Privacy Policy

PART I PRELIMINARY PROVISIONS

1. Introduction

Welcome to ConsulTOpen.

ConsulTOpen recognises that privacy is fundamental to the trust placed in our Platform by Students, Parents, Counsellors, educational institutions and every other User.

Accordingly, ConsulTOpen is committed to processing Personal Data responsibly, transparently and in accordance with applicable law.

This Privacy Policy explains the manner in which ConsulTOpen collects, stores, analyses, processes, uses, shares, retains, protects and deletes Personal Data throughout the lifecycle of the User’s relationship with the Platform.

The Platform has been designed to continuously evolve.

Accordingly, this Privacy Policy applies not only to the Platform as it presently exists but also to future websites, mobile applications, dashboards, APIs, enterprise solutions, educational partnerships, corporate wellness services, Artificial Intelligence products and other digital services reasonably connected with ConsulTOpen.

Nothing contained within this Privacy Policy shall be interpreted as limiting ConsulTOpen’s ability to responsibly innovate while continuing to comply with applicable privacy laws.

2. Scope of This Privacy Policy

This Privacy Policy governs every interaction between ConsulTOpen and every User relating to Personal Data.

Without limitation, it applies whenever a User:

• visits the Website;
• creates an account;
• applies as a Counsellor;
• books consultations;
• provides consultations;
• uploads documents;
• communicates through the Platform;
• submits mood logs;
• interacts with AI tools;
• receives career recommendations;
• uploads resumes;
• receives ATS analysis;
• uses internship recommendations;
• accesses placement preparation resources;
• receives certification recommendations;
• participates in future Platform features;
• contacts customer support;
• otherwise interacts with ConsulTOpen.

This Privacy Policy applies irrespective of whether the User completes registration or merely browses publicly accessible portions of the Platform.

3. Definitions

Unless the context requires otherwise, capitalised expressions shall have the meanings assigned below.

“Personal Data” means any information relating to an identified or identifiable natural person.

“Sensitive Personal Information” refers to categories of information requiring enhanced protection under applicable law or Platform practices.

“Processing” includes collection, recording, organisation, storage, adaptation, retrieval, consultation, use, disclosure, transmission, analysis, combination, restriction, deletion and destruction of Personal Data.

“Data Fiduciary” means ConsulTOpen acting in accordance with applicable law.

“Data Principal” means the individual to whom the Personal Data relates.

“Consent” means a free, specific, informed, unconditional and unambiguous indication of the Data Principal’s agreement for the processing of Personal Data.

Unless otherwise defined herein, all defined terms shall carry the same meaning assigned to them in the ConsulTOpen Terms & Conditions.

4. Applicability

This Privacy Policy applies to:

• Students;
• Parents and Guardians;
• Counsellors;
• Institutions;
• Universities;
• Schools;
• Corporate Users;
• Enterprise Users;
• Website Visitors;
• Mobile Application Users;
• API Users;
• Future categories of Users introduced by ConsulTOpen.

5. Relationship with Other Policies

This Privacy Policy forms an integral part of the overall legal framework governing the ConsulTOpen Platform.

It shall be read together with:

• Terms & Conditions;
• Refund Policy;
• Cancellation & Rescheduling Policy;
• Settlement & Payout Policy;
• Missed Session & No-Show Policy;
• Consultant Agreement;
• Cookie Policy;
• AI Policy;
• Community Guidelines;
• every future Platform Policy.

Where any inconsistency exists, applicable law shall prevail, followed by the Terms & Conditions, followed by this Privacy Policy, except where a subject-specific policy expressly governs the relevant issue.

6. Changes to This Privacy Policy

ConsulTOpen reserves the unrestricted right to amend, update, replace, supplement or discontinue this Privacy Policy at any time, subject to applicable law.

Material changes may be communicated through:

• Website notices;
• Dashboard notifications;
• Email;
• SMS;
• WhatsApp;
• Push notifications;
• other electronic communication channels.

Continued use of the Platform after the effective date of revised provisions constitutes acceptance of the updated Privacy Policy where permitted by applicable law.

7. Electronic Acceptance

This Privacy Policy constitutes an electronic legal record.

Acceptance may occur by:

• clicking “I Agree”;
• creating an account;
• logging into the Platform;
• booking consultations;
• applying as a Counsellor;
• uploading documents;
• using Artificial Intelligence features;
• making payments;
• continuing to use the Platform following publication of this Privacy Policy.

Electronic acceptance shall possess the same legal validity as a handwritten signature to the fullest extent permitted under applicable law.

8. Legal Basis for Processing

ConsulTOpen processes Personal Data only where permitted under applicable law.

Depending upon the circumstances, processing may occur for purposes including:

• obtaining and performing contractual obligations;
• complying with legal obligations;
• protecting Users;
• preventing fraud;
• securing the Platform;
• responding to emergencies;
• providing requested services;
• operating Artificial Intelligence features;
• improving Platform functionality;
• obtaining valid consent;
• complying with regulatory requirements;
• protecting the legitimate interests of ConsulTOpen where permitted by law.

9. Consent Framework

Where consent is required, ConsulTOpen shall obtain consent through appropriate electronic mechanisms before processing Personal Data.

Users may provide consent through:

• electronic acceptance;
• account registration;
• specific consent requests;
• recording consent mechanisms;
• parental consent mechanisms;
• future consent technologies introduced by ConsulTOpen.

Users may withdraw consent where permitted by applicable law.

Withdrawal of consent shall not affect processing lawfully undertaken before such withdrawal.

10. Categories of Users

This Privacy Policy presently applies to:

• Students;
• Parents and lawful Guardians;
• Independent Counsellors;
• Website Visitors;
• Educational Institutions;
• Universities;
• Schools;
• Corporate Organisations;
• Enterprise Customers;
• Strategic Partners;
• Future categories of Users introduced by ConsulTOpen.

Different categories of Users may be subject to additional privacy notices, supplementary agreements or institution-specific privacy provisions where appropriate.

PART II – PERSONAL DATA COLLECTION & PROCESSING

11. General Principles of Data Collection

11.1 Purpose-Driven Collection

ConsulTOpen collects only such Personal Data as is reasonably necessary for:

• operating the Platform;
• creating and maintaining User Accounts;
• facilitating consultation services;
• verifying Users;
• verifying Counsellors;
• improving educational guidance;
• improving career counselling;
• improving mental wellness support;
• personalising Platform experiences;
• operating Artificial Intelligence services;
• complying with applicable law;
• protecting Platform security;
• preventing fraud;
• conducting quality assurance;
• supporting future Platform functionality.

ConsulTOpen shall endeavour not to collect Personal Data unrelated to legitimate Platform purposes.

11.2 Voluntary Information

Certain Personal Data is voluntarily provided by Users.

Users acknowledge that voluntarily providing additional information may improve:

• AI recommendations;
• educational guidance;
• career planning;
• internship recommendations;
• certification recommendations;
• placement preparation;
• counsellor matching;
• overall Platform personalisation.

Users remain responsible for ensuring the accuracy of voluntarily submitted information.

11.3 Mandatory Information

Certain information is mandatory to enable Platform functionality.

Failure to provide mandatory information may prevent:

• account creation;
• booking confirmation;
• payment processing;
• consultation services;
• counsellor onboarding;
• settlement processing;
• identity verification;
• access to certain Platform features.

12. Categories of Personal Data Collected

Depending upon the nature of the User’s interaction with the Platform, ConsulTOpen may collect different categories of Personal Data.

Without limitation, Personal Data may include the categories described below.

13. Information Collected From Students

Depending upon Platform usage, ConsulTOpen may collect information including:

13.1 Identity Information

• Full Name
• Date of Birth
• Gender
• Profile Photograph
• Username
• User ID
• Parent or Guardian Information (where applicable)

13.2 Contact Information

• Mobile Number
• Email Address
• Communication Preferences
• Alternative Contact Information where voluntarily provided

13.3 Educational Information

Students may voluntarily or necessarily provide information including:

• Current Class
• Academic Year
• School Name
• College Name
• University Name
• Educational Board
• Degree Programme
• Branch
• Specialisation
• Current Semester
• Academic Performance
• Academic Interests
• Preferred Subjects
• Areas of Difficulty
• Learning Preferences
• Future Academic Plans

13.4 Career Information

To improve career guidance and AI recommendations, ConsulTOpen may collect:

• Career Goals
• Career Interests
• Professional Aspirations
• Preferred Industries
• Dream Companies
• Skills
• Certifications Completed
• Skills Intended to Learn
• Areas requiring improvement
• Long-term Professional Goals
• Short-term Professional Goals
• Personal Ambitions
• Educational Objectives

13.5 Internship Information

Users may voluntarily provide:

• Internship Interests
• Preferred Domains
• Preferred Cities
• Work Preferences
• Remote or On-site Preference
• Previous Internship Experience
• Internship Applications
• Internship Status
• Internship History

This information may be used for AI-assisted internship recommendations.

13.6 Placement Preparation Information

Where Users utilise Placement Preparation features, ConsulTOpen may process:

• Resume
• ATS Scores
• Resume Versions
• Interview Preparation Progress
• Mock Interview Results
• Coding Preparation Information
• Skill Assessment Results
• Placement Readiness
• Preferred Roles
• Preferred Salary Expectations
• Company Preferences

13.7 Certification Information

• Users may provide:
• Existing Certifications
• Desired Certifications
• Learning Interests
• Skill Development Preferences
• Professional Development Goals

This information may be used to recommend future certifications.

13.8 Platform Activity

ConsulTOpen may collect information regarding:

• Pages Visited
• Features Used
• Session Duration
• Login History
• Search Activity
• Bookings
• Session Attendance
• AI Usage
• Notification Preferences
• User Interactions

14. Mood Logs & Wellness Information

Students may voluntarily submit emotional wellbeing information including:

• Mood Logs
• Emotional Reflections
• Stress Indicators
• Wellness Journal Entries
• Daily Check-ins
• Self-reported Emotional Information

Such information is voluntarily provided.

Mood logs are intended to improve educational support, personalisation and consultation quality.

Mood logs:

• are not medical diagnoses;
• are not psychiatric evaluations;
• are not emergency intervention tools;
• do not replace professional healthcare.

Where AI-assisted insights are generated, such insights remain informational only.

15. Information Collected From Parents & Guardians

Where Students are Minors, ConsulTOpen may collect:

• Parent Name
• Guardian Name
• Relationship with Student
• Mobile Number
• Email Address
• Consent Records
• Verification Information
• Payment Information
• Communications relating to the Minor

Parents and Guardians may also communicate with Customer Support regarding the Student.

16. Information Collected From Counsellors

ConsulTOpen may collect extensive information from Counsellors during onboarding and throughout their relationship with the Platform.

16.1 Identity Information

Including but not limited to:

• Full Name
• Photograph
• Gender
• Date of Birth
• Signature
• Government-issued Identification

16.2 Contact Information

• Mobile Number
• Email Address
• Professional Contact Information
• Communication Preferences

16.3 Professional Information

Including:

• Professional Biography
• Profile Description
• Areas of Expertise
• Specialisations
• Languages Spoken
• Qualifications
• Professional Experience
• Professional Achievements
• Awards
• Publications
• Research Work
• Training Programmes
• Workshops Conducted

Professional biographies may be displayed to Students through the Platform.

16.4 Educational Qualifications

ConsulTOpen may collect:

• Degrees
• Diplomas
• Certificates
• University Information
• Educational Transcripts where required
• Professional Registrations
• Licence Information
• RCI Registration where applicable
• Future professional credentials

16.5 Verification Information

Including:

• PAN
• Bank Account Information
• Cancelled Cheque
• Government Identification
• Qualification Documents
• Experience Certificates
• Address Verification
• Live Verification where introduced
• Selfie Verification where introduced
• Additional verification documents reasonably required by ConsulTOpen

16.6 Financial Information

For settlement purposes, ConsulTOpen may collect:

• Bank Name
• Account Holder Name
• Account Number
• IFSC Code
• PAN
• GST Information where applicable
• Settlement Records
• Payment History
• Commission Records
• Tax Deductions
• Invoice Information

17. Information Collected From Website Visitors

Visitors who browse the Website without creating an account may still provide or generate information including:

• IP Address
• Browser Type
• Device Type
• Operating System
• Approximate Geographic Region
• Language Preference
• Referring Website
• Pages Visited
• Session Duration
• Clickstream Information
• Cookies
• Analytics Information

18. Information Generated During Consultations

During the course of consultations, ConsulTOpen may process information including:

• Booking Information
• Session Date
• Session Time
• Session Duration
• Session Status
• Consultation Category
• Session Metadata
• AI-generated Session Notes
• AI-generated Summaries
• Session Feedback
• Ratings
• Reviews
• Technical Logs

18.1 Audio Recordings

Where both the Student and Counsellor expressly consent, ConsulTOpen may create an audio recording of the consultation.

ConsulTOpen does not presently record video consultations.

Audio recordings may be processed solely for:

• generation of AI-assisted session notes;
• generation of AI-generated summaries;
• quality assurance where reasonably necessary;
• investigation of complaints;
• dispute resolution;
• legal compliance;
• fraud prevention.

Audio recordings shall ordinarily be deleted within the applicable retention period unless their continued retention is reasonably necessary for legal proceedings, dispute resolution or compliance with applicable law.

19. Information Generated Through Artificial

INTELLIGENCE ConsulTOpen may process information submitted to Artificial Intelligence features.

This may include:

• AI Chat Inputs
• Career Queries
• Educational Questions
• Resume Information
• ATS Reports
• Placement Preparation Data
• Internship Preferences
• Certification Preferences
• Mood Logs
• Counsellor Profile Information
• Educational Goals
• Career Aspirations
• Uploaded Documents
• Portfolio Information
• User Prompts
• AI Feedback

Such information is processed for the purpose of delivering requested AI-assisted functionality and improving the Platform, subject to applicable law.

20. Automatically Collected Information

ConsulTOpen may automatically collect technical information including:

• Device Identifiers
• Browser Information
• Operating System
• Network Information
• IP Address
• Login Time
• Logout Time
• Authentication Logs
• Device Tokens
• Session Identifiers
• Crash Reports
• Performance Metrics
• Security Logs
• Fraud Detection Signals
• API Logs
• Error Reports
• Diagnostic Information

Automatic collection assists in:

• Platform security;
• fraud prevention;
• system reliability;
• troubleshooting;
• analytics;
• performance optimisation;
• cybersecurity;
• compliance;
• continuous improvement.

21. Information Provided Through Customer Support

Users contacting Customer Support may provide:

• Name
• Contact Information
• Complaint Details
• Screenshots
• Documents
• Technical Information
• Communications
• Attachments
• Follow-up Information

Support interactions may be retained for quality assurance, training, dispute resolution and legal compliance.

22. Information Received From Third Parties

Where legally permissible, ConsulTOpen may receive limited information from authorised third parties including:

• Payment Confirmation from Razorpay;
• Authentication Providers;
• Educational Verification Services;
• Identity Verification Services;
• Banking Partners;
• Security Providers;
• Analytics Providers;
• Cloud Infrastructure Providers;
• Future service providers integrated with the Platform.

ConsulTOpen shall process such information only for legitimate Platform purposes and in accordance with applicable law.

23. Accuracy of Personal Data

Users are responsible for ensuring that all Personal Data submitted to ConsulTOpen is:

• accurate;
• complete;
• current;
• truthful; and
• not misleading.

Users should promptly update information whenever changes occur.

Knowingly providing false information may result in restriction, suspension or termination of Platform access in accordance with the Terms & Conditions.

24. Reserved Rights Relating to Data Collection

• ConsulTOpen reserves the right to introduce additional categories of Personal Data collection

in connection with future Platform features, provided that such collection complies with applicable law and Users are notified or consent is obtained where legally required.

Future categories may include data necessary for:

• Mobile Applications;
• Educational Institution Services;
• Corporate Wellness Programmes;
• Enterprise Services;
• Subscription Plans;
• International Operations;
• AI Innovations;
• Research Initiatives;
• Scholarship Programmes;
• Additional educational and professional services introduced by ConsulTOpen.

PART III – PURPOSE OF PROCESSING, ARTIFICIAL INTELLIGENCE & DATA

USAGE

25. Principles of Processing

25.1 Fair and Lawful Processing

ConsulTOpen processes Personal Data fairly, lawfully and transparently in accordance with applicable law.

Personal Data shall only be processed for legitimate Platform purposes and shall not be used in a manner incompatible with those purposes unless otherwise permitted by applicable law or valid consent has been obtained.

25.2 Purpose Limitation

Personal Data shall be processed only for purposes reasonably connected with the operation, improvement, security and future development of the ConsulTOpen Platform.

Where additional purposes arise, ConsulTOpen shall obtain consent or provide notice where required by applicable law.

25.3 Data Minimisation

ConsulTOpen shall endeavour to collect and process only such Personal Data as is reasonably necessary for the relevant processing activity.

Where possible, anonymised or aggregated information may be used instead of identifiable Personal Data.

25.4 Accuracy

ConsulTOpen shall take commercially reasonable measures to maintain accurate Personal Data.

Users are encouraged to promptly update inaccurate or outdated information through their Platform account.

25.5 Security

Personal Data shall be processed using commercially reasonable administrative, organisational and technical safeguards designed to protect confidentiality, integrity and availability.

26. Purposes for Which Personal Data Is Used

Depending upon the nature of the Platform and the User’s interaction with it, Personal Data may be processed for one or more of the following purposes.

26.1 Platform Operations

Including but not limited to:

• creating User Accounts;
• authenticating Users;
• enabling secure login;
• maintaining account security;
• managing User profiles;
• facilitating bookings;
• managing consultations;
• operating dashboards;
• enabling communications;
• delivering Platform features;
• maintaining system functionality.

26.2 Identity Verification

ConsulTOpen may process Personal Data for verification including:

• identity verification;
• educational verification;
• professional qualification verification;
• counsellor verification;
• licence verification;
• bank account verification;
• PAN verification;
• fraud prevention;
• ongoing compliance reviews.

Verification may occur before onboarding, periodically during Platform usage or whenever reasonably necessary.

26.3 Consultation Services

Personal Data may be processed for:

• matching Students with appropriate Counsellors;
• scheduling consultations;
• conducting consultations;
• generating booking confirmations;
• sending reminders;
• managing rescheduling;
• handling cancellations;
• facilitating post-session activities.

26.4 Payment Processing

Including:

• payment authorisation;
• payment verification;
• invoice generation;
• refund processing;
• settlement processing;
• commission calculation;
• tax deduction;
• accounting;
• financial reporting;
• regulatory compliance.

26.5 Customer Support

Information may be processed to:

• respond to enquiries;
• investigate complaints;
• resolve technical issues;
• verify account ownership;
• improve support quality;
• provide assistance;
• communicate with Users.

27. Personalisation of Platform Services

ConsulTOpen aims to deliver a personalised experience to every User.

Accordingly, Personal Data may be processed to personalise:

• homepage recommendations;
• counsellor suggestions;
• career guidance;
• educational resources;
• internship recommendations;
• certification recommendations;
• placement preparation resources;
• AI responses;
• dashboard experiences;
• notifications;
• learning resources;
• future Platform features.
• Personalisation is intended to improve the usefulness and relevance of Platform services.

28. Educational Guidance

Information relating to academic background, educational interests and career aspirations may be processed for purposes including:

• educational counselling;
• stream selection guidance;
• subject recommendations;
• higher education planning;
• university guidance;
• academic roadmaps;
• educational planning;
• scholarship recommendations;
• future educational services introduced by ConsulTOpen.

29. Career Guidance

Personal Data may be processed to provide career-related services including:

• career planning;
• professional development;
• industry recommendations;
• skill gap identification;
• role suitability;
• career pathways;
• long-term planning;
• short-term planning;
• professional growth suggestions.

30. Internship Recommendations

ConsulTOpen may process Personal Data to recommend internship opportunities.

Recommendation factors may include:

• educational background;
• current skills;
• career goals;
• preferred industries;
• preferred locations;
• academic level;
• certification history;
• internship interests;
• previous internships;
• resume quality.

Internship recommendations are intended solely as informational assistance and do not constitute guarantees of employment or internship placement.

31. Certification Recommendations

The Platform may recommend certifications based upon:

• educational profile;
• existing skills;
• career ambitions;
• professional goals;
• industry trends;
• placement preparation;
• AI analysis;
• User preferences.

Recommendations remain informational only.

Users remain responsible for independently evaluating any suggested certification.

32. Resume Review & Ats Analysis

ConsulTOpen may process uploaded resumes for purposes including:

• resume analysis;
• ATS compatibility scoring;
• formatting suggestions;
• keyword recommendations;
• resume improvement;
• AI-assisted optimisation;
• career guidance.

Resume analysis is intended solely for educational and professional development.

Users remain solely responsible for the final version of any resume submitted to employers.

33. Placement Preparation

Personal Data may be processed to personalise placement preparation resources including:

• interview preparation;
• aptitude resources;
• technical preparation;
• communication skills;
• resume development;
• company-specific preparation;
• role-specific preparation;
• placement readiness analysis.

Artificial Intelligence may recommend learning material based upon User profiles.

34. Artificial Intelligence

34.1 General

ConsulTOpen utilises Artificial Intelligence to enhance Platform functionality.

Artificial Intelligence supplements human expertise and does not replace professional judgement.

34.2 AI Features

Artificial Intelligence may presently or in future assist with:

• AI Chat;
• AI Career Guidance;
• AI Educational Assistance;
• AI Resume Review;
• ATS Analysis;
• AI Session Notes;
• AI Session Summaries;
• AI Career Roadmaps;
• Internship Recommendations;
• Certification Recommendations;
• Placement Preparation;
• Counsellor Portfolio Generation;
• AI Productivity Tools;
• AI Recommendation Engines;
• AI Learning Assistance;
• Future AI services.

34.3 AI Inputs

Artificial Intelligence may process information including:

• questions submitted by Users;
• resumes;
• uploaded documents;
• educational information;
• career preferences;
• placement preparation information;
• certification interests;
• internship preferences;
• consultation information;
• mood logs;
• profile information.

34.4 AI Outputs

Artificial Intelligence may generate:

• recommendations;
• summaries;
• suggestions;
• reports;
• educational content;
• resume feedback;
• ATS scores;
• learning pathways;
• internship suggestions;
• certification suggestions;
• portfolio content;
• placement resources.

AI-generated outputs are intended solely as decision-support tools.

34.5 Human Oversight

Significant Platform decisions shall not rely exclusively upon Artificial Intelligence.

• Human review may be involved in:
• counsellor onboarding;
• account suspension;
• enforcement actions;
• verification outcomes;
• complaint investigations;
• dispute resolution;
• moderation decisions.

34.6 AI Limitations

Users acknowledge that Artificial Intelligence:

• may generate inaccurate information;
• may misunderstand context;
• may provide incomplete responses;
• may require correction;
• may not reflect recent developments;
• should not replace independent judgement.

Users should independently verify important information before relying upon AI-generated outputs.

35. Mood Logs & Wellness Processing

Mood logs voluntarily submitted by Students may be processed for:

• consultation preparation;
• educational support;
• AI-generated insights;
• wellbeing tracking;
• personalised recommendations;
• Platform improvement.

Mood logs are not intended to diagnose, treat or prevent medical or psychological conditions.

ConsulTOpen does not provide emergency healthcare services through mood tracking functionality.

36. Audio Recordings

Where both participants expressly consent, audio recordings may be processed for:

• AI-generated session notes;
• AI-generated summaries;
• dispute resolution;
• complaint investigations;
• service quality review;
• fraud prevention;
• legal compliance.

Audio recordings shall not be used for unrelated commercial purposes.

At the Effective Date, ConsulTOpen does not record video consultations.

37. Research, Analytics & Improvement

ConsulTOpen may process Personal Data to:

• understand Platform usage;
• improve user experience;
• evaluate Platform performance;
• improve Artificial Intelligence;
• improve educational services;
• improve career recommendations;
• improve security;
• identify technical issues;
• conduct quality assurance.

Where reasonably practicable, anonymised or aggregated information may be used.

38. Fraud Prevention & Security

Personal Data may be processed to:

• detect fraud;
• prevent identity theft;
• identify suspicious activity;
• prevent payment fraud;
• prevent unauthorised access;
• protect Platform infrastructure;
• investigate security incidents;
• enforce Platform policies;
• comply with legal obligations.

39. Legal & Regulatory Compliance

ConsulTOpen may process Personal Data where reasonably necessary to:

• comply with applicable law;
• comply with court orders;
• respond to lawful governmental requests;
• satisfy tax obligations;
• maintain statutory records;
• enforce contractual rights;
• establish, exercise or defend legal claims.

40. Communications

ConsulTOpen may use Personal Data to communicate with Users through:

• Email;
• SMS;
• WhatsApp;
• Push Notifications;
• In-App Notifications;
• Telephone Calls where appropriate;
• Dashboard Notifications;
• Future communication technologies.

Communications may include:

• booking confirmations;
• reminders;
• account notifications;
• verification requests;
• settlement updates;
• security alerts;
• policy updates;
• newsletters;
• educational content;
• promotional campaigns;
• internship opportunities;
• certification opportunities;
• placement preparation updates;
• AI feature announcements.

Where required by applicable law, Users may manage communication preferences.

Operational and legally required communications may continue notwithstanding certain marketing preference changes.

41. Business Development & Future Services

ConsulTOpen may process Personal Data to support future Platform development including:

• new educational services;
• mobile applications;
• AI innovations;
• institutional partnerships;
• university programmes;
• school programmes;
• corporate wellness services;
• enterprise solutions;
• APIs;
• subscription services;
• scholarship programmes;
• international expansion;
• future technology initiatives.

Such processing shall continue to remain subject to applicable law and this Privacy Policy.

42. Anonymised & Aggregated Information

ConsulTOpen may create anonymised or aggregated datasets from Personal Data.

Such datasets no longer identify individual Users and may be used for:

• research;
• analytics;
• reporting;
• product development;
• service improvement;
• Artificial Intelligence training and evaluation where legally permissible;
• educational research;
• statistical analysis.

Where information has been irreversibly anonymised, it may no longer constitute Personal Data under applicable law.

43. No Sale of Personal Data

ConsulTOpen does not sell Users’ Personal Data to third parties.

Any sharing of Personal Data shall occur only for legitimate business purposes, legal compliance, service delivery or other purposes described in this Privacy Policy and applicable law.

44. Future Processing Activities

As ConsulTOpen evolves, additional processing activities may become necessary.

Future processing shall remain subject to:

• applicable law;
• this Privacy Policy;
• additional notices where appropriate;
• User consent where legally required.

ConsulTOpen shall endeavour to maintain transparency regarding significant changes to Personal Data processing practices.

PART IV – COOKIES, SECURITY, THIRD-PARTY SERVICES & DATA

SHARING

45. Cookies & Similar Technologies

45.1 General

ConsulTOpen uses Cookies and similar technologies to improve the security, performance, reliability and functionality of the Platform.

Cookies are small text files stored on a User’s browser or device that enable the Platform to recognise returning Users, maintain sessions and improve the overall user experience.

The use of Cookies does not permit ConsulTOpen to access information unrelated to the Platform or the User’s device beyond what is reasonably necessary for Platform functionality.

45.2 Categories of Cookies

The Platform may utilise one or more categories of Cookies including:

Essential Cookies

Essential Cookies are necessary for the operation of the Platform.

Without limitation, they may be used for:

• User authentication;
• Login sessions;
• Account security;
• Fraud prevention;
• Session continuity;
• Secure navigation;
• Payment security;
• Platform stability.

The Platform may not function correctly if Essential Cookies are disabled.

Preference Cookies

Preference Cookies help personalise the User experience.

These may remember:

• Language preferences;
• Notification preferences;
• Dashboard settings;
• Display preferences;
• Recently viewed Counsellors;
• Accessibility settings;
• Future personalisation settings.

Analytics Cookies

Analytics Cookies help ConsulTOpen understand Platform usage.

Such information may include:

• Pages visited;
• Time spent on pages;
• User journeys;
• Feature usage;
• Navigation behaviour;
• Device types;
• Browser types;
• Error frequency;
• Platform performance.

Analytics information assists in improving Platform quality.

Performance Cookies

Performance Cookies may be used to:

• improve loading speed;
• optimise server performance;
• improve responsiveness;
• identify technical bottlenecks;
• improve user experience;
• monitor Platform availability.

45.3 Future Cookie Technologies

ConsulTOpen may introduce future technologies performing functions similar to Cookies, including browser storage, software development kits (SDKs), device identifiers or successor technologies.

Such technologies shall remain subject to this Privacy Policy and applicable law.

46. Analytics

ConsulTOpen may utilise analytics technologies to better understand how Users interact with the Platform.

Analytics may assist in:

• improving educational services;
• improving career guidance;
• improving mental wellness support;
• improving Artificial Intelligence;
• improving internship recommendations;
• improving certification recommendations;
• improving placement preparation;
• improving Platform performance;
• improving security;
• improving accessibility.

Analytics data may be processed in aggregated or anonymised form wherever reasonably practicable.

47. Authentication & Account Security

To protect Users and maintain Platform integrity, ConsulTOpen may implement multiple authentication mechanisms.

Authentication methods may include:

• Mobile OTP;
• Email OTP;
• Password Authentication;
• Google Sign-In;
• Apple Sign-In;
• Multi-Factor Authentication (MFA);
• Device Verification;
• Future authentication technologies introduced by ConsulTOpen.

ConsulTOpen reserves the right to require stronger authentication where suspicious activity is detected.

48. Device Information

The Platform may automatically collect technical information relating to User devices.

Such information may include:

• Device Type;
• Device Model;
• Operating System;
• Browser Version;
• Screen Resolution;
• Language Settings;
• Device Identifiers;
• Mobile Application Version;
• Diagnostic Information;
• Error Reports.

This information assists in ensuring compatibility, reliability and Platform security.

49. Log Files

ConsulTOpen automatically generates technical logs relating to Platform activity.

Such logs may include:

• Login Time;
• Logout Time;
• Authentication Events;
• IP Addresses;
• Session Identifiers;
• Device Information;
• Browser Information;
• Security Events;
• Failed Login Attempts;
• Booking Activity;
• Payment Events;
• API Requests;
• Error Logs.

Log files assist in:

• fraud prevention;
• cybersecurity;
• dispute resolution;
• troubleshooting;
• legal compliance;
• audit requirements.

50. Payment Information

50.1 Payment Processing

Payments are presently processed through Razorpay or any future authorised payment processor selected by ConsulTOpen.

Payment processing may involve:

• payment authorisation;
• transaction verification;
• fraud detection;
• refund processing;
• settlement processing;
• reconciliation.

50.2 Payment Credentials

ConsulTOpen does not ordinarily store complete card information.

Payment credentials are generally processed directly by authorised payment processors in accordance with their own security standards and privacy practices.

50.3 Financial Records

ConsulTOpen may maintain records including:

• invoices;
• receipts;
• booking confirmations;
• payment confirmations;
• refund records;
• settlement statements;
• commission calculations;
• tax deductions;
• accounting records.

Such information may be retained where required by applicable law.

51. Cloud Infrastructure

ConsulTOpen presently utilises Amazon Web Services (AWS), or future cloud infrastructure providers, to support Platform operations.

Cloud infrastructure may be used for:

• application hosting;
• database hosting;
• secure storage;
• file management;
• backups;
• disaster recovery;
• scalability;
• cybersecurity;
• monitoring;
• infrastructure management.

ConsulTOpen endeavours to engage reputable infrastructure providers implementing industry-standard security practices.

52. Third-party Service Providers

To operate efficiently, ConsulTOpen may engage carefully selected third-party service providers.

Such providers may assist with:

• cloud infrastructure;
• payment processing;
• authentication;
• messaging;
• email delivery;
• SMS delivery;
• WhatsApp communication;
• Artificial Intelligence services;
• analytics;
• customer support;
• fraud prevention;
• cybersecurity;
• identity verification;
• future Platform services.
• Third-party providers shall receive only such information as is reasonably necessary for

providing their services.

53. Sharing of Personal Data

ConsulTOpen does not sell Personal Data.

Personal Data may, however, be shared where reasonably necessary for legitimate Platform purposes.

Sharing may occur with:

• authorised service providers;
• payment processors;
• cloud infrastructure providers;
• communication providers;
• verification partners;
• analytics providers;
• legal advisors;
• auditors;
• regulatory authorities;
• law enforcement agencies where legally required.

Sharing shall occur only in accordance with applicable law.

54. Information Shared Between Students & Counsellors

Certain information is intentionally shared to facilitate consultation services.

54.1 Information Visible to Counsellors

Depending upon Platform functionality, Counsellors may view:

• Student Name;
• Profile Photograph where provided;
• Educational Information;
• Career Goals;
• Academic Interests;
• Session History;
• Uploaded Documents;
• Resume where voluntarily shared;
• Mood Logs where voluntarily submitted and relevant to the consultation;
• Booking Information;
• Consultation Category.

Only information reasonably necessary for providing consultation services shall ordinarily be made available.

54.2 Information Visible to Students

Students may view Counsellor information including:

• Name;
• Photograph;
• Professional Biography;
• Qualifications;
• Areas of Expertise;
• Languages Spoken;
• Professional Experience;
• Ratings;
• Reviews;
• Certifications;
• Session Pricing;
• Availability;
• Profile Description.

ConsulTOpen may also generate AI-assisted portfolio content for Counsellors using information provided by the Counsellor.

55. Legal Disclosures

ConsulTOpen may disclose Personal Data where reasonably necessary to:

• comply with applicable law;
• comply with judicial orders;
• respond to lawful governmental requests;
• protect Users;
• protect Platform security;
• investigate fraud;
• prevent illegal activity;
• enforce Platform agreements;
• establish, exercise or defend legal rights.
• Such disclosures shall be limited to the extent reasonably necessary.

56. Business Transfers

In connection with:

• mergers;
• acquisitions;
• investments;
• restructuring;
• sale of assets;
• corporate reorganisation;
• financing transactions;
• strategic partnerships;
• business succession,

Personal Data may be transferred as part of the relevant transaction, subject to applicable law and appropriate safeguards.

The successor entity shall remain bound by obligations substantially consistent with this Privacy Policy unless Users are otherwise notified in accordance with applicable law.

57. International Data Processing

ConsulTOpen primarily intends to process and store Personal Data using infrastructure located in India wherever reasonably practicable.

However, certain authorised service providers, including Artificial Intelligence providers or future technology partners, may process limited Personal Data outside India where necessary to provide requested Platform functionality.

Where cross-border processing occurs, ConsulTOpen shall endeavour to ensure that appropriate contractual, technical and organisational safeguards are implemented and that such processing remains consistent with applicable Indian law.

Nothing in this section shall permit transfers prohibited by applicable law.

58. Security Measures

• ConsulTOpen implements commercially reasonable administrative, technical and

organisational safeguards designed to protect Personal Data.

Security measures may include:

• encryption in transit;
• encryption at rest where appropriate;
• access controls;
• role-based permissions;
• authentication controls;
• multi-factor authentication;
• secure infrastructure;
• network monitoring;
• intrusion detection;
• malware protection;
• vulnerability assessments;
• security audits;
• disaster recovery planning;
• backup systems;
• cybersecurity monitoring;
• security awareness programmes.

Security measures may evolve as technology develops.

59. Access Controls

Access to Personal Data shall be limited to authorised personnel who require such access for legitimate business purposes.

Access may be controlled through:

• role-based permissions;
• least-privilege principles;
• authentication mechanisms;
• audit logs;
• periodic access reviews;
• security monitoring.

Unauthorised access to Personal Data is strictly prohibited.

60. Data Breach Response

In the event of an actual or suspected Personal Data breach, ConsulTOpen may:

• investigate the incident;
• contain the breach;
• preserve evidence;
• assess affected systems;
• notify relevant internal stakeholders;
• notify affected Users where required by applicable law;
• notify competent regulatory authorities where legally required;
• implement remedial measures;
• improve security controls to reduce the likelihood of recurrence.

ConsulTOpen shall endeavour to respond to security incidents promptly and responsibly.

61. Cybersecurity

ConsulTOpen continuously works to improve Platform security.

Cybersecurity initiatives may include:

• penetration testing;
• vulnerability assessments;
• threat intelligence;
• security monitoring;
• incident response planning;
• infrastructure hardening;
• continuous updates;
• risk assessments;
• employee awareness programmes.

No internet-connected system can guarantee absolute security.

Users also play an important role in maintaining security by safeguarding passwords, OTPs and authentication credentials.

62. User Responsibilities

Users are responsible for:

• maintaining password confidentiality;
• protecting OTPs;
• securing personal devices;
• logging out from shared devices;
• promptly reporting suspected unauthorised access;
• ensuring uploaded files are lawful;
• maintaining accurate account information.
• Failure to adopt reasonable security practices may increase security risks beyond the

reasonable control of ConsulTOpen.

63. Future Security Technologies

ConsulTOpen reserves the right to introduce future security technologies including:

• biometric authentication where legally permissible;
• behavioural authentication;
• device fingerprinting;
• risk-based authentication;
• advanced fraud detection;
• Artificial Intelligence-assisted cybersecurity;
• zero-trust security architectures;
• future authentication technologies.

Such technologies shall be implemented in accordance with applicable law and this Privacy Policy.

64. Reservation of Rights

Nothing contained within this Part IV shall limit ConsulTOpen’s ability to:

• improve security;
• replace service providers;
• enhance cybersecurity;
• adopt new technologies;
• improve authentication;
• improve fraud prevention;
• strengthen infrastructure;
• modify technical architecture,

provided that such changes remain consistent with applicable law and this Privacy Policy.

PART V – DATA RETENTION, USER RIGHTS, CHILDREN’S PRIVACY &

ACCOUNT DELETION

65. Data Retention Principles

65.1 General Principle

ConsulTOpen retains Personal Data only for as long as reasonably necessary to:

• provide Platform Services;
• fulfil contractual obligations;
• comply with applicable law;
• resolve disputes;
• enforce Platform Policies;
• maintain financial records;
• prevent fraud;
• maintain Platform security;
• improve Platform functionality.

After expiry of the applicable retention period, Personal Data shall ordinarily be deleted, anonymised or securely destroyed unless further retention is required by applicable law.

65.2 Factors Considered

When determining retention periods, ConsulTOpen may consider:

• legal obligations;
• contractual obligations;
• operational requirements;
• security considerations;
• fraud prevention;
• dispute resolution;
• ongoing investigations;
• regulatory requirements;
• User requests;
• technological limitations.

66. Retention of Student Data

Student Personal Data may be retained while:

• the account remains active;
• consultations remain ongoing;
• refunds remain pending;
• disputes remain unresolved;
• legal obligations continue.

Where a Student Account is deleted, Personal Data shall ordinarily be deleted within ninety (90) days following account deactivation, subject to legal retention obligations.

67. Retention of Counsellor Data

Counsellor Personal Data may be retained during:

• onboarding;
• active Platform participation;
• settlement processing;
• tax compliance;
• dispute resolution;
• verification activities.

Following account deletion or termination, Counsellor Personal Data shall ordinarily be deleted within ninety (90) days, except where continued retention is reasonably necessary for legal, accounting, tax or regulatory purposes.

68. Audio Recordings

Where audio recordings are created with the consent of both participants, they may be retained only for purposes including:

• AI-generated session notes;
• AI-generated summaries;
• dispute resolution;
• complaint investigations;
• quality assurance;
• legal compliance.
• Unless required for an ongoing investigation, legal proceeding or regulatory obligation, audio

recordings shall ordinarily be deleted within ninety (90) days.

ConsulTOpen does not presently retain video recordings because video consultations are not recorded.

69. Financial Records

Certain financial records may be retained beyond general retention periods where required by applicable law.

Such records may include:

• invoices;
• payment confirmations;
• settlement statements;
• commission records;
• refund records;
• tax records;
• accounting records;
• audit records.

Deletion of a User Account does not automatically require deletion of financial records.

70. Security Logs

Security-related information including:

• login history;
• authentication logs;
• device logs;
• fraud detection records;
• cybersecurity events;
• audit trails;

may be retained for longer periods where reasonably necessary to protect Platform security or comply with legal obligations.

71. Backups

• Personal Data may temporarily remain within encrypted backup systems after deletion from

active systems.

Backup information shall ordinarily be overwritten or securely deleted during normal backup lifecycle management unless continued retention is legally required.

72. Account Deletion

72.1 User Requests

Users may request deletion of their accounts through authorised Platform functionality or by contacting ConsulTOpen.

Identity verification may be required before processing deletion requests.

72.2 Immediate Deactivation

Upon successful verification of the deletion request:

• Platform access shall ordinarily be suspended;
• future bookings may be cancelled;
• active sessions may be concluded where appropriate;
• the account shall be immediately deactivated.

72.3 Deletion Timeline

Following deactivation, Personal Data shall ordinarily be permanently deleted or anonymised within ninety (90) days unless continued retention is required by:

• applicable law;
• court orders;
• dispute resolution;
• fraud investigations;
• taxation;
• accounting obligations;
• security investigations.

72.4 Information Not Immediately Deleted

• Certain categories of information may continue to be retained including:
• invoices;
• settlement records;
• audit records;
• tax documentation;
• legal correspondence;
• dispute records;
• fraud investigation records;
• anonymised analytics.

Retention shall occur only to the extent reasonably necessary.

73. User Rights

Subject to applicable law, Users may exercise various rights relating to their Personal Data.

73.1 Right to Access

Users may request information regarding:

• categories of Personal Data processed;
• purposes of processing;
• categories of recipients;
• retention practices;
• rights available under applicable law.

73.2 Right to Correction

Users may request correction of inaccurate, incomplete or outdated Personal Data.

ConsulTOpen may request supporting documentation before implementing requested corrections.

73.3 Right to Deletion

Users may request deletion of Personal Data, subject to:

• legal obligations;
• contractual obligations;
• dispute resolution;
• fraud prevention;
• regulatory compliance.

73.4 Right to Withdraw Consent

Where processing is based upon consent, Users may withdraw consent at any time.

Withdrawal of consent shall not affect processing lawfully undertaken prior to withdrawal.

Withdrawal may limit access to certain Platform features where Personal Data is necessary for service delivery.

73.5 Right to Grievance Redressal

Users may submit privacy-related grievances to the designated Grievance Officer.

ConsulTOpen shall endeavour to acknowledge privacy grievances within forty-eight (48) hours and resolve them within thirty (30) days wherever reasonably practicable, subject to applicable law.

73.6 Right to Nominate

Where applicable law provides such right, Users may nominate another individual to exercise certain privacy-related rights on their behalf in circumstances recognised under applicable law.

74. Children’s Privacy

74.1 Minimum Age

Students must be at least thirteen (13) years of age to create an account.

74.2 Users Below Eighteen Years

• Individuals below eighteen (18) years of age shall be considered Minors for purposes of the

Platform.

Minor Users may use the Platform only after valid consent has been obtained from their Parent or lawful Guardian.

74.3 Parent or Guardian Consent

Parents or Guardians represent and warrant that:

• they possess lawful authority to provide consent;
• information provided is accurate;
• they understand this Privacy Policy;
• they consent to the processing of the Minor’s Personal Data in accordance with this
• Privacy Policy.

74.4 Rights of Parents & Guardians

Subject to applicable law, Parents or Guardians may:

• provide consent;
• withdraw consent where permitted;
• request correction of information;
• request deletion of the Minor’s Personal Data;
• communicate with Customer Support regarding the Minor’s account.

74.5 Protection of Minor Users

ConsulTOpen recognises the heightened importance of protecting the privacy of Minor Users.

Accordingly, ConsulTOpen shall endeavour to implement appropriate safeguards for the protection of Personal Data relating to Minors in accordance with applicable law.

75. Data of Deceased Users

Where permitted by applicable law, authorised nominees or lawful representatives may exercise applicable privacy rights relating to deceased Users.

• ConsulTOpen may require reasonable documentary evidence before acting upon such

requests.

76. Withdrawal of Consent

Withdrawal of consent shall not:

• invalidate lawful processing undertaken before withdrawal;
• require deletion of information required by law;
• prevent ConsulTOpen from complying with legal obligations;
• affect ongoing legal proceedings.

Certain Platform features may become unavailable following withdrawal of consent.

77. Restriction of Processing

Where recognised by applicable law, ConsulTOpen may temporarily restrict processing of Personal Data while:

• identity is verified;
• disputes are investigated;
• correction requests are evaluated;
• legal obligations are assessed.

78. Complaints

Users dissatisfied with ConsulTOpen’s handling of Personal Data may submit complaints through the grievance mechanism provided in this Privacy Policy.

Nothing in this Privacy Policy limits any statutory rights available under applicable law.

79. Data Portability

Where applicable law requires or permits, ConsulTOpen may provide Users with reasonable access to Personal Data in a structured format, subject to:

• technical feasibility;
• protection of third-party rights;
• legal obligations;
• Platform security.

80. Anonymisation

Where Personal Data is no longer required in identifiable form, ConsulTOpen may:

• anonymise information;
• aggregate information;
• remove identifying elements.

Anonymised information may continue to be used for:

• research;
• analytics;
• Artificial Intelligence improvement;
• statistical reporting;
• educational insights;
• Platform development.

Such information no longer identifies individual Users.

81. Reservation of Rights

Nothing contained within this Part V shall limit ConsulTOpen’s ability to retain, process or disclose Personal Data where required or permitted by:

• applicable law;
• judicial orders;
• regulatory requirements;
• fraud investigations;
• cybersecurity obligations;
• dispute resolution;
• contractual enforcement.

ConsulTOpen shall continue to process Personal Data responsibly and proportionately while balancing User privacy, legal obligations and Platform security.

PART VI – GRIEVANCE REDRESSAL, COMPLIANCE, FUTURE PRIVACY

PRACTICES & FINAL PROVISIONS

82. Privacy Governance

82.1 Commitment to Privacy

ConsulTOpen recognises that privacy forms an essential component of the trust placed in the Platform by Students, Parents, Counsellors, Institutions and every other User.

Accordingly, ConsulTOpen is committed to maintaining responsible governance over the collection, storage, processing, use, disclosure, retention and deletion of Personal Data throughout the lifecycle of every User relationship.

82.2 Privacy by Design

ConsulTOpen endeavours to adopt privacy-conscious practices throughout the design, development, deployment and operation of its Platform.

Where reasonably practicable, privacy considerations may be incorporated into:

• software development;
• Artificial Intelligence systems;
• Platform architecture;
• security controls;
• authentication systems;
• business processes;
• future technologies.

82.3 Continuous Improvement

Privacy practices may evolve in response to:

• technological developments;
• legal changes;
• cybersecurity risks;
• Platform expansion;
• User feedback;
• regulatory guidance;
• industry best practices.

83. Grievance Redressal

83.1 Grievance Officer

For questions, concerns or complaints relating to Personal Data, Users may contact:

Grievance Officer Abhinav Saini

Email: abhinav@consultopen.com

Support Email: support@consultopen.com

Contact Number: +91 9717972908

83.2 Privacy Complaints

Users may submit complaints relating to:

• collection of Personal Data;
• processing activities;
• account deletion;
• correction requests;
• consent;
• withdrawals of consent;
• security concerns;
• unauthorised access;
• Artificial Intelligence processing;
• Platform communications;
• any other privacy-related concern.

83.3 Acknowledgement

ConsulTOpen shall endeavour to acknowledge privacy complaints within forty-eight (48) hours of receipt wherever reasonably practicable.

83.4 Resolution

ConsulTOpen shall endeavour to investigate and respond to privacy complaints within thirty (30) days or within such other period as may be prescribed by applicable law.

Certain complex matters requiring investigation may require additional time.

83.5 Additional Information

ConsulTOpen may request additional information where reasonably necessary to:

• verify identity;
• investigate complaints;
• protect User privacy;
• prevent fraud;
• comply with legal obligations.

84. Compliance with Applicable Law

ConsulTOpen intends to process Personal Data in accordance with applicable laws governing privacy, electronic records, cybersecurity and digital services.

Where applicable, this Privacy Policy shall be interpreted consistently with:

• the Digital Personal Data Protection Act, 2023;
• the Information Technology Act, 2000;
• rules, regulations and notifications issued thereunder;
• judicial decisions;
• applicable governmental directions.

Nothing contained herein limits any rights available to Users under applicable law.

85. Future Privacy Practices

ConsulTOpen is designed as a continuously evolving technology platform.

Accordingly, future services may include:

• Android Applications;
• iOS Applications;
• Desktop Applications;
• Progressive Web Applications;
• APIs;
• Educational Institution Portals;
• University Dashboards;
• School Dashboards;
• Corporate Wellness Programmes;
• Enterprise Solutions;
• Subscription Services;
• Premium Memberships;
• Artificial Intelligence Products;
• Educational Research Tools;
• Scholarship Platforms;
• Internship Marketplaces;
• International Services;
• Additional educational technologies.

Personal Data processed through future services shall remain subject to this Privacy Policy unless superseded by a more specific privacy notice.

86. Business Changes

In connection with future business expansion, ConsulTOpen may undergo:

• investment;
• acquisition;
• merger;
• restructuring;
• business transfer;
• strategic partnership;
• corporate reorganisation.

Where Personal Data forms part of such transactions, ConsulTOpen shall endeavour to ensure appropriate safeguards consistent with applicable law.

87. Third-party Websites

The Platform may contain links to third-party websites, services or resources.

ConsulTOpen does not control the privacy practices of third-party websites.

Users should review the privacy policies of such third parties before providing Personal Data.

• ConsulTOpen shall not be responsible for the privacy practices of independent third parties.

88. No Waiver

Failure by ConsulTOpen to exercise any right available under this Privacy Policy shall not constitute:

• waiver;
• abandonment;
• estoppel;
• limitation of future enforcement.

89. Severability

If any provision of this Privacy Policy is held invalid, illegal or unenforceable by a court or competent authority, the remaining provisions shall continue in full force and effect.

The invalid provision shall, to the extent possible, be interpreted in a manner consistent with the original intent.

90. Assignment

ConsulTOpen may assign or transfer its rights and obligations under this Privacy Policy in connection with lawful business transactions, including mergers, acquisitions or restructuring.

Users may not assign rights or obligations under this Privacy Policy without prior written consent from ConsulTOpen.

91. Entire Privacy Framework

This Privacy Policy forms part of the comprehensive legal framework governing the ConsulTOpen Platform.

It shall be read together with:

• Terms & Conditions;
• Consultant Agreement;
• Refund Policy;
• Cancellation & Rescheduling Policy;
• Settlement & Payout Policy;
• Missed Session & No-Show Policy;
• Cookie Policy;
• AI Policy;
• Community Guidelines;
• every future Platform Policy.

Together these documents constitute the complete privacy and data protection framework of ConsulTOpen.

92. Interpretation

Unless the context requires otherwise:

• singular words include the plural and vice versa;
• references to one gender include every gender;
• references to legislation include amendments and successor legislation;
• references to writing include electronic records recognised by applicable law;
• headings are inserted solely for convenience and shall not affect interpretation;
• references to the Platform include all present and future versions of ConsulTOpen.

93. Reservation of Rights

Except where expressly limited by applicable law, every right, remedy, discretion and power not expressly granted to Users remains reserved to ConsulTOpen.

Without limitation, ConsulTOpen reserves the right to:

• improve Platform security;
• introduce new technologies;
• improve Artificial Intelligence;
• modify authentication methods;
• replace service providers;
• revise operational procedures;
• improve educational services;
• improve career guidance;
• improve mental wellness support;
• expand internationally;
• launch new products and services;
• improve compliance mechanisms.

94. Contact Information

For privacy-related matters, Users may contact:

ConsulTOpen

Registered Office:

House No. 20, First Floor

Khasra No. 630

Pahari Colony

Ghitorni Enclave

New Delhi – 110030

India

Website: https://consultopen.com

Support Email: support@consultopen.com

Legal Email: consultopen1@gmail.com

Privacy & Grievance Officer: Abhinav Saini

Privacy Email: abhinav@consultopen.com

Contact Number:

+91 9717972908

95. Effective Date

This Privacy Policy becomes effective on 25 June 2026 and shall remain effective until replaced by a subsequent version published by ConsulTOpen.

Continued use of the Platform after publication of an updated Privacy Policy constitutes acceptance of the revised Privacy Policy to the extent permitted by applicable law.

96. Final Declaration

• By accessing, browsing, registering with, booking through, providing services on or

otherwise using the ConsulTOpen Platform, every User acknowledges and agrees that:

• they have carefully read this Privacy Policy;
• they understand how ConsulTOpen processes Personal Data;
• they acknowledge their rights and responsibilities under this Privacy Policy;
• they understand that certain processing activities are necessary for the operation of the
• Platform;
• they consent to processing where consent is required by applicable law;
• they agree to remain bound by future revisions of this Privacy Policy upon continued
• use of the Platform, subject to applicable law.

ConsulTOpen appreciates the trust placed in it by its Users and remains committed to protecting Personal Data through responsible governance, robust security measures and continuous compliance with applicable law while building a secure, innovative and future- ready educational and counselling ecosystem.

• END OF PRIVACY POLICY
• Document Version: 1.0
• Platform: ConsulTOpen
• Effective Date: 25 June 2026
• Document Status: Official Privacy Policy