THE SCENHOLM PARENT PLEDGE
This Pledge sits above the formal Privacy Policy. It is written in plain language, in our voice, so a parent can read it in a minute and know where we stand.
The full Privacy Policy follows. If there is any difference between the Pledge and the Privacy Policy, the Privacy Policy will apply.
1. We collect only what we need.
Names, contact details, basic programme information, and what a parent chooses to tell us. We do not ask for, or store, what we do not need to run a session responsibly.
2. We never sell personal information.
Not to advertisers, not to data brokers, not to anyone. Your trust is not a revenue line.
3. We will not use a child's image, voice, or words in any public marketing without your specific written consent for that specific use.
Consent for a parent debrief is not consent for a brochure. Consent for a brochure is not consent for an Instagram ad. Each use is a separate decision.
4. We will not put your child's identifiable information into WhatsApp.
WhatsApp is used only for adult-facing logistics with the parent or lawful guardian. Programme observations, session notes, debrief content, and media of children flow through more controlled channels.
5. Where you enrol with us directly, your child's school does not see their Scenholm data unless you specifically ask us to share it.
For programmes run in partnership with a school, different rules apply, and we will tell you clearly at the point of enrolment.
6. We do not track, profile, or behaviourally target children.
No retargeting ads to minors. No behavioural profiling. No automated decisions about a child's ability, character, or future.
7. We will tell you promptly if a data incident affects your child's information.
Within the timeframe required by Indian law, and with clear information about what happened and what we are doing about it.
8. Our facilitators are vetted, trained, and never alone with a single student in unsupervised settings.
Sessions are run with appropriate adult presence and oversight. A separate Safeguarding Policy sets out the full standard.
If any of these commitments matters enough to you to ask about, write to us at privacy@scenholm.com. We will answer.
PART A — THE PARENT-READABLE SUMMARY
This first section is written for parents and lawful guardians. It explains how Scenholm thinks about privacy in plain language.
The detailed policy follows in Part B. If there is any difference between this summary and the detailed policy, the detailed policy will apply.
A1. The simple version
Scenholm works with families and students. We treat personal information, especially information about children and teenagers, with care.
We collect information only when it helps us:
- respond to a parent enquiry;
- book a discovery session;
- understand which programme may fit your child;
- run a session safely and responsibly;
- communicate with parents;
- manage payments, invoices, refunds, and records;
- meet legal, tax, accounting, consent, or safety requirements.
We do not sell personal information.
We do not use children's personal information for targeted advertising, behavioural tracking, behavioural monitoring, or any processing that could be detrimental to a child's well-being.
We do not publish identifiable photos, videos, audio, testimonials, or programme clips of a Minor Student without specific written parent or lawful guardian consent for the specific use.
We do not keep child-specific programme information longer than necessary.
A2. What information we usually collect
For a parent or lawful guardian, we may collect:
- your name;
- phone number;
- email address;
- city or locality;
- the programme you are interested in;
- booking and payment details;
- the questions or information you choose to share with us.
For a student, we may collect:
- name;
- age or grade;
- school or educational stage, if relevant;
- programme or cohort information;
- attendance details;
- limited programme notes or observations needed for parent communication, student support, or safe programme delivery.
We avoid collecting sensitive information unless it is genuinely needed. A parent may choose to tell us about a medical, dietary, accessibility, safety, or support need so that we can run the session responsibly.
A3. Children and teenagers
Students below 18 should not submit information to Scenholm on their own.
A parent or lawful guardian should be involved in discovery-session booking, programme enrolment, payment, consent, and media permission.
Where required by Indian law, including the Digital Personal Data Protection Act, 2023, we take reasonable steps to obtain verifiable parental or lawful guardian consent before processing a Minor Student's personal information.
A4. Photos, videos, audio, and programme evidence
Scenholm may capture photographs, video, audio, or written observations during a session for limited purposes such as:
- parent debriefs;
- internal programme review;
- student support;
- facilitator training;
- quality improvement;
- private communication with the relevant family.
We use a granular consent approach. A parent or lawful guardian may consent separately to:
- internal use only (parent debrief, facilitator training, quality review);
- closed-cohort or family-only sharing;
- public marketing on Scenholm channels;
- public marketing on third-party platforms (Meta, Google, YouTube);
- press, podcasts, or media features.
Consent for one of these uses is not consent for another. A parent or lawful guardian may withdraw consent for future use at any time by writing to privacy@scenholm.com.
A5. Co-working offices, shared workspaces, and venue access
Scenholm may run sessions in co-working offices, shared workspaces, meeting-room facilities, school premises, event venues, or similar third-party locations.
These venues may require visitor information for building access, safety, reception, security, or attendance management.
This may include limited information such as:
- attendee name;
- parent or guardian name, where needed;
- contact number, where required by the venue;
- date and time of visit;
- session or event name;
- visitor-list or access-list information;
- emergency or safety information, where necessary.
We share only the minimum information reasonably required for the venue purpose.
We do not share student information with venues for their independent marketing purposes.
A6. School-partner programmes
Some Scenholm programmes are organised in partnership with a school or institutional partner.
If your child is enrolled in Scenholm through a school partnership, the school is involved in the data flow. The school may receive attendance information and individual student progress reports, and the school's own privacy policy and consent process will also apply.
This will be made clear to you at the point of enrolment so you know which regime applies before consenting.
If you enrol with Scenholm directly, we do not share your child's Scenholm information with their school unless you specifically ask us to in writing.
A7. How long we keep child-specific information
Our approach is to keep child-specific programme information for the minimum period necessary.
After a programme is completed, student-specific programme notes, observations, attendance details, and media records are deleted, anonymised, or de-identified when they are no longer needed.
Some records are kept longer where required by law or legitimate operational need — for example, payment records for tax purposes, or consent records to demonstrate that lawful consent was obtained.
Indicative retention periods are listed in Section B19.
A8. Website cookies, analytics, and ads
Like most websites, Scenholm may use cookies, pixels, analytics tools, and campaign tools to understand whether our website and parent-facing campaigns are working.
We may use these tools for adult-facing marketing.
We do not use cookies, pixels, or advertising tools to target children with behavioural advertising.
A separate Cookie Notice sets out which cookies we use and how to manage them.
A9. Your choices and rights
You may contact us to:
- ask whether we hold personal information about you or your child;
- correct or update information;
- request access to information;
- withdraw consent where consent is the basis for use;
- request deletion, subject to legal and operational limits;
- opt out of marketing communication;
- withdraw future permission for public use of student photos, videos, audio, or testimonials;
- raise a privacy concern;
- nominate another person to exercise your rights, where applicable.
For a Minor Student, these requests should generally come from the parent or lawful guardian.
Privacy contact: privacy@scenholm.com
Grievance Officer: To be appointed before paid enrolment opens — privacy@scenholm.com
A10. Need this in another language?
This Privacy Policy is published in English.
If Hindi, Telugu, Kannada, or another Indian language is easier for you, please write to us at privacy@scenholm.com. We will make reasonable efforts to provide a translated summary or explanation for parent convenience.
The English version will remain the official version if there is any difference in meaning.
PART B — DETAILED PRIVACY POLICY
This section contains the detailed legal and operational policy. It is written more formally so that the obligations, rights, exceptions, and safeguards are clear.
B1. Our position under Indian law
Scenholm Labs LLP processes personal information in accordance with applicable Indian law, including the Digital Personal Data Protection Act, 2023 (the "DPDP Act") and the rules made under it.
Because Scenholm's services involve children, we observe the additional protections that the DPDP Act applies to a "child" (defined as an individual below 18 years of age):
- we obtain verifiable consent from a parent or lawful guardian before processing a Minor Student's personal information for programme-related purposes;
- we do not undertake processing that is likely to cause any detrimental effect on the well-being of a Minor Student;
- we do not undertake tracking or behavioural monitoring of Minor Students;
- we do not undertake targeted advertising directed at Minor Students.
Scenholm has appointed a Grievance Officer who is responsible for receiving and responding to privacy complaints and Data Principal requests. Contact details are set out in Section B27.
B2. Our position on privacy
Scenholm works with families, students, and schools. That means privacy is part of the trust a family places in us.
This Privacy Policy explains what personal information we collect, why we collect it, how we use it, when we may share it, how long we keep it, and how parents, lawful guardians, students, and other users may contact us about it.
Our principle is simple:
We collect only what we need to respond to enquiries, run our programmes responsibly, communicate with families, protect student safety, improve our services, and meet legal or operational obligations.
We do not sell personal information.
We do not use children's personal information for targeted advertising, behavioural monitoring, or tracking.
We do not publish identifiable student photographs, videos, audio, testimonials, or programme material without specific written consent for the specific use.
Students below 18 should not submit personal information to Scenholm without parent or lawful guardian involvement.
B3. Who this policy applies to
This policy applies to personal information we collect from or about:
- parents, lawful guardians, and adult family members who enquire about Scenholm;
- students who attend, enquire about, or participate in Scenholm programmes, discovery sessions, workshops, or events;
- school representatives, venue partners, facilitators, vendors, professional advisers, and collaborators;
- visitors to Scenholm websites, landing pages, booking pages, forms, WhatsApp flows, emails, social media pages, advertisements, and campaign pages.
Where we collect information about a Minor Student, the parent or lawful guardian remains the primary decision-maker and contact point unless applicable law requires otherwise.
B4. Definitions
For this Privacy Policy:
"Scenholm", "we", "us", or "our" means Scenholm Labs LLP.
"Services" means our website, landing pages, discovery sessions, programmes, workshops, events, forms, booking flows, payment flows, WhatsApp communication, email communication, and related online or offline services.
"Parent" or "Lawful Guardian" means an adult who has legal authority or responsibility to act for the student.
"Student" means a person who attends, enquires about, or participates in a Scenholm programme, discovery session, workshop, or event.
"Minor Student" means a student below 18 years of age.
"Personal Information" means information that identifies, or can reasonably identify, a person. This may include name, email address, phone number, age, grade, school, locality, booking details, enquiry details, attendance records, photographs, videos, audio recordings, payment-related information, and communication records.
"Sensitive Information" means information that may require additional care under applicable law or good privacy practice, such as health information, medical or safety information, payment information, official identifiers, passwords, biometric information, or other legally sensitive categories. For Scenholm specifically, this also includes facilitator-generated observations about a Minor Student's behaviour, emotional response, or interpersonal patterns made during a session.
"DPDP Act" means the Digital Personal Data Protection Act, 2023 and the rules made under it.
"Data Principal" means the individual to whom personal information relates. For a Minor Student, the Data Principal is the Minor Student, and the parent or lawful guardian acts on their behalf.
B5. Parent and lawful guardian consent for minors
Scenholm's programmes are designed for students, including minors. We therefore treat children's and teenagers' personal information with additional care.
For Minor Students:
- enrolment, discovery-session booking, and programme participation must be initiated or approved by a parent or lawful guardian;
- we rely on verifiable consent from a parent or lawful guardian before collecting or using a Minor Student's personal information for programme-related purposes;
- where required by applicable law, including the DPDP Act, we may take reasonable steps to verify that the person providing consent is an adult parent or lawful guardian;
- the parent or lawful guardian remains the primary contact for registration, payment, programme communication, consent, media permission, withdrawal, correction, or deletion requests.
Consent is sought for, where relevant:
- programme participation;
- collection of basic personal information needed to run the programme;
- collection of any sensitive information voluntarily shared by the parent;
- photo, video, or audio capture during a session;
- the specific use of any captured media (see Section B9);
- parent-facing communication channels (email, WhatsApp, phone).
Minor Students should not independently submit personal information to Scenholm forms, WhatsApp flows, booking pages, or programme channels without parent or lawful guardian involvement.
If we learn that a Minor Student has provided personal information without appropriate parent or lawful guardian involvement, we may contact the parent or lawful guardian, restrict use of the information, or delete it where appropriate.
B6. Information we may collect
The information we collect depends on how you interact with Scenholm.
B6.1 Parent / guardian information
We may collect:
- name;
- email address;
- phone number;
- city, locality, or preferred programme location;
- preferred programme, cohort, or student age band;
- discovery-session booking details;
- WhatsApp, email, phone, or form communication;
- questions, preferences, concerns, or context you choose to share with us;
- marketing consent and communication preferences.
B6.2 Student information
We may collect:
- student name;
- age or date of birth, if needed;
- grade, school, curriculum, or educational stage, if relevant;
- programme interest, cohort, attendance, or participation status;
- information a parent or lawful guardian chooses to share to help us understand programme fit, safety, or support needs;
- broad programme observations needed for parent communication, quality review, or student support.
We do not ask students to provide unnecessary personal information.
B6.3 Discovery session and programme information
We may collect:
- registration and attendance records;
- parent communication history;
- programme logistics and scheduling details;
- broad participation notes needed to run the programme safely and responsibly;
- parent debrief notes or family communication records;
- selected photographs, videos, or audio recordings, only where appropriate consent has been obtained for the specific use.
B6.4 Payment and billing information
If you make a payment, we may collect or receive limited information necessary to process and record the transaction, such as:
- payer name;
- billing details;
- payment status;
- transaction reference;
- invoice or receipt details;
- GST, tax, or accounting information, where applicable.
Payments are processed through third-party payment processors. Scenholm does not store full card numbers, card authentication data, UPI PINs, banking passwords, or other payment authentication credentials.
B6.5 Website, analytics, and campaign information
When you visit our website or campaign pages, we may collect limited technical and usage information such as:
- device type;
- browser type;
- IP address or approximate location derived from technical signals;
- pages visited;
- referral source;
- date and time of visit;
- form submissions;
- booking-link interactions;
- campaign, advertisement, or social media interaction data;
- cookie, pixel, or analytics information, where applicable.
This helps us understand whether our website is working, whether parents can find the information they need, and whether our adult-facing campaigns are reaching relevant decision-makers.
B6.6 Information from third-party tools
We may receive limited information from service providers that support our operations, such as:
- website hosting providers;
- booking tools;
- form tools;
- payment processors;
- email tools;
- WhatsApp or CRM tools;
- analytics tools;
- advertising platforms;
- social media platforms;
- venue or operations partners.
The information available to us depends on the privacy settings, policies, and technical design of those third-party services.
B7. Sensitive information
Scenholm generally avoids collecting Sensitive Information unless it is genuinely needed.
A parent or lawful guardian may voluntarily share health, medical, emotional, behavioural, accessibility, dietary, or safety-related information if they believe it is necessary for safe and responsible participation.
We may use such information only for relevant purposes such as:
- student safety;
- reasonable support during a session;
- medical or emergency context;
- dietary or venue planning;
- responsible facilitator awareness;
- legal or operational obligations.
In addition, observations made by a Scenholm facilitator during a session about a Minor Student's behaviour, emotional response, or interpersonal patterns are treated with the same care as health and safety information. These observations are recorded only where necessary for parent communication, student support, or programme quality, and are accessible only to authorised personnel on a need-to-know basis.
We do not use biometric attendance, facial recognition, or facial-pattern analysis unless we separately notify the parent or lawful guardian and obtain appropriate consent.
B8. How we collect information
We may collect information when you:
- visit our website or landing pages;
- submit a form;
- contact us by email, phone, WhatsApp, Instagram, or another channel;
- book a discovery session;
- attend a discovery session, workshop, or programme;
- make a payment;
- respond to a survey, feedback request, or parent communication;
- interact with our advertisements or social media pages;
- communicate with us through a school, partner, referral source, venue, or collaborator.
We may also collect limited information automatically through cookies, pixels, analytics tools, server logs, and similar technologies.
B9. How we use information
We may use personal information to:
- respond to enquiries;
- schedule discovery sessions;
- understand programme fit;
- manage enrolment, attendance, payment, refunds, invoices, and programme logistics;
- communicate with parents and lawful guardians before, during, and after a programme;
- support student safety and responsible programme delivery;
- provide parent-visible updates or debriefs where applicable;
- maintain internal records;
- train and guide programme teams on a need-to-know basis;
- improve our website, communication flows, and programme experience;
- understand adult-facing campaign performance;
- send relevant updates about Scenholm programmes, events, or availability;
- prevent misuse, fraud, unauthorised access, or safety issues;
- comply with legal, tax, accounting, compliance, dispute-resolution, or regulatory obligations;
- conduct programme research, curriculum design, and thought leadership using only aggregated, anonymised, or de-identified information that does not reasonably identify a student, parent, lawful guardian, or family.
We do not use children's personal information for targeted advertising, behavioural monitoring, or tracking.
B10. Photos, videos, audio, testimonials, and programme evidence
Scenholm may capture photographs, video, audio, parent-visible clips, or programme observations during a session. The use of any such material is governed by granular consent.
Consent is sought separately for each of the following categories:
- Internal use only — parent debrief, facilitator training, internal quality review, private communication with the relevant family;
- Closed-cohort or family-only sharing — sharing with the specific family or cohort to which the material relates;
- Public marketing on Scenholm channels — Scenholm website, Scenholm-owned social media, Scenholm brochures and decks;
- Public marketing on third-party platforms — Meta, Google, YouTube, or other paid advertising platforms;
- Press, podcasts, or media features — interviews, press articles, podcast appearances, or third-party media coverage.
Consent for one category is not consent for another. The default position is that no identifiable image, video, audio recording, or quote of a Minor Student is used in any public Scenholm marketing without specific written parent or lawful guardian consent for that specific use.
Where multiple students appear in the same frame and consent positions differ, Scenholm will either obtain consent from all relevant parents, blur or remove non-consenting students, or not use the material publicly.
A parent or lawful guardian may withdraw consent for future use at any time by contacting privacy@scenholm.com. Withdrawal does not affect use that has already occurred lawfully before the request, but we will take reasonable steps to stop future public use where practicable.
Parents, students, and participants should not record, photograph, publish, forward, or share images, videos, audio, names, comments, or personal information of other students, parents, facilitators, or participants without appropriate permission.
B11. WhatsApp and adult-facing communication channels
Scenholm uses WhatsApp for adult-facing logistics communication with parents and lawful guardians, such as booking confirmations, session reminders, payment communication, programme updates, and direct responses to parent queries.
WhatsApp messages flow through Meta's infrastructure. While Meta states that messages are end-to-end encrypted, certain metadata (phone numbers, timestamps, business message templates) flow through Meta's systems. Parents who prefer not to use WhatsApp may choose email or phone communication instead.
We do not transmit Minor Student programme observations, session notes, debrief content, or media of children through WhatsApp. Where such information needs to be shared with a parent, we use email or another more controlled channel.
B12. Cookies, pixels, analytics, and advertising tools
Our website and campaign pages may use cookies, pixels, tags, web beacons, server logs, or similar technologies to:
- keep the website functioning;
- remember basic preferences;
- understand page visits and user journeys;
- measure campaign performance;
- improve website clarity;
- detect technical issues;
- support adult-facing marketing and retargeting where permitted.
These technologies may be provided by tools such as hosting providers, analytics providers, booking tools, Meta / Instagram, Google, WhatsApp-related tools, or similar services.
A separate Cookie Notice sets out the specific cookies we use and how to accept, decline, or manage non-essential cookies.
You may control cookies through your browser settings. Some website features may not work properly if cookies are disabled.
Scenholm does not use cookies, pixels, or advertising tools to target children with behavioural advertising.
B13. Marketing communication
If you contact Scenholm, submit a form, book a session, register interest, attend an event, or interact with our campaigns, we may contact you about:
- discovery sessions;
- cohort availability;
- programme dates;
- parent information sessions;
- relevant Scenholm updates.
You may opt out of marketing communication by contacting us at privacy@scenholm.com or hello@scenholm.com, or by using any unsubscribe or opt-out mechanism provided in the relevant channel.
Even if you opt out of marketing, we may still send service-related messages such as booking confirmations, payment information, programme logistics, safety updates, refund communication, policy updates, or responses to your direct requests.
B14. Automated decisions and profiling
We do not use personal information to make solely automated decisions that produce legal or similarly significant effects for a parent, lawful guardian, or student.
We do not undertake behavioural profiling of Minor Students.
We may use limited analytics to understand website performance, campaign effectiveness, enquiry trends, and programme operations. These analytics are used to improve Scenholm and are not used to make automated decisions about a child's eligibility, ability, character, or future prospects.
B15. Sharing information with others
We may share limited personal information where necessary and appropriate with:
- Scenholm team members, facilitators, and authorised personnel on a need-to-know basis;
- booking, form, hosting, email, WhatsApp, CRM, analytics, and communication service providers;
- payment processors and accounting systems;
- venue providers, property managers, shared-workspace operators, security teams, reception teams, or operational partners, where needed for venue access, safety, attendance, security, visitor registration, or programme logistics;
- external observers, guest experts, or specialist contributors invited to a session, where they are subject to confidentiality expectations and parents have been informed in advance where appropriate;
- professional advisers such as legal, accounting, tax, compliance, or insurance advisers;
- school or institutional partners, where a programme is organised through or with a school and where sharing is part of the partnership terms (see Section B17);
- government, regulatory, judicial, law-enforcement, or statutory authorities where required by law;
- parties involved in a business transfer, merger, restructuring, acquisition, sale, or reorganisation, subject to appropriate confidentiality and legal safeguards.
We do not allow service providers to use personal information for their own unrelated purposes where we control the use of that information.
We may also use or disclose aggregated, anonymised, or de-identified information that does not reasonably identify a student, parent, lawful guardian, or family.
B16. Legal disclosure and safety
We may disclose personal information if we believe in good faith that disclosure is necessary to:
- comply with applicable law, regulation, court order, government request, or legal process;
- enforce our Terms, policies, programme rules, or agreements;
- protect the rights, safety, property, or security of Scenholm, students, parents, facilitators, partners, or others;
- detect, prevent, investigate, or respond to fraud, misuse, unauthorised access, safety concerns, technical issues, or unlawful activity;
- defend against legal claims or support dispute resolution.
Where legally permitted and appropriate, we may attempt to notify affected individuals before disclosure in response to legal requests.
B17. School and institutional partner programmes
Some Scenholm programmes are organised in partnership with a school or institutional partner. Where this is the case, the data flow is different from direct enrolment, and parents are informed at the point of enrolment.
B17.1 School-partner enrolment
If a Minor Student is enrolled in Scenholm through a school partnership:
- the school is involved in the data flow;
- attendance information and individual student progress reports may be shared with the school as part of the partnership;
- the school's own privacy policy and consent process will also apply alongside this Privacy Policy;
- parents are informed of this arrangement at the point of enrolment so they can decide whether to consent;
- the specific information shared with the school is limited to what is reasonably necessary for the partnership and is set out in the partnership terms.
Where a school is the primary controller of student information (for example, where the school provides student lists, manages parent consent, and runs enrolment internally), the school's own privacy policy governs the school-side data flow, and parents may need to address requests about that data flow to the school directly.
B17.2 Direct enrolment
If a parent or lawful guardian enrols a Minor Student with Scenholm directly:
- Scenholm does not share the student's Scenholm information with their school;
- if the school later contacts Scenholm requesting information about the student, Scenholm will not share that information without specific written consent from the parent or lawful guardian for that specific request;
- this applies even if the school is a Scenholm partner for other students.
B17.3 Hybrid arrangements
Where a school refers parents to Scenholm but the parent enrols directly with Scenholm, the direct-enrolment regime in Section B17.2 applies. Referral does not authorise data sharing with the referring school.
B18. Co-working offices, shared workspaces, and venue access
Scenholm may conduct discovery sessions, workshops, or programmes in co-working offices, shared workspaces, meeting-room facilities, school premises, event venues, or similar third-party locations.
When we use such venues, we may be required to follow the venue's access, visitor, safety, security, and operational policies. This may include sharing limited attendee information with the venue provider, property manager, reception desk, security team, or facilities team.
The information shared will be limited to what is reasonably required for the relevant venue purpose, such as:
- attendee name;
- parent or guardian name, where needed;
- contact number, where required by the venue;
- date and time of visit;
- session or event name;
- access list or visitor-list information;
- emergency or safety-related information, where necessary.
We do not share student information with venues for their independent marketing purposes. Venue providers and property managers may have their own visitor, CCTV, security, access-control, or building-entry policies. Where applicable, parents, guardians, students, and other attendees may also be subject to those venue policies while on the premises.
B19. Storage, security, and access control
We use reasonable organisational, technical, and physical safeguards to protect personal information from unauthorised access, misuse, loss, alteration, or disclosure.
These measures may include:
- limiting access to authorised personnel on a need-to-know basis;
- using reputable service providers;
- maintaining internal confidentiality expectations;
- using secure systems where practicable;
- keeping programme and student information restricted to relevant operational purposes;
- reviewing access and retention practices as Scenholm grows.
No digital or physical system is completely risk-free. We therefore collect only what we need, limit access, and take reasonable steps to protect information in our control.
B20. Child safety and safeguarding
Scenholm runs live sessions with children and teenagers. Privacy and safeguarding are connected but distinct concerns, and Scenholm maintains a separate Safeguarding Policy that sets out the full standard.
In summary:
- facilitators are vetted, trained, and operate under written conduct expectations;
- sessions are run with appropriate adult presence; a Scenholm facilitator is not alone with a single Minor Student in unsupervised settings;
- safeguarding concerns raised by a student, parent, or facilitator are recorded, escalated to the designated Scenholm safeguarding lead, and communicated to the relevant parent where appropriate;
- a parent or student with a safeguarding concern may contact safeguarding@scenholm.com [or as updated in the Safeguarding Policy].
The full Safeguarding Policy is available on request and is published on the Scenholm website.
B21. Data incidents
If we become aware of a data incident involving personal information, we will take reasonable steps to assess, contain, investigate, and address the incident.
Where required by applicable law, including the DPDP Act, we will notify the Data Protection Board of India and affected Data Principals within the timeframe and in the manner prescribed by law. Notification will include appropriate information about the nature of the incident, the personal information affected, and the steps being taken.
B22. Retention of information
Scenholm follows a data-minimisation approach to retention. We do not keep personal information, especially child-specific programme information, for longer than necessary.
We retain personal information only for the minimum period reasonably required for the purpose for which it was collected, or for the period required or permitted by applicable law.
The following indicative retention periods apply. Specific records may be retained for shorter or longer periods where necessary, for example to address an ongoing dispute, safety matter, or legal obligation.
| Category of record | Indicative retention period |
|---|---|
| Enquiry data not converted to enrolment | Up to 12 months from last contact, then deleted or anonymised |
| Discovery-session records (no enrolment) | Up to 12 months, then deleted or anonymised |
| Programme observations and facilitator session notes (Minor Student) | Up to 6 months after programme completion, then deleted, anonymised, or de-identified |
| Photos, videos, and audio used for parent debrief only | Up to 12 months after programme completion, unless specific consent given for longer use |
| Photos, videos, and audio with public-marketing consent | Retained for as long as the consent is in force; deleted on withdrawal where practicable |
| Parent communication records | Up to 24 months after last interaction, then deleted or anonymised |
| Payment, invoice, GST, and tax records | Retained for the period required by Indian tax and accounting law (typically up to 8 years) |
| Consent records and media-permission records | Retained for as long as the consent is being relied on, plus a reasonable period thereafter |
| Safety, safeguarding, or incident records | Retained as required for safety, legal, and dispute-resolution purposes |
| Anonymised or aggregated programme research data | Retained without time limit, as it does not reasonably identify any individual |
Where information is no longer required, we will aim to delete, anonymise, or de-identify it rather than retain it in identifiable form.
B23. Your choices
You may choose:
- not to provide certain information, though this may limit our ability to respond to an enquiry or provide a service;
- to opt out of marketing communication;
- to disable cookies through your browser settings or the Cookie Notice;
- to withdraw consent where processing is based on consent;
- to request that we stop using identifiable photographs, videos, audio, or testimonials for future public use;
- to request correction, update, access, or deletion of personal information, subject to legal and operational limits.
If consent is withdrawn for information that is necessary to provide a service, Scenholm may be unable to continue providing that service.
B24. Your rights
Subject to applicable law, including the DPDP Act, parents, lawful guardians, adult users, and, where appropriate, students may contact us to:
- ask whether we hold personal information about them or their child;
- request access to personal information;
- correct inaccurate information;
- complete or update incomplete information;
- withdraw consent where processing is based on consent;
- request deletion or erasure of information;
- opt out of marketing communication;
- raise a privacy concern or complaint;
- nominate another person to exercise rights where applicable under law.
For a Minor Student's personal information, requests should generally come from the parent or lawful guardian.
We may need to verify your identity and, where relevant, your relationship to the student before acting on a request.
We aim to acknowledge privacy requests within 5 working days and respond within the timeframe required by applicable law.
If you are not satisfied with our response, you may escalate the matter to our Grievance Officer (see Section B27). If you remain dissatisfied, you may have a further right under the DPDP Act to approach the Data Protection Board of India.
B25. International and cross-border processing
Some of the technology services we use may store or process information outside India. These typically include:
- website hosting providers;
- email service providers;
- analytics tools;
- booking and form tools;
- WhatsApp / Meta business infrastructure;
- payment gateway infrastructure where applicable.
Where this occurs, we use reputable service providers and take reasonable contractual and technical steps to ensure that personal information is handled responsibly and in line with applicable law.
If the central government issues a list of countries to which transfers of personal information are restricted under the DPDP Act, we will adjust our practices accordingly.
If you access Scenholm from outside India, you understand that your information may be processed in India or in other countries where our service providers operate.
B26. Language support and translations
This Privacy Policy is published in English.
Translated summaries or explanations may be provided in Hindi, Telugu, Kannada, or other Indian languages on request for convenience.
If there is any inconsistency or difference in interpretation between a translated version and the English version, the English version will prevail.
B27. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in law, our services, our technology stack, or our operating practices.
The updated version will be posted on the website with a revised effective date.
If we make material changes that affect how we collect or use student personal information, we will take reasonable steps to provide notice where appropriate.
B28. Contact us
For privacy questions, correction requests, deletion requests, consent withdrawal, media-permission withdrawal, or privacy complaints, contact:
Scenholm Labs LLP
7th Floor, Innov8, Pranava Business Park, Kothaguda,
Hitec City Road, Hyderabad, Telangana - 500084, India
We aim to acknowledge privacy requests within 5 working days and respond within the timeframe required by applicable law.