1.1 Applicability and Data Fiduciary

This Privacy Policy applies to Grow, operated by Physiosimplified Private Limited, through https://www.physiosimplified.com/grow and related forms, dashboards, payment pages, communication channels, support systems, communities, and service workflows.

For this service, Physiosimplified acts as the Data Fiduciary for digital personal data collected from users, learners, subscribers, clients, community members, and persons who communicate with the platform. The service collects data only for lawful, specific, transparent, and service-connected purposes.

 

1.2 Legal Framework

This policy is intended to operate in accordance with Indian legal requirements applicable to digital education, e-commerce, data protection, cyber security, consumer grievance handling, and intellectual property protection, including:

• Information Technology Act, 2000, and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

• Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, to the extent platform and grievance practices are relevant.

• Digital Personal Data Protection Act, 2023, including notice, consent, Data Principal rights, withdrawal, grievance redressal, reasonable security safeguards, and breach governance.

• Consumer Protection (E-Commerce) Rules, 2020, including clear business identity, refund transparency, grievance acknowledgement within 48 hours, and redressal within one month.

• Copyright Act, 1957, including civil remedies for infringement such as injunctions, damages, account of profits, and related relief.

 

1.3 Categories of Personal Data Processed

The categories of personal data processed for Grow include the following, depending on the user interaction:

• identity and contact details

• subscription and payment data

• test attempts

• question responses

• scores

• rank/progress analytics where available

• custom test settings

• dashboard usage logs

• device/session logs

• cookies

 

1.4 Notice of Consent and Purpose of Data Collection

By registering, purchasing, subscribing, uploading files, joining a community, submitting a form, or using Grow, the user provides free, specific, informed, and affirmative consent for the following processing purposes:

Data Category

Purpose of Processing

Identity and contact details

Account creation, user verification, support, communication, access management, grievance handling

Payment and transaction data

Payment confirmation, invoices, refunds, failed/duplicate transaction verification, tax/accounting records

Technical logs and cookies

Secure login, platform performance, fraud prevention, analytics, consent management, debugging

Support and complaint records

Customer service, grievance resolution, audit record, legal defence, service improvement

Test attempts, answers, scores, and analytics

Practice tests, progress tracking, performance reports, dashboard insights, exam-preparation feedback

Subscription and plan data

Plan activation, renewal/cancellation management, free-trial management, billing support

 

1.5 No Third-Party Sale and Limited Vendor Sharing

Physiosimplified does not sell, rent, trade, or monetise user personal data. Personal data may be shared only with essential processors and service providers required for service delivery, including hosting providers, payment gateways, learning or dashboard infrastructure, email/SMS/WhatsApp communication tools, analytics providers, security tools, accountants, auditors, legal advisors, and government authorities where legally required.

Vendor access must be purpose-limited, access-controlled, and restricted to what is necessary for the relevant service.

 

1.6 User Rights and Request Workflow

Users may exercise Data Principal rights by emailing support@physiosimplified.com from their registered email address with an appropriate subject line such as Access Request, Correction Request, Erasure Request, Consent Withdrawal Request, or Grievance.

Physiosimplified may verify identity before acting on a request. Requests may be refused or limited where retention or processing is required for tax, accounting, fraud prevention, dispute resolution, platform security, academic integrity, contractual enforcement, legal compliance, or protection of another person’s rights.

1. Right to access information about personal data processed and processing purposes.

2. Right to correct inaccurate or outdated personal data.

3. Right to complete incomplete data needed for service delivery.

4. Right to request erasure of data no longer necessary for the disclosed purpose, subject to lawful retention.

5. Right to withdraw consent for consent-based processing.

6. Right to grievance redressal.

7. Right to nomination where applicable under Indian data protection law.

 

1.7 Consent Withdrawal

Withdrawal of consent does not affect lawful processing already completed before withdrawal. Withdrawal may restrict or prevent service delivery, including access to paid content, active subscriptions, community participation, support, refunds, invoices, dashboard analytics, research revisions, or account communication.

Physiosimplified may continue to retain limited data where necessary for legal obligations, dispute resolution, payment records, academic integrity, fraud prevention, cyber security, or statutory compliance.

 

1.8 Data Retention

Record Type

Retention Limit

Account and profile data

Active account period plus up to 3 years after inactivity, unless longer retention is legally required

Test attempts, scores, analytics, subscription records

Active subscription/account period plus up to 3 years for progress continuity, fraud prevention, analytics, and support

Payment, invoice, tax, and accounting records

Up to 8 years or as required under applicable tax/accounting laws

Complaint and grievance records

Up to 5 years from closure

Security logs

Up to 24 months unless required for investigation or legal enforcement

Cookie consent records

Up to 24 months or until refreshed by the user

 

1.9 WhatsApp and Community Privacy

Grow may use WhatsApp, email, or similar communication channels for service coordination, announcements, reminders, support, and professional community interaction. Users must provide affirmative opt-in before being added to WhatsApp groups or communities.

Users acknowledge that WhatsApp group participation may make their phone number, profile name, and profile image visible to other group members. Users must not scrape, export, copy, sell, contact, harass, profile, or commercially exploit other members. Violation may lead to removal without refund, account suspension, and legal action.

 

1.10 Security, Breach Handling, and Grievance

Physiosimplified implements reasonable technical, organisational, and contractual safeguards including access controls, secure payment integration, limited administrative access, restricted file access, internal confidentiality practices, backup controls, security logs, and reasonable monitoring against unauthorised access or misuse.

Privacy, refund, access, service, account, copyright, or grievance complaints may be emailed to support@physiosimplified.com. The Grievance Officer is Mr. Pankaj Girish Pandey, Director. Consumer complaints shall be acknowledged within 48 hours and redressed within one month from receipt, subject to verification, user cooperation, third-party timelines, and legal requirements.