PLACEHOLDER DRAFT — PENDING LEGAL REVIEW. This document is a non-binding draft prepared for the client's legal counsel to review, correct, and replace before launch. It does not constitute legal advice. Replace before launch.

Privacy Policy

Effective date: [INSERT EFFECTIVE DATE]

Platform: dMAT Practice (the "Platform")
Provider / Data Fiduciary: Germany Help Center India (the "Company", "we", "us", "our")
Support / Grievance contact: [support@germanyhelpcenter.com]

1. Introduction

This Privacy Policy explains how Germany Help Center India collects, uses, stores, and protects your personal data when you use the dMAT Practice Platform. We aim to handle your personal data in line with the spirit of India's Digital Personal Data Protection Act, 2023 (DPDP Act).

By using the Platform, you agree to the practices described here. Where the DPDP Act requires your consent, we will ask for it separately and clearly.

2. Data We Collect

We collect the following personal data:

Account details: your name and email address.
Password: stored only in hashed form — we never store your password in plain text. (If you sign in with Google, we do not store a password.)
State (optional): the Indian state/UT you tell us you're in. This is optional, never requested during sign-up, and can be added, changed, or removed any time from your account settings. We use it only to understand where our students are; it is visible only to us and is never shared or sold.
Practice data: your practice-test attempts, answers, and practice scores.
Marketing consent: whether you have opted in to receive marketing emails.
Technical/session data: limited data needed to keep you logged in (see Cookies below).

We do not store your full payment card or bank details — payments are handled by Razorpay (see Section 6).

3. How We Use Your Data

We use your data to:

Create and manage your account and authenticate your sign-in.
Provide practice papers and calculate and display your practice scores and progress.
Provide customer support and respond to your requests.
Send marketing or promotional emails only if you have opted in.
Maintain the security and integrity of the Platform and comply with legal obligations.

4. Legal Basis and Consent (DPDP Act 2023)

We process your account and practice data to provide the service you have signed up for. For marketing communications, we rely on your explicit opt-in consent.

Marketing is opt-in. You will not receive marketing emails unless you choose to receive them.
You may withdraw consent / unsubscribe at any time — via the unsubscribe link in any marketing email or by contacting support. Withdrawing marketing consent does not affect service-related emails (e.g. password resets, receipts).

5. Your Rights

In keeping with the DPDP Act 2023, you have the right to:

Access the personal data we hold about you.
Correct or update inaccurate or incomplete data.
Withdraw consent for marketing at any time.
Request deletion of your personal data and account (subject to any legal retention obligations).
Grievance redressal — raise concerns with us and, if unresolved, escalate to the Data Protection Board of India as provided under the DPDP Act.

To exercise any of these rights, contact [support@germanyhelpcenter.com]. We will respond within a reasonable time.

6. Payments (Razorpay)

Payments for paper packs are processed by Razorpay, our third-party payment processor, which supports UPI, cards, and net banking. When you make a payment:

Your payment details (card, UPI, or bank information) are collected and processed directly by Razorpay under their privacy policy and security standards.
We receive only confirmation of payment status and limited transaction references needed to unlock your purchase and provide support. We do not receive or store your full payment credentials.

Please review Razorpay's own privacy policy for details of how they handle your payment data.

7. Cookies

We use cookies (and similar technologies) primarily to keep you logged in and maintain your session. These are necessary for the Platform to function. We do not use cookies to sell your data. You can control cookies through your browser settings, but disabling essential cookies may prevent you from logging in.

8. Data Sharing

We do not sell your personal data. We share data only:

With service providers who help us operate the Platform (e.g. Razorpay for payments, email delivery providers), under appropriate confidentiality obligations.
Where required by law or to protect our legal rights.

9. Data Retention and Security

We retain your data for as long as your account is active or as needed to provide the service, and thereafter only as required by law.
We apply reasonable technical and organisational safeguards (including password hashing and access controls) to protect your data. No system is completely secure, and we cannot guarantee absolute security.

10. Children's Data

The Platform is intended for students preparing for the dMAT. If you are a minor under applicable law, you should use the Platform only with the consent and involvement of a parent or guardian, consistent with the DPDP Act.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified through the Platform or by email. Continued use after changes constitutes acceptance of the updated policy.

12. Contact

For any privacy questions, requests, or grievances, contact our support / grievance officer at [support@germanyhelpcenter.com].

*This is a placeholder draft pending legal review — replace before launch.*