Effective Date: September 9, 2026
1. Introduction and Company Information
This Privacy Policy explains how Sapphire Bharat Learning Inc. (“Sapphire Bharat Learning Inc.”, “we”, “us”, or “our”) collects, uses, discloses, stores, and protects personal information in connection with our Indian-learning services, including educational content, tutoring, classes, assessments, registrations, customer support, and related websites, platforms, communications, and administrative activities (collectively, the “Services”).
We are committed to handling personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable provincial privacy legislation. We strive to collect only the information reasonably necessary for the purposes described in this Privacy Policy and to use that information responsibly and transparently.
Company Name: Sapphire Bharat Learning Inc.
Address: 1450 Main Street East, Unit 204, Hamilton, ON L8K 1C5, Canada
Email: [email protected]
Phone: +1 (905) 487-6392
2. Data Collection and Processing
We may collect personal information directly from you, automatically through your use of our Services, and from authorized third parties where permitted by law. Depending on how you interact with us, we may collect the following categories of information:
- Identification and contact details: name, email address, phone number, postal address, and similar contact information.
- Account and profile information: login credentials, user preferences, class selections, enrollment details, and communication preferences.
- Student and learning information: age or date of birth where necessary, learning level, academic goals, attendance records, progress, feedback, test or assessment results, and class participation information.
- Payment and billing information: billing address, transaction records, invoice details, and payment status. Payment card details are typically processed by third-party payment processors and are not stored by us unless required for legitimate business or legal reasons.
- Device and technical information: IP address, browser type, device identifiers, operating system, access times, log data, and usage analytics.
- Communication content: messages sent to us by email, forms, chat, support requests, surveys, or feedback submissions.
- Marketing and preference information: consent choices, newsletter preferences, and engagement with our communications.
Where we collect information about a child or minor, we do so with appropriate consent from a parent, guardian, or other authorized person, as required by applicable law and the nature of the Services.
We may process personal information using manual and automated means, including collection, recording, organization, storage, use, analysis, disclosure, and deletion.
3. Purpose of Data Processing
We process personal information for the following purposes:
- to provide, operate, maintain, and improve our Services;
- to register users, manage accounts, and verify identities where needed;
- to deliver educational content, tutoring, assessments, and student support;
- to personalize learning experiences and track progress;
- to communicate with users regarding classes, schedules, updates, invoices, support, and policy changes;
- to process payments, issue receipts, and manage billing;
- to administer surveys, feedback, and service quality improvement initiatives;
- to monitor, secure, and troubleshoot our systems and Services;
- to meet legal, regulatory, accounting, and tax obligations;
- to prevent fraud, unauthorized access, misuse, and other harmful activity;
- to market our Services, where permitted by law and subject to applicable consent requirements;
- to establish, exercise, or defend legal claims; and
- for any other purpose to which you consent or that is otherwise permitted or required by law.
4. Legal Basis for Processing
Under Canadian privacy law, personal information is generally processed based on consent, necessity for contractual performance, legitimate business purposes permitted by law, and legal or regulatory obligations. Depending on the circumstance, our processing may rely on one or more of the following grounds:
- Consent: where you have given express or implied consent for us to collect, use, or disclose your personal information.
- Contractual necessity: where processing is necessary to provide the Services you request, such as class enrollment, account management, or customer support.
- Legal obligation: where processing is necessary to comply with applicable laws, lawful requests, or regulatory requirements.
- Legitimate business purposes: where processing is reasonably required to operate, secure, and improve our Services, subject to applicable law and privacy safeguards.
- Protection of interests: where necessary to protect the rights, safety, or property of Sapphire Bharat Learning Inc., our users, or others.
Where consent is required, we will seek it in a form appropriate to the sensitivity of the information and the context of the processing.
5. Data Sharing and Third Parties
We do not sell personal information. We may share personal information with third parties only as necessary and in accordance with this Privacy Policy and applicable law. Such third parties may include:
- Service providers: hosting providers, cloud storage providers, customer support tools, analytics providers, communication platforms, and other vendors that assist us in operating the Services.
- Payment processors and financial service providers: for secure payment processing, fraud prevention, billing, and accounting functions.
- Educational and operational partners: teachers, tutors, instructors, curriculum providers, and contractors engaged to support the delivery of learning services.
- Professional advisors: lawyers, accountants, auditors, insurers, and other professional advisers where necessary for business operations or legal compliance.
- Authorities and legal recipients: law enforcement, regulators, courts, government agencies, or other persons where disclosure is required or permitted by law.
- Business transaction parties: in connection with a merger, financing, acquisition, reorganization, sale of assets, or similar corporate transaction, subject to confidentiality and legal requirements.
We require third-party service providers to protect personal information and use it only for the purposes for which it was disclosed, subject to contractual and legal safeguards.
6. Data Transfer to Third Countries
Some of our service providers, affiliates, or systems may be located outside of Canada, including in other countries that may have different data protection laws than Canada. As a result, your personal information may be transferred to, stored in, or accessed from jurisdictions outside Canada.
When personal information is transferred outside Canada, it may be subject to lawful access by courts, law enforcement, or regulatory authorities in those jurisdictions. We take reasonable steps to ensure that cross-border transfers are protected by appropriate contractual, technical, and organizational safeguards consistent with the sensitivity of the information and applicable legal requirements.
7. Storage Duration
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal, tax, accounting, or regulatory obligations, to resolve disputes, and to enforce our agreements.
The retention period may vary depending on the type of information and the purpose of collection. For example:
- account and customer service records may be retained for the duration of the relationship and for a reasonable period afterward;
- payment and invoicing records may be retained for periods required by tax and accounting laws;
- learning progress and attendance records may be retained as needed to provide educational services and continuity;
- communications and support records may be retained for quality assurance, training, and dispute resolution.
When personal information is no longer required, we will securely delete, anonymize, or de-identify it in accordance with our retention practices and applicable law.
8. User Rights
Subject to applicable law, you may have the right to:
- Access: request access to the personal information we hold about you and obtain information about how it is used and disclosed;
- Rectification: request correction of inaccurate, incomplete, or outdated personal information;
- Erasure: request deletion of your personal information, subject to legal or contractual retention obligations and legitimate exceptions;
- Restriction: request that we limit certain processing of your personal information in appropriate circumstances;
- Data portability: request, where applicable, a copy of certain information in a structured and commonly used format;
- Objection: object to certain processing activities, including certain marketing communications where applicable.
To exercise your rights, please contact us using the details provided below. We may require information to verify your identity before responding to your request. We will respond within the time required by applicable law or, if no specific period applies, within a reasonable time.
In some cases, we may deny or limit a request where permitted by law, such as where fulfilling the request would infringe upon another person’s rights, compromise legal obligations, or be otherwise unlawful.
9. Withdrawal of Consent
Where our processing is based on your consent, you may withdraw that consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
Please note that if you withdraw consent for certain uses, we may not be able to provide some or all of the Services to you. For example, if you withdraw consent for essential account or learning-related processing, we may be unable to continue your enrollment or deliver certain features.
You may also opt out of certain marketing communications by using the unsubscribe link in the communication or by contacting us directly.
10. Right to Complain
If you have a concern about how we handle your personal information, please contact us first so that we can review and address your concern.
If you are not satisfied with our response, you may have the right to file a complaint with the appropriate privacy regulator in Canada. Depending on your circumstances, this may include the Office of the Privacy Commissioner of Canada or a relevant provincial privacy authority.
We encourage you to contact us promptly so that we may attempt to resolve any privacy issue efficiently and in good faith.
11. Data Security
We use reasonable physical, technical, and organizational safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. These safeguards may include, as appropriate:
- access controls and role-based permissions;
- password protection and secure authentication measures;
- encryption in transit and, where appropriate, at rest;
- secure hosting and system monitoring;
- staff confidentiality obligations and privacy training;
- vendor due diligence and contractual protections; and
- incident response procedures for suspected security events.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. However, we continually work to improve our safeguards and respond appropriately to privacy and security risks.
12. Contact Information
If you have questions, requests, or concerns regarding this Privacy Policy or our handling of personal information, please contact:
Sapphire Bharat Learning Inc.
1450 Main Street East, Unit 204, Hamilton, ON L8K 1C5, Canada
Email: [email protected]
Phone: +1 (905) 487-6392
13. Changes to Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will provide notice in a manner appropriate to the circumstances, which may include posting the updated Privacy Policy on our website, sending a notice by email, or otherwise informing you through the Services.
The updated policy will become effective on the date stated at the top of the policy unless otherwise indicated. We encourage you to review this Privacy Policy periodically to stay informed about how Sapphire Bharat Learning Inc. handles personal information.