures in accordance with the Privacy Laws. If the User objects to User Information being transferred or used in this way the User should not proceed to use the Website.
  1. The User acknowledges and understands that in relation to the conduct of the Business through the Website, SEPL may require and solicit, obtain, receive "personalinformation" and "sensitive personal data or information" pertaining to the Users, as set out below.

The term "personal information" (the "Personal Information"), in terms of the extant statutory provisions means, "any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person”. Such personal information may pertain to & include:

  1. Full & Complete Name, age, gender, address and contact phone number (Mobile and/or Landline) of the User;
  2. Physical & demographic information of the individual User necessary to ascertain the products and/or services of SEPL appropriate for such User;
  3. Email address, user name and password for the purpose of registering the User as a registered user;
  4. User’s Computer IP Address
  5. User’s financial & tax related information, proof of identification / address related information (including passport details), educational qualification related information (including educational institution/university related details), choices/preferences with regard to further academic study / courses/ universities & educational institutions etc
  6. Information regarding payment gateway i. e. bank account & other relevant details etc. for the payment the user needs to make to access the services of SEPL

The term “sensitive personal data or information” ("SPDI"), in terms of the extant statutory provisions means, such Personal Information which consists of information relating to –

  1. Password;
  2. Financial information such as bank account or credit card or debit card or other payment instrument details;
  3. Physical, physiological and mental health conditions;
  4. Sexual orientation;
  5. Medical records and history;
  6. Biometric information;
  7. Any detail relating to the above clauses as provided to body corporate for providing service; and
  8. Any of the information received under above clauses by body corporate for processing, stored or processes under lawful contract or otherwise.

Any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information.


  1. The Personal Information and SPDI (and such documentation, data/information which is required in substantiation thereof) solicited, obtained and received from a User in accordance with the terms of the Privacy Laws will be used by SEPL solely for the purpose of processing and executing orders in relation to the Business or Request for Further Information received from such User through the Website, which constitutes the performance of a lawful and valid contract between SEPL and the User.

Use of Personal Information & SPDI for the purposes of Business & Request for Further Information would include (but would not be limited to) the following end-use:-

  • To provide and maintain SEPL’s Service, including to monitor the usage of SEPl’s Service.
  • To manage User Account: The Personal Information provided to SEPL may allow the User the access to different functionalities of the Service that are available to the User.
  • For the performance of the contract with SEPL: the development, compliance and undertaking of the contract for the products/services 
  • To contact User: To contact User by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide User with news, special offers and general information about other products/ services and events offered by SEPL that are similar to those that User has already contracted for or enquired about (unless User has opted not to receive such information)
  • To manage User requests placed with SEPL
  • To maintain a database for internal analysis, to improve the functionality of SEPL’s Service etc

 All Personal Information and SPDI obtained or received by SEPL on the Website will be accessed, utilized and retained only by SEPL and its authorized personnel for the purpose for which it would be collected.


  1. The Personal Information & SPDI to be collected may depend upon the type of service sought by the User. As such, the User may be required to provide such Personal Information and SPDI on the Website as may be deemed necessary & essential by SEPL in the context of services sought from & rendered by SEPL.

The Website would indicate / highlight, in a suitable manner, all such information so deemed necessary & essential and consequently which is to be provided by the User.

With regard to Personal Information & SPDI, the submission of which is not necessary or essential – but which is routinely solicited by the Website - the User is strongly advised to provide such Personal Information or SPDI through the exercise of his/her sole judgment and discretion. In case such information is voluntarily provided by the User – it would be deemed that such information is being collected by SEPL for a lawful purpose connected with the functions/activities of SEPL and no recourse would be available to the User to claim otherwise. In the event the User is not desirous of providing any Personal Information or SPDI which is otherwise not necessary or essential, the User may abstain from providing such information without any loss of functionality in the use of the Website. In case the User is unwilling to provide the Personal Information or SPDI which is deemed necessary & essential by SEPL for the provision of its services - the User may discontinue use of the Website or abstain from carrying out any transaction pertaining to the Business.

  1. Where SEPL collects the information directly from the User, such User would be held to be fully in the knowledge of:

(a) the fact that the information is being collected;

(b) the purpose for which the information is being collected;

(c) the intended recipients of the information; and

(d) the name and address of the entity (viz. SEPL & its authorized personnel) collecting & retaining information

   However, SEPL shall not be responsible for the authenticity of the personal information or sensitive personal data or information supplied by the User.

  1. In the event the User is desirous of amending or modifying Personal Information or SPDI provided to SEPL on the Website, the User may do so by visiting his/her profile page on the Website. SEPL freely permits deletion, modification and augmentation of all information provided on the Website.
  1. SEPL will retain the User’s Personal Information / SPDI for as long as is necessary for the purposes set out in this Privacy Policy. SEPL may retain and use the personal information/data to the extent necessary to comply with requirements of statute, legal obligations, resolve disputes, and enforce our legal agreements and policies.

User’s personal information is processed at SEPL’s operating offices and in any other places where the parties involved in the processing are located. The information may be transferred to and maintained on computers located outside User’s location where the data protection laws may differ than those from User’s jurisdiction. SEPL shall make all reasonable efforts to ensure that the destination(s) of the transfer of data is subjected to the same level of data-protection norms, policies & procedures as in India. Where any express consent to data transfer is not obtained – the User’s consent to this Privacy Policy as evidenced, inter-alia, by submission of such information by the User to SEPL - represents the User’s consent to such transfer with no recourse to the User to claim otherwise.

  1. SEPL will not, subject to this clause, disclose, without prior consent, any Personal Information or SPDI except to governmental authorities, regulatory bodies & other stake-holders & third-parties where such disclosure is requisitioned under any Indian law or judicial decree. SEPL may, in connection with Business or Request for further Information or for the execution of any other contractual obligation arising in the provision of services to the User, be required (such requirement being implied from the nature of service to be rendered or in respect of which express consent is obtained from the User) to share the personal information / SPDI of the User with other service providers for the full & proper rendering of services. Where the nature of service implicitly requires & connotes the sharing of personal information & SPDI with other service providers such that execution of the service required by the User cannot be performed without such sharing, then in the absence of express permission – the User assent to sharing such information would be deemed to be in place regardless of whether the business transaction is ultimately carried out. The personal information /SPDI shall not be published by SEPL.
  1. The Website uses temporary cookies to store certain data (that is not SPDI or Personal Information) that is used by SEPL for the technical administration of the Website, research and development, and for User administration. These cookies are intended to be automatically cleared or deleted when the User quits the browser application supporting access to the Website. All Users are, however, encouraged to use the "clear cookies" functionality of their browsers to ensure such clearing/deletion, since it is impossible for SEPL to guarantee, predict or provide for the behaviour of every User’s equipment.
  1. SEPL’s Website may contain links to other websites that are not operated by it. The User may be directed to a third party’s website on clicking the link. It is strongly advised that the User verifies the Privacy Policy of every site so visited via a link. SEPL would have no control over and assumes no responsibility for the content, privacy policies or practices of any third party sites or services.
  1. Subject to the provisions of the Terms of Use as regards the execution of orders relating to the Business, the User is free to withdraw consent given to SEPL for use of his/her Personal Information or SPDI. Upon receipt of information by SEPL indicating withdrawal of consent to the use of User’s Personal Information or SPDI, SEPL shall forthwith abstain from using such information and transacting Business thereof, provided that the User discontinues any further use of this Website. Notwithstanding the foregoing, the Privacy Policy set out herein shall, without exception, be applicable at all times to any purported transaction(s) approved by acceptance of an order already placed by the User on SEPL or affect any liability that may have arisen against the User or any liability that may have arisen under Privacy Policy.


  1. In accordance with the requirements under extant statutes, SEPL has implemented Indian legal industry standard security policies, rules and technical measures to protect the SPDI and Personal Information under its control, from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.



  1. The User acknowledges and agrees that SEPL shall not be liable to the User, or to anyone claiming through such User for any indirect, special, consequential, incidental, punitive or exemplary damages or losses, arising from, connected with or directly or indirectly related to the use of or inability to use the Website, or the contents, material, functions or Business related thereto, or User’s provision of information on, by or through the Website, or for loss of anticipated savings, opportunity, revenue, profit or goodwill, or other economic loss; however caused, and whether arising under contract, tort (including negligence) or otherwise, and even if such User has intimated or advised SEPL, of the possibility of such loss or damages, or SEPL is, or should reasonably have been aware of such possibility. Without prejudice to the aforesaid, the total aggregate liability of SEPL, its directors, officers, employees and/or agents for all damages, losses, and causes of action (whether in contract or tort, including, without limitation, negligence or otherwise) arising from this Privacy Policy and/or the Terms of Use and/or the Website, shall not exceed the aggregate Price of such Business ordered or purchased by the User, and in any other case, Rs. 1.000/- (Rupees One Thousand Only).


  1. SEPL hereby undertakes to carry out all measures necessary to address discrepancies and grievances of the Users providing Personal Information or SPDI, with respect to the manner in which such Personal Information or SPDI is handled or processed by SEPL. The name and contact details of the Grievance Officer are provided below:

Name: Mrs. Priyanka Mitra

Designation: Chief Operating Officer

Stratosphere Education Private Limited

Address: 30A, Southern Avenue, Kolkata 700026

Phone: 9073369982/ 9874011122

Email: enquiries@stratoedu.com

All grievances are intended to be acted upon expeditiously, but not longer than a month from the date of receipt of the grievance.


  1. This Privacy Policy shall be governed and construed in accordance with the laws of India, without giving effect to the principles of conflict of laws thereunder and the competent Courts/Tribunals at Kolkata (within whose territorial jurisdiction, the registered office of SEPL is situated) shall have the exclusive jurisdiction in any proceedings arising out of this Privacy Policy or the use of the Website.