Privacy Policy

Headstart, a product offered by Headstart Infotech OPC Private Limited (“Headstart”, “Company”, “we”, “us”, “our”). This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you use our Services.

If you are considered a minor under the laws applicable in your country or region, you may use the Services only with the involvement and valid consent of your parent or legal guardian. By permitting you to use the Services, your parent or legal guardian confirms that they have reviewed and agreed to this Privacy Policy and the Terms of Service on your behalf. If such review and consent are not provided, you must not access or use the Services.

By accessing or using our Services, interacting with any content on our website, submitting your information to us, or otherwise engaging with Headstart, you acknowledge that you have read and understood this Privacy Policy. We process personal data on an appropriate lawful basis under applicable Indian data protection law and, where consent is required, we will specifically obtain it.

If you do not agree with the terms of this Privacy Policy, please discontinue use of the Services.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. When updates are made, we will revise the “Last Updated” date at the top of this Policy.

Definitions

For the purposes of this Privacy Policy:

  • Personal Data: Any information that identifies or can reasonably be used to identify an individual.
  • Processing: Any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
  • Data Fiduciary: The entity that, alone or jointly with others, determines the purpose and means of processing Personal Data
  • Data Processor: The entity that processes Personal Data on behalf of a Data Fiduciary.
  • Customer: An educational institution or organisation that uses Headstart’s Services.
  • User: An employee, representative, agent, or appointee of a Customer who accesses the platform.
  • Applicant / Lead: A prospective student or individual whose information is submitted through admissions or enquiry workflows managed on behalf of a Customer.
  • Device Data: Information automatically collected from your device, such as IP address, browser details, and operating system.
  • Cookies: Small text files stored on your device that support functionality, analytics, or preferences.

1. Who We Are

Headstart is a product of Headstart Infotech OPC Private Limited, a company incorporated under the Companies Act, 2013, India (CIN: U72900KA2021OPC151778, GSTIN: 29AAFCH9455G1Z5).

Registered Office: BTM Layout 2nd Stage, Bannerghatta Road, Bangalore, Karnataka – 560076, India.

Depending on how you interact with us, Headstart may act either as a Data Processor or as a Data Fiduciary.

When We Act as a Data Processor

We act as a Data Processor when we process Personal Data strictly on behalf of and under the contractual and documented instructions of our Customers (educational institutions using our admissions CRM). We process such Personal Data solely to deliver the Services that the Customer has opted for under contract. We do not determine the purposes, categories of Personal Data collected, or the means of processing in these cases – the Customer acts as the Data Fiduciary.

When We Act as a Data Fiduciary

We act as a Data Fiduciary when we collect or process Personal Data for our own independent business purposes, including:

  • Responding to enquiries from prospective Customers
  • Managing our own marketing communications
  • Conducting website and product analytics
  • Managing employment and HR-related data
  • Administering contracts and business relationships

In these cases, we independently determine the purposes and means of processing.

Use of Service Providers

To support delivery of our Services, we engage certain authorised service providers (such as hosting, email, SMS, and payment providers). These providers process Personal Data only on our behalf and in accordance with our instructions, subject to appropriate contractual, technical, and organisational safeguards.

2. Scope of This Privacy Policy

This Privacy Policy applies to the Personal Data that we collect, receive, or process when you:

  • Visit or interact with our website, mobile applications, or digital interfaces
  • Communicate with us through email, phone, chat, support tickets, or online forms
  • Use or access our admissions CRM platform in any capacity
  • Engage with our demos, webinars, marketing campaigns, or surveys
  • Otherwise provide Personal Data to us when we act as a Data Fiduciary

Where This Privacy Policy Does Not Apply

Customer-Controlled Data: Personal Data provided directly by applicants, leads, students, or other individuals to our Customers – for example, through admissions or enquiry forms hosted on Headstart-managed pages, or provided physically at a Customer’s campus. In such cases, the Customer is the Data Fiduciary, the Customer’s own privacy policy applies, and we process such data only as a Data Processor under documented Customer instructions. Customers are responsible for providing appropriate privacy notices to their applicants and users.

Third-Party Tools Used by Customers: This Policy does not apply to third-party integrations, scripts, pixels, tags, forms, or applications that Customers independently deploy on their websites or within their Headstart environment. Customers are solely responsible for the legality and compliance of such tools, including obtaining any required consents.

External Websites or Services: This Policy does not cover external websites, mobile applications, or services that may be linked from our website, platform, or communications. Such third parties operate under their own privacy policies, for which we are not responsible.

3. Summary

While we encourage you to read this Privacy Policy in full, here is a quick overview of how your personal data is handled when you interact with Headstart.

Who We Are: Headstart is owned and operated by Headstart Infotech OPC Private Limited, headquartered in Bangalore, Karnataka, India.

How You Interact With Us: Your relationship with Headstart determines what data we collect and how we use it. You may engage with us as:

  • A Visitor browsing our website
  • A Customer (educational institution) using our Services
  • A User – an employee or representative of a Customer accessing the platform
  • An Applicant/Lead whose data is processed by us on behalf of a Customer

Voluntary Submission: When you choose to provide personal information – such as submitting an enquiry, requesting a demo, or using our Services – you do so voluntarily. Certain information may be required to deliver Services or provide effective support.

If you do not agree with any part of this Privacy Policy, we advise that you discontinue use of our website, application, or Services. This Privacy Policy forms part of and should be read together with our Terms of Service.

4. Information We May Collect & How We Use It

We collect different categories of personal data depending on how you interact with Headstart. Collection and processing are based on appropriate lawful bases, including consent, performance of a contract, legitimate business purposes, legal obligations, or processing on behalf of a Customer.

4.1 Visitors (Website Browsers)

Data we may collect: Name, mobile number, email address, organisation/institute name, designation, and country or region (only if you submit an enquiry); and technical data such as IP address, approximate geographic location, browser and device information, operating system, pages viewed, time spent, clickstream paths, and cookies.

We use this information to understand how visitors interact with our website, improve performance, and enhance the overall user experience. If you submit your details and provide valid consent, we may also use your Personal Data to send emails or service-related updates, and to communicate about the demo, event, or enquiry you registered for.

4.2 Customers (Educational Institutions Using Our Services)

Data we may collect: Name, email address, and phone number of authorised representatives; institution/organisation details; IP address, cookies, device and browser details.

We use this data to create and manage Customer accounts, enable secure access, process billing, provide onboarding, support and training, and fulfil our contractual commitments.

4.3 Users (Employees / Representatives of Our Customers)

Data we may collect: Name, email, organisation details, phone (optional), address; IP address, browser and device details, login timestamps and activity logs; in-platform activity data (aggregated or anonymised where possible); and, only where optionally enabled, calendar access or communication metadata (such as SMS/email/call metadata) used for authorised follow-ups.

We do not collect: Call recordings, SMS content, device contact lists, or personal emails outside CRM leads.

We use this data to provide platform functionality, security, service notifications, technical support, and product improvement.

4.4 Applicants and Leads (Processed on Behalf of Customers)

When a Customer uses Headstart to manage admissions or enquiries, applicant and lead data (such as name, contact details, academic information, and application status) submitted through Customer-managed forms is processed by us strictly as a Data Processor, under the Customer’s instructions. The applicable Customer is responsible for providing privacy notices to and obtaining consents from such applicants.

4.5 User Choice & Control

Certain data elements – such as calendar access, communication metadata, and location tracking (where applicable to field or on-ground admissions activity) – are strictly optional and collected only after explicit opt-in. You may withdraw such permissions at any time through your device settings or the Headstart application.

4.6 Lawful Bases for Processing

Depending on the context, we rely on one or more of the following: consent; performance of a contract; legitimate business purposes; compliance with legal obligations; or processing on behalf of a Customer (Data Fiduciary).

5. Cookies, Tracking Technologies & Optional Features

We use cookies and similar technologies to support website functionality, remember preferences, analyse performance, and – where consent is provided – deliver relevant content.

  • Cookies: Small text files that enable login sessions, preferences, security, and analytics. Non-essential cookies are used only after obtaining your consent and can be managed through your browser settings.
  • Web Beacons / Pixels: Used to measure email and page engagement; these do not install software on your device.
  • Optional Mobile App Features: Such as calendar integration or communication metadata sync, used for admissions follow-up activity. These are strictly opt-in and can be revoked at any time.
  • Customer-Installed Third-Party Tools: Customers may deploy their own third-party analytics tools, pixels, scripts, or tags, which operate independently and are governed by the Customer’s and the respective third party’s privacy policies.

By using our Services, you agree to the use of cookies and tracking technologies as described above, subject to your right to manage or withdraw consent.

6. Children’s Data and Consent from Parents / Guardians

Our Services are primarily intended for use by educational institutions and their authorised representatives. Headstart does not directly provide Services to children or minors, nor does it collect their personal data for its own independent purposes.

Headstart may, however, process minors’ personal data (such as prospective student applicants) strictly as a Data Processor, on behalf of Customers. In such cases:

  • The Customer, acting as the Data Fiduciary, is responsible for obtaining appropriate parental or guardian consent where required under applicable law.
  • Headstart processes such data only in accordance with the Customer’s documented instructions.
  • Headstart does not use minors’ data for marketing, profiling, or behavioural tracking, or for any purpose other than delivering the Services requested by the Customer.

Where Headstart acts as a Data Fiduciary in its own right, we do not knowingly collect personal data of children or minors without appropriate parental or guardian consent, as required by applicable law.

7. Retention of Personal Information

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, comply with contractual or legal obligations, or support legitimate business needs. When retention is no longer required, we take reasonable steps to securely delete or anonymise the data.

  • Optional Feature Data: Calendar and communication metadata are retained only while the relevant feature is enabled, and deleted upon revocation where technically possible.
  • Customer-Controlled Data: Retained or deleted in accordance with the Customer’s instructions, contractual commitments, and applicable law.
  • Responding to Rights Requests: If you request deletion and it is technically feasible, we remove data from active systems and through backup cycles in line with our retention and deletion practices.

8. Sharing of Information with Third Parties

To deliver our Services, we work with vetted third-party service providers such as those for hosting, email, SMS, payments, and support. These providers process personal data only under our instructions and applicable contractual protections. We do not permit them to use personal data for their own independent purposes.

We do not sell, rent, or trade your Personal Information. We may share it in the following circumstances: with our service providers as described above; with affiliates, in connection with a merger, acquisition, or transfer of business assets (subject to this Policy continuing to apply); or where required to comply with legal obligations, court orders, or regulatory requests.

Customers may independently integrate third-party tools, scripts, or applications on their own instance of the platform. Personal data collected through such Customer-initiated tools is governed by the Customer’s and the respective third party’s privacy policies.

9. Third-Party Links

Our website and platform may contain links to third-party websites, applications, or services. Headstart does not operate, control, or endorse these third parties and is not responsible for their content, privacy practices, or data handling. We encourage you to review their privacy policies before sharing any personal information with them.

10. Compelled Disclosure

We may disclose personal information where required or permitted by law, including in response to court orders, government directives, or regulatory requests, or to protect the rights, safety, or security of users, Customers, employees, or the public. When acting as a Data Processor, we will, where legally permitted, forward such requests relating to Customer-controlled data to the applicable Customer. We follow the principle of minimum necessary disclosure.

11. Security of Your Personal Information

We take reasonable administrative, technical, and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or loss, and our platform is hosted on reputable cloud infrastructure. Security measures may include, where appropriate:

  • Encryption of data in transit (SSL/TLS)
  • Role-based access controls and secure authentication mechanisms
  • Firewalls and monitoring for unauthorised access
  • Periodic review of security practices and access controls
  • Logging and incident response procedures

We are continuing to strengthen our security and compliance posture over time. No method of transmission or storage is completely secure, and while we work to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials, using strong passwords, and remaining vigilant against phishing or other security threats.

12. Your Privacy Rights

Subject to applicable Indian law, you may have rights of access, correction, erasure, grievance redressal, and withdrawal of consent in relation to your Personal Data that we hold as a Data Fiduciary. We will honour and facilitate the exercise of such rights and will verify requests as required, responding within a reasonable time.

Where a Customer (educational institution) uses Headstart to process personal data relating to applicants, students, leads, or similar records, that Customer acts as the Data Fiduciary and is responsible for handling such requests. If your personal data was collected by such an organisation, please submit your request directly to them. In these cases, Headstart acts only as a Data Processor and will assist the Customer with verified requests in accordance with our contractual obligations.

13. Your Privacy Choices

  • Opting out of optional or consent-based processing: You may decline or withdraw consent for marketing, analytics, or optional data sharing at any time. Withdrawal does not affect processing carried out prior to withdrawal.
  • Opting out of marketing communications: You may unsubscribe using the link in our marketing emails, or by contacting us at [email protected]. Essential service or transactional communications will continue where necessary.
  • Submitting a request: You may submit privacy-related requests by emailing [email protected] or by writing to us at our registered office address below. Please include your name, email address, and details of your request.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, technology, business practices, or legal requirements. Where changes are material, we will provide notice through email, in-product notification, or a website alert. The updated Privacy Policy becomes effective upon publication, and continued use of our website, application, or Services after that date constitutes acceptance of the revised Policy.

15. How to Contact Us

If you have questions, want to exercise your rights, or wish to raise concerns, you can contact us as follows:

Company: Headstart Infotech OPC Private Limited

Email: [email protected]

Phone: +91 88269 01188

Registered Office: BTM Layout 2nd Stage, Bannerghatta Road, Bangalore, Karnataka – 560076, India

CIN: U72900KA2021OPC151778

GSTIN: 29AAFCH9455G1Z5