India Privacy Supplement
Last updated: August 22, 2026
Overview
This supplement applies when GrowWise Omnix360 processes digital personal data in connection with India under the Digital Personal Data Protection Act, 2023 (DPDP Act) and the Digital Personal Data Protection Rules, 2025 (notified November 2025). It supplements the General Privacy Policy.
Data fiduciary and processor
- Where a school or Institution determines the purpose of processing student data, that Institution is typically the Data Fiduciary and GrowWise acts as a Data Processor.
- GrowWise may be a Data Fiduciary for marketing and direct platform accounts.
Purpose limitation and minimization
We collect personal data for specified purposes related to providing Omnix360 (accounts, instruction, assessment, support, security, and compliance). We do not use personal data for incompatible purposes without a lawful basis.
Children’s data
Processing of children’s personal data requires verifiable parental consent as set out in the DPDP Rules. Tracking and targeted advertising directed at children are restricted. See the Children & Minors Notice.
Breach notification
Where required by the DPDP Rules, we will:
- Notify affected Data Principals as required
- Report to the Data Protection Board of India within the prescribed timeframe (including detailed reporting within 72 hours where applicable)
Cross-border transfers
Personal data may be transferred outside India subject to the DPDP Act and any Central Government orders under Rule 15. Primary hosting is described in the General Privacy Policy (United States cloud regions and subprocessors).
Phased commencement
Certain DPDP Rules provisions commence on a phased schedule (Board-related provisions earlier; many operational obligations later, including through 2026–2027). We will update processes and this notice as obligations become enforceable.
Rights and grievances
Data Principals may exercise applicable rights (access, correction, erasure, withdrawal of consent, grievance redressal) by contacting connect@thegrowwise.com. School-mediated accounts should contact the school first where the school is the Data Fiduciary.