Privacy Policy

Last updated: 4 December 2025

Our Commitment to Your Privacy

At IPGRAM Learn, we believe in transparency and simplicity. We collect only the bare minimum data necessary to deliver course content and generate certificates. We don't track you, we don't sell your data, and we don't push marketing. Your privacy is non-negotiable.

This Privacy Policy explains how Turnip Innovations Private Limited ("we", "our", or "IPGRAM Learn") collects, uses, and protects your personal data in compliance with India's Digital Personal Data Protection Act, 2023 (DPDP Act).

About Us (Data Fiduciary)

Entity Name: Turnip Innovations Private Limited

Address: Blob Ground Floor, Yamuna Building, 86 Golaghata Road, Dakshindari, Kolkata 700048, West Bengal, India

Email: courses@turnipinno.com

What Data We Collect

We collect only the essential information needed to provide our educational services:

1. Information You Provide

  • Name: To personalize course content and certificates
  • Email Address: To deliver course modules and verify your identity
  • Organization Email Domain: To verify your organizational affiliation

2. Information Generated During Use

  • Course Enrollment Records: Which courses you've enrolled in
  • Quiz Scores: Your performance in course assessments
  • Certificates: Completion certificates with unique IDs
  • Email Engagement: Basic delivery status (sent/opened) for course emails

3. Technical Data (Minimal)

  • Login Sessions: Essential cookies for authentication (OTP-based, no passwords)
  • IP Address: For security and fraud prevention only

✓ What We DON'T Collect:

  • Tracking cookies or analytics beyond essential functionality
  • Browsing behavior or third-party tracking pixels
  • Passwords (we use OTP-based authentication)
  • Financial information (courses are free under organizational subscriptions)
  • Any data unrelated to course delivery

How We Use Your Data

Your data is used exclusively for legitimate educational purposes:

  • Delivering daily course modules via email
  • Verifying your identity during enrollment and quiz access
  • Generating and issuing completion certificates
  • Providing course progress reports to your organizational administrator
  • Responding to your support requests
  • Complying with legal obligations

Cookies & Tracking

We use ONLY essential cookies. No tracking, no analytics, no marketing cookies.

Essential cookies are necessary for login sessions and OTP verification. These expire when you close your browser or after a set period for security. You can disable cookies in your browser, but this may prevent you from accessing certain features.

Who We Share Your Data With

1. Your Organization

If you enrolled through an organizational subscription, your organization's administrator can view:

  • Your name and email
  • Course enrollment status
  • Email engagement metrics
  • Quiz scores and completion status
  • Certificates earned

This data sharing is based on your organization's agreement with us and is necessary for organizational learning management.

2. Service Providers (Data Processors)

We use trusted third-party services to deliver our platform. These providers process data only on our behalf and under strict contractual obligations:

  • SendGrid (Twilio): Email delivery for course content, OTPs, and certificates
  • Google Cloud Platform: Hosting, database, and secure file storage

These providers have their own privacy policies and data protection measures. We select providers with strong security and compliance standards.

✗ We NEVER Share Your Data With:

  • Advertisers or marketing companies
  • Data brokers or analytics firms
  • Social media platforms
  • Any third party for commercial purposes

We do not sell, rent, or monetize your personal data. Period.

Public Certificate Verification

Certificates are publicly verifiable using their unique certificate ID. Anyone with the certificate ID can verify the authenticity of a certificate, which will display the recipient's name, course name, completion date, and score. This is necessary to prevent fraud and ensure credential integrity.

Data Storage & Security

Where Your Data is Stored

Your data is primarily stored on Google Cloud Platform servers. While we strive to keep data within India, some data may be processed internationally by our service providers (Google Cloud, SendGrid) in accordance with their global infrastructure. These providers comply with international data protection standards.

How We Protect Your Data

  • Industry-standard encryption for data in transit (HTTPS/TLS)
  • Encrypted storage for sensitive data
  • OTP-based authentication (no password storage vulnerabilities)
  • Regular security audits and updates
  • Restricted access controls for our team
  • Secure database configurations with access logging

Note: While we implement robust security measures, no system is 100% secure. We commit to notifying you promptly in the event of any data breach affecting your personal information.

How Long We Keep Your Data

We retain your personal data only as long as necessary for the purposes outlined in this policy:

  • Active Enrollments: Throughout your course enrollment and for a reasonable period after completion
  • Certificates: Retained indefinitely for verification purposes and as proof of achievement
  • Quiz Records: Retained for institutional record-keeping and certificate validity
  • Email Records: Delivery logs retained as per SendGrid's retention policies

You may request deletion of your data at any time (see Your Rights section below). However, we may retain certain information if required by law or for legitimate purposes (e.g., certificate verification).

Your Rights Under DPDP Act

As a data principal under India's DPDP Act, you have the following rights:

✓ Right to Access

Request a summary of your personal data we hold and how it's being used.

✓ Right to Correction

Request correction of inaccurate or incomplete personal data.

✓ Right to Erasure

Request deletion of your personal data (subject to legal retention requirements).

✓ Right to Grievance Redressal

Lodge complaints about how we handle your data and receive timely responses.

✓ Right to Nominate

Nominate another person to exercise your rights in case of death or incapacity.

✓ Right to Withdraw Consent

Withdraw your consent for data processing at any time (may affect service delivery).

How to Exercise Your Rights

To exercise any of these rights, contact our Data Protection Officer:

Response Time: We will respond to your request within 1-5 business days.

Children's Privacy

Our platform is designed for users aged 15 and above. If you are under 18 years old, we recommend obtaining parental consent before enrolling in courses. We do not knowingly collect data from children under 15 without verifiable parental consent. If we discover such data has been collected, we will delete it promptly.

No Marketing, No Upselling

We are committed to ad-free, distraction-free learning.

You will only receive emails related to your enrolled courses (course content, OTPs, quiz results, and certificates). We will never send you marketing emails, promotional content, or spam. We have no third-party advertising or sponsored content in our communications.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by updating the "Last Updated" date at the top of this page. For material changes, we may also send an email notification to your registered email address. We encourage you to review this policy periodically.

Grievance Redressal

If you have any concerns or complaints about how we handle your personal data, please contact our Data Protection Officer:

Data Protection Officer

Name: Rahul Kapoor

Email: rkapoor@ipgram.in

Alternate: courses@turnipinno.com

Response Timeline: 1-5 business days

If you are not satisfied with our response, you have the right to lodge a complaint with the Data Protection Board of India as per the DPDP Act.

Contact Us

For any questions about this Privacy Policy or our data practices, please contact us:

Turnip Innovations Private Limited

Blob Ground Floor, Yamuna Building

86 Golaghata Road, Dakshindari

Kolkata 700048, West Bengal, India

Email: courses@turnipinno.com

Governing Law

This Privacy Policy is governed by the laws of India, including the Digital Personal Data Protection Act, 2023. Any disputes arising from this policy shall be subject to the exclusive jurisdiction of the courts in Kolkata, West Bengal, India.

Our Promise to You

At IPGRAM Learn, we believe in earning your trust through transparency and respect for your privacy. We collect only what we need, protect what we collect, and use it only for what we promised. Your learning journey should be focused on growth, not concerns about data misuse. That's our commitment.