Last Updated: September 1, 2026

Hetuluka (Proprietor: Palash Hazarika)
Madhupur, Narayanpur Block, Lakhimpur, Assam – 787033, India

1. About This Privacy Policy

Hetuluka ("Hetuluka", "we", "us" or "our") respects your privacy and is committed to protecting the personal information we handle.

This Privacy Policy explains how we may collect, use, process, store, disclose, protect, retain and delete information when you use Hetuluka.

It applies to our:

• Website and subdomains;

• Mobile and desktop applications;

• Learning Management System (LMS);

• Online courses and live classes;

• Recorded educational content;

• Assessments, assignments and examinations;

• Mentorship and academic-support services;

• Certificates and certificate verification;

• Community/discussion features;

• Customer and technical support;

• Marketing and promotional activities; and

• Other Hetuluka services that refer to this Privacy Policy.

The existing Hetuluka policy establishes the same broad scope across the website, subdomains, applications, LMS and marketing operations.

2. Who We Are

Business Name: Hetuluka
Legal/Proprietor Name: Hetuluka (Proprietor: Palash Hazarika)
Proprietor: Palash Hazarika — Proprietor, Hetuluka

Business Address:
Madhupur, Narayanpur Block,
Lakhimpur, Assam – 787033, India

Hetuluka currently operates primarily as an online education platform. References to future physical facilities, centres, events or other services do not mean that such facilities currently exist.

3. Who This Policy Applies To

This Policy may apply to:

• Students and learners;

• Parents and legal guardians;

• Educators and instructors;

• Mentors;

• Academic professionals;

• Organizations and institutions;

• Customers and subscribers;

• Community participants; and

• Website/app visitors.

Different information and privacy practices may apply depending on your role, course, service, feature, location, age and applicable law.

4. Information We Collect

We may collect information that you provide directly, information generated through your use of Hetuluka and information received from authorized third parties.

We aim to collect information that is reasonably necessary for identified purposes.

4.1 Account Information

Depending on the account and authentication method, we may collect:

• Name;

• Email address;

• Account identifiers;

• Login/authentication information;

• Profile information;

• Account preferences; and

• Other information reasonably necessary to operate the account.

Where supported, you may authenticate through third-party services such as OAuth/social-login providers.

4.2 Profile & Learning Information

Depending on what you choose to provide, this may include:

• Educational background;

• Professional goals;

• Skills;

• Interests;

• Learning preferences;

• Profile photograph;

• Achievements;

• Course interests;

• Learning history; and

• Other profile information.

Some fields may be optional or service-specific.

4.3 Academic & Learning Records

When you use educational services, we may process:

• Enrollment information;

• Batch information;

• Attendance or participation;

• Course progress;

• Lesson completion;

• Video/course activity;

• Assignments;

• Quizzes;

• Tests;

• Examinations;

• Grades and scores;

• Assessment results;

• Feedback;

• Achievements;

• Certificates;

• Certificate IDs;

• Verification records; and

• Mentorship/support records.

Our existing policy specifically describes collection of LMS activity including course progress, video playback, session duration, test/quiz results, completed lessons and certification progress.

These records may form part of your academic or learning record and may be retained after course completion or account closure where reasonably necessary.

5. Payment & Billing Information

For paid courses, subscriptions, batches or other services, we may process:

• Transaction details;

• Payment status;

• Billing information;

• Invoice/receipt information;

• Tax/GST information where applicable;

• Refund information;

• Payment disputes; and

• Other transaction-related information.

Payment processing may be performed through third-party payment providers, including Razorpay where supported.

Payment providers may collect and process payment credentials under their own security, privacy and legal requirements.

The existing policy states that payment gateways process payment information and that raw card credentials are not stored on Hetuluka's servers.

6. User Content & Communications

We may process information you submit through:

• Assignments;

• Projects;

• Discussion posts;

• Comments;

• Reviews;

• Peer-review activities;

• Questions;

• Documents;

• Images;

• Videos;

• Support requests;

• Emails;

• Mentor communications; and

• Other platform features.

You generally retain ownership of your original user-generated content unless a separate agreement or applicable law provides otherwise.

Hetuluka may receive the rights reasonably necessary to host, store, process, display, transmit, moderate, secure and provide services involving that content.

Special rules may apply to educator-created or commissioned educational content.

7. Automatically Collected Information

We may automatically collect technical and usage information such as:

• IP address;

• Device type;

• Operating system;

• Browser type;

• Browser language;

• Device/application identifiers;

• Session information;

• Usage information;

• Performance information;

• Security logs; and

• Approximate location derived from IP address.

The existing policy identifies device information, IP address, device identifiers and approximate IP-derived location as collected technical information.

We may use this information for purposes such as:

• Security;

• Fraud prevention;

• Network routing;

• Service performance;

• CDN delivery;

• Localization;

• Analytics; and

• Platform improvement.

8. Cookies & Similar Technologies

Hetuluka may use:

• Cookies;

• SDKs;

• Pixels;

• Local storage;

• Application identifiers; and

• Similar technologies.

They may be used for:

• Authentication;

• Security;

• Sessions;

• Preferences;

• Analytics;

• Performance;

• Service improvement;

• Marketing; and

• Advertising where applicable.

Some technologies may be essential to provide the service.

Where legally required and technically available, users may receive controls for certain non-essential technologies.

Third-party services may also use their own technologies subject to their respective policies.

9. How We Use Information

We may use information to:

1. Create and maintain accounts;

2. Authenticate users;

3. Deliver courses and educational services;

4. Operate the LMS;

5. Provide live and recorded classes;

6. Provide mentorship and support;

7. Process payments and enrollments;

8. Manage subscriptions and batches;

9. Conduct assessments;

10. Maintain academic records;

11. Issue and verify certificates;

12. Personalize learning;

13. Provide recommendations;

14. Improve platform performance;

15. Analyze usage;

16. Detect fraud and misuse;

17. Detect unauthorized account sharing;

18. Protect platform security;

19. Communicate important information;

20. Send permitted marketing communications;

21. Comply with legal obligations;

22. Resolve disputes; and

23. Protect Hetuluka, users and others.

10. Legal Basis for Processing

Depending on the circumstances and applicable law, Hetuluka may process information where it is:

• Necessary to provide a requested service;

• Necessary to administer an account or agreement;

• Required by law;

• Necessary for security, fraud prevention or legitimate operational purposes;

• Based on consent where consent is required; or

• Otherwise permitted by applicable law.

The applicable basis may differ depending on the data, purpose, user, feature, service and jurisdiction.

11. AI & Automated Systems

Hetuluka may use AI and automated technologies where appropriate.

Depending on the service, these systems may assist with:

• Tutoring;

• Recommendations;

• Personalization;

• Assessment;

• Grading;

• Feedback;

• Customer support;

• Moderation;

• Security;

• Fraud prevention;

• Academic-integrity controls; and

• Other educational or operational functions.

AI or automated outputs may be inaccurate, incomplete, biased, outdated or unsuitable.

Where appropriate, human review or oversight may be used, particularly for significant educational or account-related decisions.

Automated systems may also be used to detect:

• Fraud;

• Account misuse;

• Cheating;

• Unauthorized sharing;

• Security threats;

• Policy violations; and

• Other suspicious activity.

Where required by applicable law or offered by the relevant service, appropriate review or appeal mechanisms may be available.

Different AI systems may have different capabilities, limitations, safeguards and data practices.

12. AI Data Processing

Information used by an AI or automated feature depends on:

• The particular feature;

• The information involved;

• The purpose;

• The applicable legal basis;

• Consent requirements;

• The service;

• Third-party technology providers; and

• Applicable law.

AI functionality may change, improve, be restricted, suspended or discontinued.

New AI capabilities may be introduced with additional notices, terms or disclosures where appropriate.

13. Academic Integrity & AI Use

Where applicable, Hetuluka may process information to support academic integrity.

Users may be required to submit original work and comply with course or assessment rules concerning:

• Plagiarism;

• Cheating;

• Unauthorized collaboration;

• Misrepresentation;

• Unauthorized assistance; and

• AI use.

AI may be permitted, restricted or prohibited depending on the relevant course, assessment, educator or institutional requirements.

Where disclosure of AI assistance is required, users must follow the applicable disclosure rules.

14. Children & Minor Users

Hetuluka may allow minors to use services where legally permitted.

Depending on age, jurisdiction, service and applicable law, a parent or legal guardian may be required to:

• Provide consent;

• Participate in account setup;

• Verify information;

• Supervise use; or

• Exercise certain rights.

Hetuluka may introduce additional safeguards such as:

• Age verification;

• Guardian verification;

• Communication restrictions;

• Role-based access;

• Additional privacy controls;

• Safety monitoring; and

• Other child-protection measures.

Parents/guardians are responsible for appropriate supervision and for information, payment and account actions under their control.

15. Educator Information

For educators and mentors, Hetuluka may process information relating to:

• Identity;

• Qualifications;

• Skills;

• Experience;

• Portfolio;

• Verification;

• Courses;

• Teaching activity;

• Student interactions;

• Assessments;

• Mentoring;

• Payments or earnings where applicable; and

• Other information necessary for educator services.

Educator access to student information is role-based and limited according to the relevant service, permissions and legitimate educational requirements.

16. Visibility of User Information

Depending on the feature, information may be visible to:

• You;

• Hetuluka staff or administrators who require access;

• Authorized educators;

• Other users where you intentionally make information public;

• Employers or institutions through certificate verification; or

• Other parties where disclosure is legally required or otherwise permitted.

Visibility depends on the relevant role, feature, service and settings.

17. Certificates & Verification

Hetuluka may issue certificates or credentials containing a unique Certificate ID.

Depending on the certificate, verification may display limited information necessary to establish authenticity.

Verification may be available to students, employers, institutions or other legitimate users.

Hetuluka may suspend, correct, revoke or invalidate a certificate where appropriate, including in cases involving:

• Fraud;

• Misrepresentation;

• Academic misconduct;

• Incorrect issuance; or

• Other legitimate reasons.

18. Marketing Communications

Where permitted, Hetuluka may send promotional communications relating to:

• Courses;

• Batches;

• Subscriptions;

• Discounts;

• Events;

• New services; and

• Other Hetuluka offerings.

You may opt out of promotional communications where applicable.

Opting out does not necessarily stop essential communications such as:

• Security notices;

• Transaction notices;

• Course information;

• Account notices;

• Legal notices; or

• Other necessary service communications.

19. Advertising & Third-Party Promotions

Hetuluka may display advertisements, recommendations or promotional content.

Advertising may vary based on:

• Service;

• Location;

• Device;

• User settings;

• Age;

• Available technology; and

• Applicable law.

Third-party advertisers and services may have separate privacy practices.

Hetuluka does not guarantee that every third-party advertisement, recommendation or offer is suitable for every user.

Additional safeguards may apply to minors.

20. Information Sharing

Hetuluka does not sell, rent or trade personal information as a commercial data-selling practice.

We may share information where reasonably necessary with:

• Payment processors;

• Cloud and hosting providers;

• Database/storage providers;

• Backup providers;

• Video/CDN providers;

• Email/SMS/notification providers;

• Authentication providers;

• Security providers;

• Analytics providers;

• Advertising/marketing providers;

• LMS and educational technology providers;

• App stores and operating-system providers;

• Customer-support providers;

• Professional advisers; and

• Other service providers necessary to operate or improve Hetuluka.

The existing policy similarly identifies cloud infrastructure, video delivery, payment processing, marketing and analytics partners as service providers.

Third parties may have their own privacy policies and terms.

21. Legal, Regulatory & Safety Disclosures

We may disclose information where reasonably necessary or legally required to:

• Comply with law;

• Respond to valid legal requests;

• Comply with court or regulatory orders;

• Meet tax/accounting obligations;

• Investigate fraud;

• Investigate security incidents;

• Address academic misconduct;

• Protect minors;

• Protect users;

• Protect Hetuluka's rights;

• Protect intellectual property;

• Establish or defend legal claims; or

• Cooperate with lawful authorities.

The existing policy includes legal disclosures for court orders, government requirements, intellectual-property protection, safety, fraud, academic dishonesty and platform abuse.

22. International Processing

Hetuluka is operated from India but may be accessible internationally.

Depending on the service and service provider, information may be processed or stored in India or other countries.

International processing may be subject to applicable safeguards and legal requirements.

Users accessing Hetuluka from outside India are responsible for complying with applicable local laws, while Hetuluka will apply mandatory legal protections applicable to the relevant situation.

23. Data Security

Hetuluka uses reasonable technical, administrative and organizational measures designed to protect information against unauthorized access, loss, alteration, misuse or disclosure.

Measures may include:

• Encryption/TLS;

• Password protection and hashing;

• Access controls;

• Authentication;

• Monitoring;

• Security logging;

• Vulnerability management;

• Backups;

• Security reviews;

• Fraud controls; and

• Other reasonable safeguards.

The existing policy describes TLS/SSL, password hashing, cloud monitoring, firewall protection and vulnerability scanning.

We continuously seek to improve security and data-protection measures.

However, no method of internet transmission, storage or electronic security can be guaranteed to be completely secure.

24. Security Incidents

If we identify a suspected security incident, Hetuluka may:

• Investigate;

• Contain or isolate affected systems;

• Restrict affected accounts;

• Reset credentials;

• Require additional verification;

• Preserve evidence;

• Coordinate with service providers;

• Restore systems;

• Notify affected users where appropriate or legally required;

• Notify authorities where legally required; and

• Implement additional safeguards.

The response depends on the nature, scope, severity and legal requirements of the incident.

Security vulnerabilities may be reported to:

incident@hetuluka.com

25. Data Retention

We retain information only for as long as reasonably necessary for applicable purposes, subject to legal, security, operational and legitimate business requirements.

Different information may have different retention periods.

We may retain information for:

• Account operation;

• Academic records;

• Certificates;

• Certificate verification;

• Transactions;

• Tax/accounting;

• Security;

• Fraud prevention;

• Disputes;

• Legal claims;

• Compliance; and

• Backups.

When information is no longer reasonably necessary, we may delete or anonymize it, subject to applicable exceptions.

26. Account Deletion

You may request deletion of your account and applicable personal information.

We may verify your identity before processing the request.

Account deletion may permanently result in loss of:

• Course access;

• Subscription access;

• Learning progress;

• Course history;

• Grades;

• Certificates;

• Achievements;

• Mentorship/support access; and

• Other account-related services.

The existing policy expressly warns that deletion can permanently remove course access, transcripts, progress, grades, certificates, mentoring, support and community access.

We may retain information where necessary or legally permitted, including certain academic, certificate, transaction, tax, security, fraud, dispute and legal records.

27. Public Content After Deletion

If you have posted public content, Hetuluka may anonymize it rather than completely deleting the substantive content where reasonably necessary for educational or community continuity.

Personal identifiers may be removed, including:

• Name;

• Profile image;

• Account identifiers; and

• Other unnecessary identifying information.

This approach is also reflected in the existing policy.

28. Your Privacy Rights

Depending on applicable law, you may have rights to:

• Access information;

• Correct information;

• Request deletion;

• Withdraw consent where applicable;

• Request applicable data portability;

• Raise privacy complaints; and

• Exercise other legally available rights.

The existing policy provides access, correction and deletion mechanisms.

Rights may be subject to:

• Identity verification;

• Legal exceptions;

• Security requirements;

• Third-party rights;

• Academic-record requirements; and

• Other applicable restrictions.

29. Data Correction

You may request correction of inaccurate information.

Where available, information may be corrected through account settings.

For sensitive information, including academic records, certificates or identity-related information, Hetuluka may require verification or additional review.

Some historical records may need to be retained even after correction.

30. Data Portability

Where required by law and technically practical, Hetuluka may provide applicable personal or learning information in an electronic format.

Portability may be limited where information:

• Belongs to another person;

• Is subject to third-party rights;

• Is confidential;

• Is proprietary;

• Cannot safely be exported;

• Is technically unavailable; or

• Is legally restricted.

Portability does not transfer ownership of Hetuluka's intellectual property or proprietary platform content.

31. Withdrawal of Consent

Where processing is based on consent, you may withdraw that consent where legally applicable.

Withdrawal:

• Does not generally make previous lawful processing unlawful;

• Does not necessarily stop processing based on another lawful basis;

• May affect optional features; and

• May require identity verification.

32. Business Transfers

If Hetuluka undergoes a:

• Merger;

• Acquisition;

• Reorganization;

• Restructuring;

• Investment;

• Sale of assets;

• Change of ownership; or

• Similar transaction,

relevant information, accounts, contracts, subscriptions, records, educational content or other business assets may be transferred as part of the transaction, subject to applicable law and appropriate safeguards.

The existing policy also contemplates transfer of user databases and personal information during business transitions.

33. Third-Party Services

Third-party services may include:

• Payment providers;

• Cloud infrastructure;

• Storage;

• Video/CDN;

• Email and notifications;

• Authentication;

• Analytics;

• Advertising;

• Security;

• LMS/education technology;

• App stores;

• Operating systems; and

• Other technology providers.

Third parties may operate independently and have separate:

• Privacy policies;

• Terms;

• Security measures;

• Data-retention practices; and

• Legal obligations.

Hetuluka does not control every third-party service.

34. User Responsibilities

You are responsible for:

• Providing accurate information;

• Keeping account information updated;

• Protecting account credentials;

• Securing your device;

• Following applicable policies;

• Respecting other users' privacy;

• Maintaining appropriate backups of important materials where practical; and

• Promptly reporting suspected security incidents.

You should not upload malware, unlawfully obtained information or information you do not have the right to provide.

35. Changes to This Privacy Policy

We may update this Privacy Policy when:

• Our services change;

• New technologies are introduced;

• Laws or regulations change;

• New privacy requirements arise;

• New features are launched; or

• Our business operations evolve.

Updated versions will be published with a new Effective Date.

For significant changes, Hetuluka may provide additional notice where appropriate or legally required.

36. Contact & Privacy Requests

Privacy & Support

support@hetuluka.com

General / Legal

contact@hetuluka.com

Grievance Escalation

grievance@hetuluka.com

Security Incidents

incident@hetuluka.com

Business Address

Hetuluka (Proprietor: Palash Hazarika)
Madhupur, Narayanpur Block, Lakhimpur, Assam – 787033, India

37. Important Legal Protection

Nothing in this Privacy Policy is intended to:

• Remove any right that cannot legally be removed;

• Override mandatory privacy or consumer protections;

• Prevent a lawful complaint or regulatory process;

• Create an unconditional promise of security or data availability; or

• Restrict rights available under applicable law.

Where mandatory law provides greater protection, that law will apply to the extent required.

Where a particular Hetuluka service has additional privacy terms, those terms should be read together with this Policy.