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Terms & Privacy

The rules for using this website and our courses, and how we look after the personal data you share with us. Written to cover both the GDPR (RGPD) and Indian data protection law.

Last updated: 12 September 2026

1. Terms of Service

These Terms of Service govern your use of the SPENGTRA website and the AI classes and related services we provide. By using this website, sending an enrollment or contact request, or attending a course, you agree to these terms. If you do not agree, please do not use the website or our services.

If you accept these terms on behalf of a company or another organisation, you confirm that you are authorised to bind that organisation.

1.1 Who we are

This website is operated by Fractal-Apps Pvt Ltd, a private limited company registered in India (CIN U74103PY2024PTC009235) with its registered office at Suite #28, Pulsebay, 64, Subbiah Salai, 605001, Pondicherry India, trading as SPENGTRA. Our full contact details are in the Contact & Grievance Officer section below.

1.2 Courses and enrollment

Course names, levels, durations, formats and prices are described on the Courses page and are shown in US dollars (USD). Submitting the enrollment form is a request, not a confirmed booking. A contract is formed only when we confirm your enrollment in writing (by email).

Courses are intended for professionals aged 18 or over. We may decline a request, reschedule a session, or cancel a course if a trainer becomes unavailable, and we will offer an alternative date or a refund of any amount paid for the affected sessions.

1.3 Payments, cancellation and refunds

Where a course is chargeable, payments are processed securely by our payment provider, Razorpay Software Private Limited (Razorpay). You enter your payment details directly on Razorpay’s secure checkout; we do not receive or store your full card, UPI or bank-account details. We receive only the limited information needed to confirm your booking, such as the payment status and a transaction reference.

The amount payable, the applicable currency and any taxes are shown at checkout and confirmed in your enrollment confirmation or invoice. Razorpay processes your payment data under its own terms and privacy policy.

Unless your enrollment confirmation states otherwise, you may reschedule or cancel by contacting us before the course begins. Any refund is governed by your enrollment confirmation and by the mandatory consumer-protection laws that apply to you, which these terms do not limit.

1.4 Intellectual property

The website, its content, and the course materials we provide are owned by us or our licensors and are protected by copyright and other intellectual-property laws. We grant you a personal, non-transferable licence to use the course materials for your own learning or internal business use.

You may not record, copy, publish, resell, sublicense or redistribute course materials, or use our name or logos, without our prior written permission.

1.5 Acceptable use

When using this website or our services, you must not:

  • break any law or infringe the rights of others;
  • send false, misleading or abusive requests through our forms;
  • attempt to access, scrape, overload or disrupt the website or its security measures;
  • reverse-engineer or copy any part of the website; or
  • share course access or materials with people who have not enrolled.

1.6 Third-party services and links

Our website may link to third-party websites or rely on third-party service providers. We are not responsible for the content, terms or privacy practices of third parties, and following such links is at your own risk.

1.7 Availability and changes to the service

We aim to keep the website available, but we do not guarantee uninterrupted or error-free access. We may change, suspend or withdraw any part of the website or a course, and we may update these terms as described in section 1.10.

1.8 Disclaimers and limitation of liability

Our courses are taught with reasonable skill and care, but they do not guarantee any specific business, career or financial result. The website and its content are provided on an “as is” basis to the extent permitted by law.

To the maximum extent permitted by law, we are not liable for indirect or consequential losses, loss of profit, data or goodwill. Our total liability arising out of or relating to a course is limited to the amount you paid us for that course. Nothing in these terms excludes or limits any liability that cannot be excluded or limited under applicable law, including your mandatory consumer rights.

1.9 Governing law and jurisdiction

These terms are governed by the laws of India. Subject to any mandatory consumer protections, the courts at Puducherry, India have exclusive jurisdiction over any dispute arising from these terms or our services.

1.10 Changes to these terms

We may update these terms from time to time. The version published on this page, with the “Last updated” date above, is the current version. Continued use of the website after a change means you accept the updated terms.

2. Privacy Policy

This policy explains what personal data we collect through the SPENGTRA website, why we collect it, how we protect it, and the rights you have. It applies when you browse the website or send us an enrollment or contact request.

2.1 Who is responsible for your data

Fractal-Apps Pvt Ltd is the organisation responsible for the personal data described in this policy. Under the GDPR we act as the controller; under India’s Digital Personal Data Protection Act, 2023 we act as the Data Fiduciary. Contact details are in the Contact & Grievance Officer section.

2.2 What we collect

Information you give us. When you submit the enrollment or contact form, we collect your name, email address, an optional phone number, the course you are interested in, and the content of your message.

Technical and security data. To protect the forms, our server processes your IP address and request timestamps to apply rate limits and issue a one-time security challenge. This data is held in server memory only and is not used to identify or profile you. It is discarded after about ten minutes.

Payment information. If you pay for a course, your payment is handled by Razorpay. We do not store your full card, UPI or bank-account details; we receive only limited transaction information such as the payment status, amount and a transaction reference.

Analytics data. We use Google Analytics to understand how visitors use the website. Google Analytics may collect online identifiers (including a cookie or similar identifier), your device and browser type, the pages you view, and approximate location derived from your IP address. We do not use it to identify you by name.

We do not create user accounts on this website and we do not knowingly collect sensitive personal data or the personal data of children.

2.3 Why we use your data

We use your data only for the purposes below, each with a lawful basis recognised by the GDPR and by Indian law:

Purposes for processing personal data, the data used and the corresponding legal basis
PurposeData usedLegal basis
Answering your enrollment or contact requestName, email, optional phone, course of interest, messageYour consent; steps taken at your request before a contract
Delivering a course you booked and supporting youName, email, optional phone, messagePerformance of our contract with you
Taking payment for a courseName, email, contact details and transaction data (processed by Razorpay)Performance of our contract with you; our legitimate interest in preventing fraud
Preventing spam and abuse of the formsIP address and request timestamps (held in memory, transient)Our legitimate interest in keeping the service secure
Understanding how the website is usedOnline identifiers, device and browser data, pages viewed, approximate location (Google Analytics)Your consent where required (EU/EEA/UK); otherwise our legitimate interest in improving the website
Meeting accounting, tax and legal obligationsName, email, course and payment records where applicableCompliance with a legal obligation

We do not use your data for automated decision-making or profiling, and we do not sell your personal data.

2.4 Cookies and tracking

We use Google Analytics to measure how the website is used. Google Analytics sets cookies or similar identifiers that help us count visits and understand which pages are useful. Our fonts are self-hosted, so no data is sent to external font services.

When you go through Razorpay’s checkout, Razorpay may set its own cookies or identifiers as necessary to process your payment securely. Those are governed by Razorpay’s privacy policy.

Where the law requires it (for example in the EU/EEA or the UK), we ask for your consent before setting non-essential analytics cookies, and you can refuse or withdraw that consent at any time. You can also block or delete cookies through your browser settings, and Google provides a Google Analytics opt-out browser add-on. Blocking analytics cookies does not affect your ability to browse the site or contact us.

2.5 Who we share it with

We keep your data inside our organisation except where we use trusted service providers to operate the website. These providers process data on our instructions and under confidentiality obligations, and include:

  • email-delivery providers (for example Resend, an SMTP provider, or Google Gmail) that carry your request to our inbox;
  • Razorpay, which processes course payments on our behalf;
  • Google, which provides Google Analytics and processes usage data as described in section 2.4;
  • our website hosting provider, which stores the site and processes technical data; and
  • professional advisers or authorities where we are legally required to disclose information, or where it is necessary to establish, exercise or defend legal claims.

We do not sell, rent or trade your personal data. If our business is ever transferred or reorganised, data may be transferred as part of that transaction, subject to this policy.

2.6 International transfers

Some of our service providers, including Google and Razorpay, may store or process data outside India or the EU/EEA. Where that happens, we take steps required by law to protect your data, such as relying on an adequacy decision or putting appropriate safeguards (for example, standard contractual clauses) in place.

2.7 How long we keep it

We keep request data only as long as needed to answer you and to maintain legitimate business and legal records, after which we delete or anonymise it. Security and rate-limit data is held in memory for about ten minutes. If you ask us to delete your data, we will do so unless we are legally required to keep it.

2.8 How we protect it

We use appropriate technical and organisational measures, including encrypted connections (HTTPS/TLS), server-side validation, a honeypot and rate limiting, and we avoid writing personal data into application logs. No method of transmission or storage is completely secure; if you believe your data has been compromised, please contact us.

2.9 Children

Our services are intended for adults. We do not knowingly collect personal data from anyone under 18. If you believe a child has sent us personal data, contact us and we will delete it promptly.

2.10 Changes to this policy

We may update this policy to reflect changes in our practices or in the law. The current version is always on this page, with the “Last updated” date shown at the top.

3. Your rights under the GDPR (RGPD)

If you are in the European Union, the EEA, the United Kingdom or Switzerland, the General Data Protection Regulation (GDPR / RGPD) gives you the rights below. We will handle your request within the time limits set by law, normally within one month. We may ask you to confirm your identity before acting.

  • Access. Get a copy of the personal data we hold about you.
  • Rectification. Have inaccurate or incomplete data corrected.
  • Erasure. Ask us to delete your data where there is no good reason for us to keep it.
  • Restriction. Ask us to limit how we use your data.
  • Objection. Object to processing based on our legitimate interests.
  • Portability. Receive your data in a structured, machine-readable format or have it sent to another controller.
  • Withdraw consent. Withdraw consent at any time where processing is based on consent, without affecting processing already carried out.
  • Complain. Lodge a complaint with your local supervisory authority.

We process your data on the bases set out in section 2.3. Where we rely on legitimate interests, we balance those interests against your rights and expectations. You can exercise any of these rights by contacting us using the details below.

Where we rely on your consent, for example for analytics cookies, you can withdraw it at any time using the cookie controls described in section 2.4 or by contacting us. You also have the right to object to processing based on our legitimate interests.

4. Your rights in India

We are based in Pondicherry and handle personal data in line with India’s Digital Personal Data Protection Act, 2023 (the DPDP Act), the Information Technology Act, 2000 and the rules made under it. As the Data Fiduciary, we process your personal data only for the lawful purposes described in this policy and on the basis of your consent or another lawful ground.

4.1 Consent and notice

By submitting the enrollment or contact form after reading this policy, you give your consent to the processing described here. Where we ask for consent to analytics cookies, you may refuse or withdraw it at any time as described in section 2.4. You may withdraw any consent by contacting us; this will not affect processing carried out before you withdrew it.

4.2 Your rights as a Data Principal

  • Right to access information. Ask for a summary of the personal data we process and the identities of the parties with whom we share it.
  • Right to correction and erasure. Ask us to correct inaccurate data or erase data that is no longer needed, unless we must keep it by law.
  • Right to grievance redressal. Raise a concern with our Grievance Officer, who will respond as required by law.
  • Right to nominate. Nominate another person to exercise your rights in the event of your death or incapacity.

4.3 Grievance Officer

In accordance with Indian law, we have appointed a Grievance Officer to handle data-protection and website grievances:

We aim to acknowledge your complaint promptly and to resolve it within 30 days.

4.4 Data Protection Board of India

If you are not satisfied with our response, you have the right to complain to the Data Protection Board of India, in the manner provided by the DPDP Act.

4.5 Security and cross-border processing

We follow reasonable security practices and procedures to protect personal data. Data may be processed outside India by the service providers listed in section 2.5, subject to the conditions and safeguards required by the DPDP Act and other applicable law.

4.6 Children

We do not process the personal data of children. Our courses and website are intended for adults aged 18 and over. If we ever need to process a child’s data, we will do so only with verifiable parental consent as required by the DPDP Act.