Privacy Notice

Effective date: 2026-10-06 Operator: ADHYAY EDUVENTURE PRIVATE LIMITED ("we", "us") Registered office: KH NO 257 PLOT NO 26 ROYAL GREEN CITY, PHASE II VILL DUHAI, Ghaziabad, Ghaziabad, Ghaziabad, Uttar Pradesh, India, 201001 CIN: U80100UP2017PTC089682 GSTIN: 09AAPCA1080N2Z7

This notice describes personal data we handle in connection with the Being Brilliant ERP + LMS + CRM service and related website, demo, account, billing and support activities.

1. Institution-controlled data

Schools, coaching centres and other institutions use Being Brilliant to manage their own students, parents/guardians, employees and operations. For this data, the institution normally decides why the data is collected and how the platform is used. We process it to provide the contracted service on the institution's instructions, subject to applicable law.

Questions about a student's academic record, attendance, fee record or an institution-created account should generally be directed first to that institution.

2. Data we process for our own service administration

Depending on interaction, we may process:

• name, business contact details and institution;
• account identifiers and authentication/security records;
• demo/enquiry information;
• subscription, invoice and payment-provider metadata;
• support communications;
• device, log, security and diagnostic information;
• configuration information necessary to operate the service.

We do not need or intend to store full card details; payment processing may be performed by the contracted payment provider.

3. Purposes

We use personal data where lawful and necessary to:

• provide and administer accounts/services;
• respond to demos, enquiries and support requests;
• manage subscriptions, invoicing and payment confirmation;
• secure accounts and detect abuse;
• maintain service reliability and audit records;
• comply with legal obligations and resolve disputes;
• communicate material service, security and contractual information.

Marketing communications should provide an appropriate opt-out where required.

4. Children

The platform may contain child/student data when an institution uses the service. The institution is responsible for obtaining required parental/guardian consent or other lawful authorization for its processing. We do not use institution-controlled child data for targeted advertising or independent behavioural profiling.

5. Sharing

We may disclose data to authorized personnel and service providers needed for hosting, communications, payments, security, monitoring and support, under appropriate contractual/confidentiality controls. We may also disclose information where required by law or to protect legal rights and security.

We do not sell institution-controlled personal data.

6. Retention

Retention depends on the data type, contract, security needs and legal requirements. Institution-controlled data follows the contracted Data Exit & Retention Policy after subscription termination. Security, billing and legal records may be retained longer where reasonably necessary or legally required.

7. Security

We use technical and organizational measures designed to protect the service, including access controls, tenant isolation mechanisms, authentication/authorization, secure production transport and security/audit logging. No internet service can guarantee absolute security.

8. Rights and grievances

Where applicable under law, individuals may have rights relating to access, correction, erasure, consent withdrawal or grievance handling. For institution-controlled records, contact the relevant institution first so it can verify identity and authority.

For data we control directly, contact:

Privacy/Grievance email: privacy@beingbrilliantedu.com

This monitored business-role mailbox was activated and inbound delivery was verified on 6 October 2026.

9. International processing

Hosting/processing locations may depend on contracted infrastructure and service providers. Any specific residency commitment must be stated in the relevant client Order Form.

10. Changes

We may update this notice for legal, security, product or operational changes. The effective date will be updated and material changes will be communicated where required.