1. Scope & Applicability
The direct subscriber of Sparrow Campus is the Institute.
- Students, parents/guardians, and employees access the application only through the Institute.
- Sparrow Campus does not directly contract with individual students, parents, or staff.
2. Roles Under Data Protection Laws
- The Institute is the Data Fiduciary / Data Controller.
- Sparrow Campus is the Data Processor.
- All data uploaded to Sparrow Campus remains the exclusive property of the Institute.
3. Information Processed
3.1 Personal Data
May include:
- Student, parent, guardian, and employee names
- Contact details (email, phone number, address)
- Identification and enrollment details
3.2 Sensitive / Special Category Data
Only if collected by the Institute:
- Academic records and performance data
- Financial data related to fee collection
- Health or biometric data (if integrated by the Institute)
3.3 Technical & Usage Data
Automatically collected:
- IP address and device information
- Login activity and system logs
- Error and performance diagnostics
4. Purpose of Data Processing
Data is processed solely to:
- Deliver campus management services
- Enable academic, administrative, and communication workflows
- Facilitate fee collection and reporting
- Improve platform reliability and security
- Comply with legal obligations
Sparrow Campus does not use data for advertising, profiling, or marketing.
5. Data Sharing & Disclosure
- Sparrow Campus follows a strict no-sharing, no-selling policy.
- Institute data is never shared with advertisers or third parties.
- Limited access is granted only to authorized personnel for technical support, maintenance, and security monitoring.
- Data may be disclosed only if required by law or lawful government request.
6. Data Storage & Hosting
- Data is stored on secure, cloud-based infrastructure.
- Industry-standard safeguards are used to prevent unauthorized access.
- Data may be stored in India or globally compliant data centers, subject to applicable regulations.
7. Data Retention & Deletion ("Complete Blackout")
- Data is retained for the duration of the Institute's subscription.
- Institutes may request complete blackout and permanent deletion at any time.
- Upon written request, all Institute data will be deleted from active systems and backups.
- Deletion will be completed within timelines prescribed under applicable laws.
- Once deleted, Sparrow Campus will not retain or recover the data.
8. Security Measures
Sparrow Campus implements reasonable security practices including:
- AES-256 encryption for data at rest
- Secure HTTPS/TLS transmission
- Role-based access controls
- Regular monitoring and security reviews
These measures align with Section 43A of the IT Act, 2000.
9. Institute Responsibilities
Institutes are responsible for:
- Obtaining valid consent from data principals
- Ensuring legality and accuracy of uploaded data
- Managing internal user access and permissions
- Handling data principal requests (access, correction, withdrawal)
10. Policy Updates
This Privacy Policy may be updated periodically. Revised versions will be published on our website with updated effective dates.
11. Contact
For privacy-related concerns:
Sparrow Smart Solutions (P) Limited
Email: hello@sparrowcampus.com
Address: CHP-103/1, Kanan Vihar, Bhubaneswar, Odisha 751031