Effective Date / Last Updated: 2 November 2026

1. Introduction

We understand that your privacy is important to you. Manubhai Gems Pvt. Ltd. (“Manubhai,” “we,” “our,” or “us”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, safeguard, and manage your information when you use our learning and training application (the “Application”). Any information collected is used strictly to provide, secure, and improve our enterprise training services.

2. Information We Collect

To facilitate our learning environment, we collect the following types of information:

• Personal & Account Information: Name, email address, employee ID, department, and designation. This is collected for user registration, authentication, and internal account management.
• Learning & Performance Data: Course enrollment records, learning progress, module completion timestamps, and assessment results.
• Technical & Device Data: Device model, operating system version, application usage logs, IP address, and crash analytics. This is collected to ensure cybersecurity, troubleshoot technical issues, and improve application performance.
• Device Permissions: For specific Application functionality, we may request access including but not limited to:
  • Device Notifications: To send reminders about pending training modules.
  • Camera: Strictly for uploading profile photos or proctored assessment verifications (never accessed in the background).
  • Local Storage: To store downloadable course materials for offline viewing.

You maintain control over these permissions through your device settings at any time.

3. How We Use Your Information

The information we collect is strictly utilized to:

• Administer and manage corporate training activities.
• Monitor user progress and generate internal performance reports.
• Secure the Application and protect our enterprise infrastructure against unauthorized access.
• Provide technical support, diagnose crash reports, and optimize system architecture.

4. Data Storage and Security

Protecting enterprise data is a core priority. We implement robust, industry-standard technical and organizational measures to secure your personal data against unauthorized access, loss, or alteration. Data is hosted on secure cloud infrastructure and is protected using industry-standard cryptographic protocols to ensure robust data encryption in transit, maintaining the strict confidentiality and integrity of your information.

5. Data Sharing and Third Parties

We do not sell, rent, or commercially share your personal information with third parties. Your data is strictly confidential. Information may only be accessed by:

• Authorized internal personnel (such as HR, IT, and direct managers) on a strict need-to-know basis.
• Vetted service providers and analytics partners acting under strict confidentiality agreements, solely as necessary to operate and maintain the Application infrastructure.
• Legal authorities, only if required to comply with applicable laws or regulatory obligations.

6. Data Retention

We retain your personal and learning data only for as long as you are employed by Manubhai Gems Pvt. Ltd. or as necessary to fulfill the operational purposes outlined in this policy, comply with our legal obligations, resolve disputes, and enforce our agreements.

7. User Rights

Depending on applicable internal policies and local laws, you may have the right to request access to, correction of, or deletion of your personal data stored within the Application. To exercise these rights or to raise questions about your data profile, please contact the appropriate internal department. Upon employee offboarding or a verified deletion request, personal identifiers are removed or anonymized in accordance with company data retention policies and legal compliance.

8. Children’s Privacy

This Application is an enterprise employee training tool and is intended exclusively for adults (aged 18 and above). We do not knowingly collect or solicit personal information from children under the age of 18.

9. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data security practices, please contact our team at:

• Email: [email protected]
• Department: IT & System Administration

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. Any updates will be posted within the Application, and the “Last Updated” date at the top will be revised accordingly.