Privacy Policy

1. Introduction and About This Policy

Walchand College of Engineering, Sangli (“WCE”, “we”, “us”, or “our”) is committed to protecting the privacy and personal data of every individual who accesses or uses WalchandPRO, our online learning platform (the “Platform”).

This Privacy Policy (the “Policy”) explains, in a clear and comprehensive manner:

• what categories of personal data we collect;
• why we collect and process that data, and the lawful basis on which we do so;
• how long we retain each category of data, with defined retention periods;
• with whom we share data, and the safeguards that apply;
• how we secure your data; and
• what rights you have over your personal data and how to exercise them.

This Policy should be read together with our Terms of Use, Refund Policy, and Cookie Policy, each of which forms part of the contractual framework governing your use of the Platform.

By registering for, accessing, or continuing to use the Platform, you acknowledge that you have read and understood this Policy. Where processing is based on your consent, we will obtain that consent separately and you may withdraw it at any time as described in Section 8.

2. Who We Are and How to Reach Us

WalchandPRO is owned and operated by Walchand College of Engineering, Sangli, a Government-Aided Autonomous Institute affiliated to Shivaji University, Kolhapur.

For the purposes of the Digital Personal Data Protection Act, 2023 (“DPDP Act”), WCE is the Data Fiduciary that determines the purposes and means of processing your personal data. You are the Data Principal whose personal data is processed.

The Platform is developed, hosted, maintained and operated on behalf of WCE by our Technology and Operations Partner, which acts as our Data Processor and processes personal data strictly on our documented instructions and under a binding data-processing arrangement.

3. Definitions

For ease of understanding, the following terms carry the meanings set out below wherever they appear in this Policy:

• “Personal Data”: any data about an individual who is identifiable by or in relation to such data.
• “Processing”: any operation performed on personal data, including collection, recording, storage, use, sharing, disclosure, erasure or destruction, whether or not by automated means.
• “Data Principal”: the individual to whom the personal data relates. Where the individual is a child, this includes the parent or lawful guardian.
• “Data Fiduciary”: the person (here, WCE) who alone or with others determines the purpose and means of processing personal data.
• “Data Processor”: any person who processes personal data on behalf of a Data Fiduciary.
• “Learner” / “User” / “you”: any individual who registers for or uses the Platform.
• “Platform”: the WalchandPRO online learning platform, including its websites, learning-management functions, assessment tools and associated services.
• “Technology and Operations Partner”: Campus Credentials / Euclideum Solutions Private Limited, which builds, hosts and operates the Platform on WCE’s behalf.
• “Consent”: any freely given, specific, informed and unambiguous indication of your agreement to the processing of your personal data for a specified purpose.

4. Scope and Applicability

This Policy applies to:

• all visitors, registered learners, and users of the Platform;
• all personal data collected through the Platform’s registration, learning, assessment, payment and support functions;
• all personal data processed by our Technology and Operations Partner and other processors acting on our behalf; and
• all channels through which you interact with us in connection with the Platform, including email and support communications.

This Policy does not apply to any third-party website, application, or service that you may access through a link on the Platform. Your use of such external services is governed by their own privacy policies (see Section 21).

5. Legal and Regulatory Framework

This Policy is published and maintained in compliance with the applicable data-protection and consumer-protection laws of India, including in particular:

• the Information Technology Act, 2000, and rules made thereunder;
• the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SPDI Rules”);
• the Consumer Protection (E-Commerce) Rules, 2020; and
• the Digital Personal Data Protection Act, 2023 (the “DPDP Act”), as and when its provisions and subordinate rules are brought into force.

Where any provision of this Policy is found to be inconsistent with applicable law, the law shall prevail, and we will update this Policy accordingly.

6. Categories of Personal Data We Collect

We practise data minimisation: we collect only the personal data that is necessary for the specific, lawful purposes described in this Policy. The categories below reflect the data we actually collect and process through the Platform.

6.1 Account and Registration Data (provided by you)

When you create an account, we collect:

• Full name (including, where applicable, first name and last name);
• Email address (used as your login identifier and for essential service communications);
• Password, which is stored only in securely hashed (irreversible) form, we never store or have access to your password in plain text;
• User category / learner classification that you select during registration;
• Acceptance of Terms (a record that you have agreed to our Terms of Use and this Policy); and
• “How did you hear about us” (an optional source-attribution response, where you choose to provide it).

6.2 Institutional and Academic Identifiers (for Walchand College learners)

Where you register as a student of Walchand College of Engineering, Sangli, we additionally collect the following institutional identifiers to link your account to your academic enrolment:

• Permanent Registration Number (PRN), your unique nine-digit institutional registration number;
• Academic branch / department (for example, Computer Science and Engineering, Information Technology, Mechanical Engineering, and other departments offered by the Institute);
• Passout year (year of course completion); and
• Institutional-learner status (a flag indicating that your account is associated with the Institute).

6.3 Learning Activity Data (collected automatically as you learn)

To deliver courses, track progress, and issue certificates, the Platform’s learning-management functionality records:

• the courses you enrol in and, where applicable, purchase;
• videos watched, modules and lessons opened, and time spent on learning content;
• quiz attempts, assessment scores, and assignment submissions;
• course-completion status; and
• certificates earned.

6.4 Assessment and Examination-Integrity Data

When you undertake coding assignments, quizzes, proctored assessments, or MATLAB-based exercises, we and our assessment service providers process:

• your name, email address and internal learner identifier, transmitted to the assessment environment solely to authenticate you and attribute your work;
• your submissions, including code, answers and assignment files;
• scores, grades and results;
• examination-integrity signals, which may include your IP address, browser/user-agent and device metadata, count of tab or focus switches during an assessment, time-on-task, submission timestamps, and similarity/plagiarism indicators.

Examination-integrity signals are processed strictly for the legitimate purpose of upholding academic honesty and the fairness of assessments. Please see Section 10 for a full explanation of how assessments operate and which recipients are involved.

6.5 Payment, Billing and Taxation Data

Where you purchase a paid course, we collect and store the following billing and taxation data:

• billing name;
• billing address (address line 1, address line 2, city, state, country and PIN code);
• contact telephone number provided for billing;
• Goods and Services Tax Identification Number (GSTIN) and Permanent Account Number (PAN), where you require a tax invoice; and
• transaction records, comprising the order/transaction reference, payment-method type (for example, card, UPI or net banking, not the underlying instrument number), amount, currency, applicable discounts, tax amount and the success/failure status of the transaction.

We do not collect, store, or have access to your full card number, CVV, card expiry, UPI PIN, net-banking password, or any other payment-authentication credential. See Section 9 for details.

6.6 Technical and Device Data (collected automatically)

When you access the Platform, we and our infrastructure providers automatically process:

• your IP address and general (country-level) location derived from it, including a country determination made at the time of registration;
• your browser type, device type and operating system;
• pages visited and time spent on the Platform;
• login times and session information; and
• cookie and similar-technology data, as described in Section 13.

6.7 Communications and Support Data

When you contact us or raise a request, we process:

• the content of your messages, feedback, grievances and support requests; and
• associated metadata, such as the date, time and channel of the communication, and the resolution outcome.

6.8 Cookies and Similar Technologies

We use cookies and similar technologies as described in Section 13. These may involve the processing of technical identifiers and preference data stored on your device.

6.9 Data We Do Not Collect

To be transparent about the boundaries of our processing, we confirm that we do not:

• process special-category / sensitive personal data such as caste, religion, political opinion, sexual orientation, biometric data, genetic data, or health data;
• collect your date of birth or gender;
• require you to upload a profile photograph; or
• use your personal data to build advertising profiles or to sell to data brokers or advertisers.

7. Purposes of Processing and Legal Bases

We process your personal data only for specified, lawful purposes. The table below sets out each purpose and the corresponding legal basis under Indian data-protection law (namely, performance of a contract, compliance with a legal obligation, a legitimate use/interest, or your consent).

We do not use your personal data for any automated decision-making that produces legal or similarly significant effects on you (see Section 19).

8. Consent and How to Withdraw It

Where we rely on your consent to process your personal data (for example, for marketing communications or for any non-essential cookies), the following principles apply:

• Freely given and specific: we request consent separately for each distinct purpose, in clear and plain language, and never bundle unrelated purposes together.
• Opt-in: consent-based processing occurs only where you have affirmatively opted in. Silence, pre-ticked boxes or inactivity do not constitute consent.
• Withdrawable at any time: you may withdraw your consent at any time, and it must be as easy to withdraw as it was to give. You can withdraw consent by clicking the “unsubscribe” link in any marketing email; adjusting your communication or cookie preferences; or writing to us at walchandpro@walchandsangli.ac.in.
• Effect of withdrawal: withdrawing consent will stop the relevant future processing but does not affect the lawfulness of processing carried out before withdrawal, and does not affect processing that rests on another legal basis (for example, service communications relating to your enrolments, payments or certificates).

9. Payment, Billing and Taxation Data

Because WalchandPRO offers paid courses, we want to be fully transparent about how payments are handled.

9.1 How payments are processed

• When you choose to purchase a course, you are redirected to a secure, PCI-DSS-certified third-party payment gateway engaged by WCE to process online payments.
• All sensitive payment credentials, card number, CVV, card expiry, UPI ID or PIN, and net-banking credentials, are entered directly on the payment gateway’s secure environment. They never pass through, and are never stored on, WCE’s or the Platform’s systems.
• The payment gateway processes the transaction and returns to us only a confirmation record, comprising the transaction/order reference, the payment-method type, the amount and currency, the date, and the success or failure status.

9.2 What we store

We store the confirmation record described above, together with the billing and taxation data you provide (billing name, billing address, telephone number, and, where you request a tax invoice, your GSTIN and PAN). This information is retained to fulfil your order, issue receipts and GST-compliant invoices, process refunds, and meet our statutory record-keeping obligations.

9.3 Refunds

Where you are eligible for a refund under our Refund Policy, the refund is initiated back to your original payment method through the same payment gateway. WCE does not hold or retain your funds; monies remain within the regulated payment infrastructure until settlement.

9.4 Currency

All transactions are processed in Indian Rupees (INR).

10. Assessments, Coding Evaluation and Examination Integrity

The Platform provides interactive assessments, coding assignments and MATLAB-based exercises. To deliver these, WCE integrates specialist assessment technologies.

10.1 Integrated assessment and coding-evaluation environment

For coding assignments and automated evaluation, the Platform integrates a third-party assessment and coding-evaluation service engaged by WCE. When you launch an assessment:

• your name, email address and internal learner identifier are transmitted to the assessment environment solely to authenticate you and to attribute your submissions and results to your account;
• your submissions, scores and results are processed and returned to the Platform; and
• examination-integrity signals, including your IP address, browser/user-agent and device metadata, count of tab/focus switches, time-on-task, submission timestamps and similarity/plagiarism indicators, may be recorded to uphold academic honesty.

10.2 MATLAB-based assessments (MathWorks and Vocareum)

Where a course uses MATLAB Grader for automatically graded MATLAB assignments, the assessment is delivered through the MATLAB Grader environment provided by MathWorks and operated on the Vocareum platform, integrated using the LTI 1.3 (Learning Tools Interoperability) standard.

For these assignments, the following identity information is securely transmitted to MathWorks / Vocareum within a digitally signed identity token, solely to launch the assignment, identify you as the learner, and return your grade to the Platform:

• your full name (including given and family name);
• your email address;
• your role in the course (for example, learner or instructor); and
• course and assignment context (the course and the specific resource being launched).

MathWorks and Vocareum process this data as independent providers under their own privacy terms for the purpose of delivering and grading MATLAB assessments and returning results to WalchandPRO. Because these providers operate internationally, this involves a cross-border transfer as described in Section 12.

10.3 Purpose limitation for integrity data

Examination-integrity signals are used only to safeguard the fairness and validity of assessments (for example, to detect malpractice or plagiarism). They are not used for advertising, profiling, or any purpose unrelated to academic integrity, and they are retained for a limited period as set out in Section 15.

11. Recipients, Who We Share Your Data With

We do not sell your personal data. We share personal data only where necessary for the purposes described in this Policy, and only with recipients bound by appropriate confidentiality and security obligations. The recipients are:

• Euclideum Solutions Private Limited (Technology and Operations Partner): our Data Processor, which develops, hosts, maintains and operates the Platform on WCE’s behalf. Euclideum may process your data only on WCE’s documented instructions, and is contractually bound to keep it confidential and secure and not to use it for any independent purpose.
• Payment gateway (PCI-DSS-certified payment service provider): receives the transaction and billing information necessary to process your payments and refunds, as described in Section 9.
• Assessment and coding-evaluation service: receives your name, email and learner identifier, together with your submissions, in order to deliver assessments and return results, as described in Section 10.1.
• MathWorks and Vocareum: receive your identity and course-context information for the delivery and grading of MATLAB-based assessments, as described in Section 10.2.
• Course instructors and faculty: authorised instructors can view your name, enrolment status, learning progress and assessment scores for the courses they teach. Instructors cannot access your payment, billing or taxation data.
• Government, regulatory and law-enforcement authorities: where disclosure is required by law, court order, or a valid legal process, or is necessary to prevent fraud, protect our rights, or safeguard the security or safety of any person.
• Successor entity (business transfer): in the event that WCE’s relevant operations are reorganised, transferred or assumed by a successor entity, your personal data may be transferred to that entity, subject to equivalent privacy protections and continued compliance with this Policy.

We do not share your personal data with advertisers, data brokers, or third-party marketing companies.

12. International and Cross-Border Data Transfers

Certain assessment services described in Section 10.2, namely MathWorks and Vocareum, are operated internationally, and delivering MATLAB-based assessments therefore involves transferring limited identity and course-context data outside India.

Where personal data is transferred outside India, we ensure that:

• the transfer is limited to what is strictly necessary for the stated purpose;
• the transfer is not made to any territory restricted by the Central Government under the DPDP Act; and
• the recipient is subject to contractual and/or legal obligations to protect the data to a standard consistent with this Policy and applicable Indian law.

All other personal data is hosted and processed within India by our Technology and Operations Partner, save as expressly stated in this Policy.

13. Cookies and Similar Technologies

Cookies are small text files placed on your device that enable the Platform to function and to remember information about your visit.

13.1 Categories of cookies we use

• Strictly necessary cookies: required for the Platform to operate. They manage your login session, keep you securely signed in, and support core security functions. These cannot be disabled, as the Platform cannot function without them.
• Functional cookies: remember your preferences, such as your interface/theme selection and your position within a course, to improve usability.
• Analytics cookies (where enabled): help us understand, on an aggregated and de-identified basis, how the Platform is used so that we can improve it. We do not use analytics cookies to identify you individually.

We do not currently use third-party advertising cookies, cross-site tracking cookies, or cookies that build marketing profiles about you. Should we introduce any non-essential cookie that requires your consent, we will obtain that consent before it is set.

13.2 Managing cookies

You can manage or delete cookies through your browser settings at any time. Disabling non-essential cookies will not prevent you from using the Platform, although some convenience features may be affected. Disabling strictly necessary cookies may prevent the Platform from functioning correctly.

14. Do-Not-Track Signals

Some browsers transmit a “Do Not Track” (DNT) signal. As there is currently no uniform industry or legal standard governing how platforms should respond to DNT signals, WalchandPRO does not respond to DNT signals at this time. If a binding standard is adopted in the future, we will update this Policy and our practices accordingly.

15. Data Retention Periods

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with our legal and statutory obligations, to resolve disputes, and to enforce our agreements. The specific retention periods are set out below.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer identify you.

16. How We Secure Your Data

We implement reasonable security practices and procedures commensurate with the nature of the data we hold, including the following technical and organisational measures:

• Encryption in transit: all data exchanged between your device and the Platform is encrypted using industry-standard SSL/TLS.
• Password protection: passwords are stored only in securely hashed, irreversible form; they are never stored or transmitted in plain text.
• Access controls: personal data is accessible only to authorised WCE personnel and authorised processors, strictly on a role-based, need-to-know basis.
• Processor obligations: our Technology and Operations Partner and all other processors are contractually bound to implement appropriate security measures and to maintain the confidentiality of your data.
• Payment security: sensitive payment credentials are handled exclusively by a PCI-DSS-certified payment gateway and never traverse our systems.
• Security governance: we conduct periodic security reviews and apply updates and patches to safeguard the Platform.
• Breach response: we maintain procedures to detect, respond to, and report personal-data breaches (see Section 20).

No method of transmission or storage is entirely infallible. While we take every reasonable precaution to protect your data, we cannot guarantee absolute security. We encourage you to protect your account credentials, use a strong and unique password, and access the Platform only over trusted networks.

17. Your Rights as a Data Principal

Subject to applicable law, you have the following rights in respect of your personal data. We will not discriminate against you for exercising any of these rights.

• Right to access: you may request confirmation of whether we process your personal data and obtain a summary of the personal data we hold about you and the processing activities undertaken.
• Right to correction and completion: you may request that we correct inaccurate or misleading data, complete incomplete data, and update out-of-date data.
• Right to erasure: you may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to any overriding legal obligation that requires us to retain it (for example, statutory retention of tax records).
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time, as described in Section 8.
• Right of grievance redressal: you may raise a complaint regarding our processing of your personal data with our Grievance Officer (see Section 23).
• Right to nominate: you may nominate another individual to exercise your rights under the DPDP Act in the event of your death or incapacity.
• Right to information about sharing: you may request details of the recipients with whom your personal data has been shared, as described in Section 11.

How to exercise your rights. To exercise any of the above rights, please email us at walchandpro@walchandsangli.ac.in with the subject line: “Data Rights Request, [Your Name]”. To protect your privacy, we may take reasonable steps to verify your identity before acting on a request. We will respond to verified requests within fifteen (15) working days of receipt, or such shorter period as may be prescribed by law.

18. Children’s and Minors’ Data

WalchandPRO is an educational platform primarily intended for learners pursuing higher and continuing education. We recognise that some bona fide enrolled students may be minors (under eighteen years of age).

• We do not collect a learner’s date of birth or use age to profile learners.
• Where a learner is a minor, personal data is processed solely for the legitimate educational purpose of delivering courses, conducting assessments, and issuing certificates, consistent with the learner’s institutional enrolment and applicable law.
• We do not undertake targeted advertising, behavioural profiling, or tracking-based marketing directed at children.
• Examination-integrity monitoring described in Section 10.3 is limited to safeguarding assessment fairness and is not used to profile any learner.

If you believe that a minor has provided personal data without appropriate parental or guardian consent, or in a manner inconsistent with applicable law, please contact us at walchandpro@walchandsangli.ac.in and we will review the matter and, where required, delete the relevant data promptly.

19. Automated Decision-Making and Profiling

We do not use your personal data to make solely automated decisions that produce legal or similarly significant effects on you. Automated grading of assessments (for example, coding evaluation or MATLAB Grader scoring) evaluates the correctness of your submitted work only, and does not, by itself, determine any significant outcome affecting your legal rights.

20. Personal Data Breach Notification

Despite our safeguards, no system is entirely immune to security incidents. In the event of a personal-data breach that is likely to result in a risk to your rights and interests, we will:

• take prompt steps to contain and remediate the breach;
• notify the relevant supervisory authority (including the Data Protection Board of India, once constituted and to the extent required) within the timeframes prescribed by applicable law; and
• notify affected Data Principals where required, describing the nature of the breach, its likely consequences, and the measures taken or proposed to address it.

We maintain internal records of personal-data breaches and our response to them.

21. Third-Party Links

The Platform may contain links to third-party websites, resources or services that are not operated or controlled by WCE. We are not responsible for the privacy practices, content or security of such third parties. We encourage you to review the privacy policy of any external website or service before providing it with your personal data.

22. Changes to This Privacy Policy

We may update this Policy from time to time to reflect changes in law, technology, or our processing practices. When we make changes:

• the “Last Updated” date at the top of this document will always reflect the date of the most recent revision;
• where the changes are material, we will provide prominent notice through the Platform and/or by email before the changes take effect; and
• your continued use of the Platform after the effective date of the revised Policy constitutes your acknowledgement of the updated Policy, save that any processing based on consent will continue to require your consent.

We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

23. Grievance Officer and Data Protection Contact

In accordance with the Information Technology Act, 2000, the Consumer Protection (E-Commerce) Rules, 2020, and the Digital Personal Data Protection Act, 2023, we have designated a Grievance Officer to address your concerns regarding this Policy and the processing of your personal data.

If you are not satisfied with the resolution provided by our Grievance Officer, you may escalate your complaint to the appropriate authority constituted under the applicable data-protection law, including the Data Protection Board of India, once it is formally established.

24. How to Contact Us

For any questions, requests, or concerns relating to this Policy or your personal data, please contact us:

25. Governing Law and Jurisdiction

This Policy is governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts at Sangli, Maharashtra, India, without prejudice to any statutory forum or authority vested with jurisdiction under applicable data-protection or consumer-protection law.

This Privacy Policy is issued by Walchand College of Engineering, Sangli, and governs the processing of personal data on the WalchandPRO platform. It reflects the actual data-processing practices of the Platform as at the effective date stated above.