Privacy and Child Data Policy
1. Who We Are
Creatiminds is a learning initiative operated by Markmydigi Technologies. Throughout these policies, “Creatiminds”, “we”, “us” and “our” refer to Markmydigi Technologies and the Creatiminds program, as applicable.
For personal data processed in connection with Creatiminds, Markmydigi Technologies ordinarily determines why and how the data is processed and acts as the relevant data fiduciary or controller, subject to applicable law and the role of any partner school or organisation.
2. Scope
This Policy applies to the Creatiminds website, enquiry and admission forms, payments, classes, events, workshops, learning platforms, assessments, support communications, recordings, photographs, testimonials and related services.
A partner school, venue, payment provider or technology platform may separately process data under its own privacy notice. Where responsibilities are shared, Creatiminds will seek to clarify the relevant roles and contact route.
3. Personal Data We May Collect
Parent or guardian data: name, email, phone number, address, relationship to the child, communication preferences, consent records, enquiry details, invoices, transaction references and support history.
Child data: name, age or date of birth, grade, school name if relevant, preferred language, learning interests, attendance, projects, assessment information, feedback, certificate information and program participation.
Safety and support data: emergency contacts, authorised pickup information, allergies, accessibility requirements or other information voluntarily provided because it is reasonably necessary for safe participation.
Media data: photographs, videos, audio, class recordings, learner projects and testimonials, where captured for an identified purpose and subject to required consent.
Technical data: IP address, browser, device type, approximate location derived from IP, login information, website activity, cookie identifiers, security logs and interactions with emails or forms.
Payment data: amount, status, method, invoice details and transaction reference. Creatiminds does not intend to store complete card numbers, CVV, banking passwords or payment OTPs; payment credentials are ordinarily handled by authorised payment providers.
Communications: emails, messages, call notes, complaints, feedback, survey responses and other information sent to Creatiminds.
4. How We Collect Data
Directly from parents or guardians through enquiries, forms, payments, calls, messages, consent forms and program participation.
From the child during classes, projects, assessments or support interactions, within the scope authorised by the parent and appropriate to the child’s age.
Automatically through cookies, server logs, analytics and security tools when the website or platform is used.
From partner schools, referral partners, event organisers or authorised representatives where they confirm a lawful basis to share the information.
From payment, communication, learning and technology providers that support the requested service.
5. Why We Use Personal Data
To respond to enquiries, recommend age-appropriate programs and arrange trials or counselling.
To verify parent or guardian authority, record consent, complete enrollment, process payment and issue receipts.
To deliver classes, create learner accounts, manage attendance, provide feedback, assess projects and issue certificates.
To protect children, manage emergencies, investigate complaints, prevent misuse and maintain platform or venue security.
To communicate schedules, reminders, resources, payment information, policy updates and service notices.
To improve curriculum, instructor quality, accessibility, website performance and operational processes.
To comply with legal, accounting, tax, safeguarding, law-enforcement and dispute-resolution requirements.
To send marketing communications to parents where permitted. Marketing preferences can be changed, but essential service communications may still be sent.
To use identifiable child media for public promotion only where the required separate consent has been obtained.
6. Children’s Data and Verifiable Parent/Guardian Consent
Creatiminds treats every learner under 18 as a child for child-data compliance purposes, even though its primary programs are for ages 8–14.
Before processing child data that requires consent, Creatiminds will take reasonable steps to verify that consent is given by the parent or lawful guardian. Verification may include confirmation through the parent’s contact details, payment relationship, signed or digital declaration, identity or relationship information where reasonably necessary, or another legally permitted method.
Creatiminds will collect only data reasonably necessary for specified educational, operational or safety purposes. We do not intentionally undertake behavioural monitoring or tracking of children for advertising, and we do not knowingly direct personalised advertising to children.
A parent may refuse optional data uses, including promotional media use, without losing access to the core program unless the optional processing is genuinely necessary for the requested feature.
If Creatiminds learns that child data was provided without appropriate authority, it may suspend the relevant feature and seek verification or delete the data, subject to safety and legal retention requirements.
7. Consent and Other Permitted Processing
Where consent is used, the request will identify the relevant data and purpose in clear language and provide a method to withdraw consent. Withdrawal does not make earlier lawful processing invalid, but it may affect features that cannot be provided without the data.
Creatiminds may also process data where permitted or required by applicable law, including for safety, emergencies, prevention of harm, compliance with court or government requirements, legal claims and other recognised legitimate uses.
Promotional media consent is separate from enrollment consent. Health or emergency information is requested only when reasonably needed for safe participation.
8. Class Recordings, Photographs and Testimonials
Where classes are recorded, parents will be informed of the purpose, expected access and retention. Recordings may be used for learner recap, quality review, safeguarding review or instructor training, but access will be limited.
Creatiminds will not rely solely on general Terms to publish a child’s identifiable image, voice or testimonial. Separate parent or guardian media permission will be obtained for public website, social-media, advertising or print use.
Parents may withdraw future promotional permission by contacting Creatiminds. Creatiminds will take reasonable steps to stop new use and remove controllable online material, but cannot always retrieve previously distributed print material, third-party reposts or content lawfully published before withdrawal.
9. Cookies, Analytics and Advertising
The website may use essential, functional, analytics and advertising cookies as described in the Cookie and Tracking Policy.
Analytics may be used to understand website performance and parent interest. Advertising tools may be used to reach adult audiences such as parents. Creatiminds does not intend to create advertising profiles of enrolled children or target behavioural advertising to children.
Where required, optional cookies will be used only after consent. Cookie choices can be changed through the available preference tool or browser settings.
10. Sharing of Personal Data
Creatiminds may share limited data with instructors, employees and authorised contractors who need it to perform their role and are subject to confidentiality and safeguarding expectations.
Service providers may process data for hosting, cloud storage, video conferencing, payments, communications, CRM, analytics, customer support, cybersecurity, forms or learning tools. They receive only the data reasonably necessary for their service and are expected to protect it.
Data may be shared with partner schools, venues or event organisers when necessary for the requested program and where appropriate notice or consent has been provided.
Data may be disclosed to courts, law-enforcement agencies, child-protection authorities, regulators, professional advisers or other persons where required by law or reasonably necessary to protect rights, safety or prevent serious harm.
Creatiminds does not sell personal data. Creatiminds does not sell or trade child profiles for advertising.
If the Creatiminds business or a relevant part of it is reorganised, transferred or acquired, data may transfer subject to confidentiality, applicable law and continued protection for the stated purposes.
11. International and Third-Party Processing
Some technology providers may store or process data outside India. Where such processing occurs, Creatiminds will use providers and contractual or organisational safeguards considered reasonable and will comply with applicable transfer restrictions.
Parents should review the privacy settings and notices of third-party platforms. Creatiminds will avoid requiring a child to create an independent account where an adult-managed or institution-managed option is reasonably available.
12. Data Security
Creatiminds uses reasonable technical and organisational safeguards appropriate to its size and the nature of the data. Measures may include role-based access, strong passwords, multi-factor authentication where available, secure hosting, encryption in transit, access reviews, backups, staff confidentiality, device security and incident procedures.
No system is completely secure. Parents should use strong passwords, protect access links, avoid sharing OTPs and notify Creatiminds promptly of suspected misuse.
Access to health, emergency, safeguarding and child records will be limited to persons who need the information for an authorised purpose.
13. Data Retention
Creatiminds retains personal data only for as long as reasonably necessary for the stated purpose, legal compliance, safety, dispute resolution and legitimate recordkeeping.
As an operational baseline, inactive enquiry data may be retained for up to 12 months after the last meaningful interaction; child learning, attendance and certification records may be retained for up to 3 years after program completion; class recordings may ordinarily be deleted within 90 days unless a longer period was disclosed or a safety, complaint or legal reason requires preservation; optional promotional media may be used until consent is withdrawn or the stated campaign/archive period ends; and financial or transaction records may be retained for the period required by tax, accounting and legal obligations.
These periods may be shortened or extended where necessary for a live account, ongoing service, legal hold, safeguarding matter, complaint, fraud prevention or statutory requirement. Data will be deleted, anonymised or securely archived when no longer needed.
14. Parent and Data Principal Rights
Subject to applicable law and reasonable verification, a parent or other eligible data principal may request information about processing, access to relevant personal data, correction of inaccurate or incomplete data, erasure where retention is no longer required, withdrawal of consent, grievance redressal, and nomination of another person to exercise rights in circumstances recognised by law.
Requests concerning a child should be made by the verified parent or lawful guardian. Creatiminds may request information necessary to confirm identity and authority and may refuse or limit a request where required to protect another person, preserve evidence, comply with law or safeguard the child.
Requests may be sent to hello@creatiminds.com. Creatiminds will respond within a reasonable period and in accordance with applicable law.
15. Marketing Choices
Parents may unsubscribe from promotional email or message campaigns by using the provided option or contacting Creatiminds. Unsubscribing from marketing does not stop necessary enrollment, payment, schedule, safety, policy or support communications.
Creatiminds will not ask a child to consent to adult marketing. Parent contact information should be used for admissions and promotional communication unless a legally appropriate alternative has been established.
16. Personal Data Breaches
If a personal-data breach occurs, Creatiminds will investigate, contain and document the incident and take reasonable corrective action. Where required by applicable law, Creatiminds will notify affected persons and the competent authority with information about the nature of the breach, likely consequences, mitigation and contact route.
Parents should promptly report suspicious messages, account access, leaked class links or accidental disclosure to the privacy contact.
17. Parent Responsibilities and Third-Party Information
Parents should provide only information they are authorised to share and should avoid submitting unnecessary sensitive data. They should update contact, emergency and pickup details when circumstances change.
When a parent provides information about another person, such as an emergency contact or authorised pickup person, the parent should inform that person and ensure the information is accurate.
18. Changes to This Policy
This Policy may be updated for legal, technology, safety or operational changes. The updated version will show the revision date. Material changes affecting enrolled learners will be communicated where reasonably practicable.
Where a new purpose requires fresh consent, Creatiminds will seek that consent rather than relying only on a general policy update.
19. Privacy and Grievance Contact
Privacy contact: hello@creatiminds.com .
Grievance Officer: Pranjal Deshmukh.
Address: 506, West Avenue, Opposite PMRDA Office, Aundh, Pune, Maharashtra 411067, India. Phone: +91 99606 41826 .
A complaint may also be escalated under the Grievance Redressal Policy and to competent statutory authorities where applicable.
Email: hello@creatiminds.com
Phone: +91 99606 41826
Address: 506, West Avenue, Opposite PMRDA Office, Aundh, Pune, Maharashtra 411067, India