PRIVACY POLICY

Effective Date: 14 October 2026
Last Updated: 14 October 2026

1. Who We Are and What This Policy Covers

1.1 This Privacy Policy explains how VisionaryCue Informatics Private Limited (“VisionaryCue”, “we”, “us” or “our”) collects, uses, stores, discloses and otherwise processes Personal Data in connection with the following Websites:

https://visionarycue.org/

https://opm.visionarycue.org/

https://ecosystem.visionarycue.org/

https://development.visionarycue.org/

These websites are collectively referred to as the “Websites”. This Policy applies to Personal Data collected through the Websites, including information submitted through enquiry forms and AI-assisted enquiry processes.

1.2 This Policy does not apply to separate brands, products or services that are subject to their own privacy policies or notices, unless expressly stated otherwise.

1.3 Where VisionaryCue processes Personal Data solely on behalf of a client in connection with services provided to that client, such processing will be governed by the applicable client agreement and, where applicable, data processing terms or other contractual arrangements between VisionaryCue and the client. In such circumstances, the client may determine the purposes and means of processing.

1.4 For Personal Data processed by VisionaryCue for its own purposes, VisionaryCue determines the purposes and means of processing and, where applicable, acts as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 and other applicable data protection laws.

Registered Office: Unit No. 604, 6th Floor, Tower B, Bhutani Alphathum, Sector-90, Noida – 201305, Uttar Pradesh

CIN: U73100UP2025PTC221870

2. Personal Data We Collect

Depending on how you interact with our Websites, we may collect Personal Data that you voluntarily provide to us. This may include:

a. VisionaryCue Website: When you submit an enquiry, we may collect your full name, phone number, email address, brand or company name, website or social media URL, selected service requirements, estimated pricing or budget, and information about your idea, project or requirements.

b. OPM Website: When you use the consultation, enquiry, enrolment or other service functionality, we may collect your full name, phone number, email address and information relevant to the course, service or interaction. Where you select the “Talk to Advisor” option, this information is used to facilitate the requested free consultation. Where you purchase a paid offering, we may also process information relating to the transaction, such as the selected offering, payment status, transaction or order details and refund or cancellation information. Payment card or other sensitive payment credentials may be processed directly by the applicable payment provider.

c. Ecosystem Website: Depending on the interaction, we may collect information such as your name, email address, phone number, business or organisation details, subscription or transaction information, and information submitted in connection with an enquiry, listing, subscription or other service.

We collect only the information reasonably necessary for the relevant enquiry, consultation, service, purchase or interaction.

2.2 AI-Assisted Enquiries

For enquiries submitted through the VisionaryCue Website and Development Website, we may use an AI-assisted workflow operated through n8n and OpenAI to generate follow-up questions based on the information you provide, assist with enquiry qualification and support lead management.

The AI-assisted workflow is used for website enquiry and lead information and is intended to generate or adapt follow-up questions and responses based on your answers. It is not intended to process client project or account data through the enquiry flow. Information submitted through the relevant enquiry process may be transmitted to OpenAI through the applicable integration and processed in accordance with applicable service terms and privacy arrangements.

2.3 Information Collected Automatically

When you access or use our Websites, certain information may be collected automatically, depending on the technologies enabled on the relevant Website. This may include your IP address, browser type, device information, operating system, pages viewed, interactions with the Websites, referring and exit pages, and information relating to Website performance and usage.

We may collect such information through cookies, pixels, tags and similar technologies. Further information is provided in Section 4 of this Policy.

2.4 Information From Other Sources

We may receive or obtain personal data from sources such as social media and messaging platforms, referrals, advertising platforms, lead-generation or business databases, and publicly available business or professional sources, where permitted by applicable law and the terms applicable to those sources.

We may use such information to identify and contact prospective clients, respond to enquiries, develop business relationships and provide relevant services or communications. Where applicable, we will provide an appropriate means to stop further communications.

2.5 Information You Should Not Submit

You should not submit passwords, authentication credentials, payment card information, health information, biometric information or other highly sensitive personal data through our Websites unless specifically requested through an appropriate and secure process.

If you provide personal data relating to another person, you must have the authority or permission required to provide that information and for us to process it for the relevant purpose.

3. How We Use personal data

We use personal data only for the purposes described in this Policy and as permitted by applicable law. Depending on the nature of the interaction, we may use personal data to:

3.1 Respond to and manage enquiries: Review, respond to and follow up on enquiries, understand your requirements, assess potential service needs and communicate with you regarding requested Services.

3.2 AI-assisted enquiry follow-up and qualification: We may use automated workflows and OpenAI through an API to generate, adapt and respond to follow-up questions based on information submitted through the VisionaryCue Website and Development Website. This may assist us in understanding your requirements, qualifying enquiries and managing prospective client interactions.

3.3 Provide and manage Services: Use relevant personal data to onboard clients, communicate regarding Services, manage ongoing client relationships and perform activities necessary to provide the Services requested by you or agreed with you.

3.4 Operate and improve the Websites: Maintain, secure, troubleshoot and improve the Websites, monitor their performance and understand how visitors interact with them.

3.5 Analytics and advertising: Use analytics, advertising and similar technologies to measure website performance, understand engagement and measure the effectiveness of campaigns, where the use of such technologies requires consent, only after obtaining the required consent.

3.6 Business development and prospective-client outreach: Identify and communicate with prospective clients and develop business relationships using personal data obtained through the sources described in Section 2.4, where such use and communication are permitted by applicable law and the requirements applicable to the relevant source. Where we use personal data for direct outreach, we will provide an appropriate means to request that we stop contacting you.

3.7 Legal, regulatory and security purposes: Comply with applicable legal and regulatory requirements, respond to lawful requests from authorities, protect our rights and interests, investigate or prevent fraud, security incidents or unlawful activity, and enforce our agreements and policies where permitted by law.

3.8 Sharing of personal data: We may share personal data, where reasonably necessary for the purposes described in this Policy and as permitted by applicable law, with:

a. VisionaryCue personnel who require access to perform their assigned responsibilities;

b. service providers and technology providers supporting hosting, CRM, enquiry management, automation, communications, analytics, advertising and AI-assisted processing, including providers such as n8n and OpenAI where relevant;

c. professional advisers, such as legal, financial, accounting or other advisers, where reasonably necessary;

d. government authorities, regulators, courts or law enforcement agencies, where disclosure is required or permitted by law or is necessary to respond to a lawful request; and

e. relevant parties in connection with a business transaction, such as a merger, acquisition, restructuring, financing or sale or transfer of all or part of our business or assets, subject to applicable law and appropriate confidentiality requirements.

We require service providers engaged by us to process personal data only for authorised purposes and in accordance with applicable contractual requirements and law. Certain third-party providers may independently determine how they process personal data and may be subject to their own privacy policies and terms.

4. Cookies and Tracking

We use cookies, pixels, tags and similar technologies on our Websites to support website functionality and security, understand website usage, measure performance and, where applicable, support advertising and campaign measurement.

The specific technologies used may differ between our Websites. These may include technologies provided by third parties such as Google, Meta and Microsoft. Microsoft Clarity is currently used on the OPM, Ecosystem and Development subdomains.

Where applicable law requires consent for the use of non-essential cookies or similar technologies, we will obtain the required consent before activating them. Where consent is required, you may refuse or withdraw your consent through the cookie preference mechanism made available by us.

Cookies and similar technologies that are necessary for the operation, security or basic functionality of a Website may be used where permitted by applicable law.

Third-party providers whose technologies are used on our Websites may process information collected through those technologies in accordance with their own privacy policies and terms.

The cookies and similar technologies used on our Websites may change from time to time as our Websites, services and technology providers change. Where required, we will provide updated information and obtain any required consent.

5. Data Retention

We retain personal data only for as long as reasonably necessary to fulfil the purpose for which it was collected, provide and manage our Services, comply with applicable legal and regulatory requirements, resolve disputes, enforce agreements and protect our legal rights and interests.

The period for which personal data is retained depends on factors including the nature and sensitivity of the personal data, the purpose for which it was collected, the nature of our relationship with you, whether the information is required for an ongoing business or legal purpose, and any applicable legal or regulatory requirements.

When personal data is no longer required for the relevant purpose and there is no legal, regulatory, security or other valid requirement to retain it, we will delete, anonymise or otherwise securely dispose of it in accordance with our applicable retention practices.

Enquiry and CRM records may be retained for as long as reasonably necessary to manage enquiries, maintain business records, develop or maintain prospective or existing client relationships, comply with applicable requirements, or establish, exercise or defend legal rights.

Security and technical logs may be retained for as long as reasonably necessary for security, troubleshooting, incident investigation, fraud prevention, system integrity or compliance with applicable requirements.

Where personal data is required to be retained for a longer period due to applicable law, a dispute, an agreement or the protection of our legal rights and interests, we may retain it for that additional period.

6. Third-Party Processing and Service Providers

We use third-party service providers and technology providers to support our Websites, business operations and Services. Depending on the nature of the service, these providers may support functions such as hosting, CRM and enquiry management, automation, communications, analytics, advertising and AI-assisted processing.

Where a provider processes personal data on our behalf, we require it to process the personal data only for authorised purposes and in accordance with applicable contractual and legal requirements.

Some third-party providers may process personal data independently for their own purposes and may therefore process personal data under their own privacy policies and terms. In such cases, the processing carried out by that provider may be governed by its own privacy practices.

The third-party providers used by us may change from time to time as our technology, business operations and Services develop.

7. International Data Transfers

personal data may be processed, stored or accessed outside India where this occurs in connection with the services, infrastructure or technology providers used by VisionaryCue.

Where personal data is transferred to, stored in or accessed from a jurisdiction outside India, we will take the measures required under applicable law to ensure that such processing or transfer is carried out lawfully and that appropriate safeguards are applied to the personal data.

Third-party service providers may process personal data in jurisdictions different from India and may be subject to the laws of those jurisdictions. The availability and location of such processing may vary depending on the provider and services used by VisionaryCue.

8. Your Privacy Rights

Subject to applicable law and, where applicable, the commencement of the relevant provisions of the Digital personal data Protection Act, 2023, you may have the following rights in relation to your personal data:

Access and information: request confirmation of whether we process your personal data and, where applicable, a summary of the personal data being processed, information about the processing activities undertaken by us, and information regarding the entities with whom your personal data has been shared, subject to applicable law;

Correction, completion and updating: request correction of inaccurate or misleading personal data and request completion or updating of incomplete or outdated personal data;

Erasure: request erasure of your personal data where permitted by applicable law, subject to circumstances where retention is required or permitted by law or is necessary for a specified purpose;

Withdrawal of consent: withdraw consent where processing is based on consent. Withdrawal will not affect the lawfulness of processing carried out before withdrawal, and we will provide a means to withdraw consent that is as easy as the means through which consent was given, where required by applicable law;

Grievance redressal: raise a grievance regarding our processing of your personal data or the exercise of your privacy rights; and

Nomination: nominate another individual to exercise your rights in accordance with applicable law, where this right is available.

You may exercise your applicable privacy rights or raise a grievance by contacting us using the details provided in the Contact and Grievance section of this Policy. We may request information reasonably necessary to verify your identity and protect against unauthorised requests.

We will address requests and grievances within the period prescribed by applicable law and may decline or limit a request where permitted or required by law.

Where you are dissatisfied with our response or where applicable law provides for escalation after the available grievance redressal mechanism has been exhausted, you may approach the Data Protection Board of India or such other competent authority or forum as may have jurisdiction under applicable law.

9. Data Security

We implement reasonable technical and organisational measures appropriate to the nature of the personal data we process and the risks associated with its processing, with the aim of protecting personal data against unauthorised access, use, disclosure, alteration, loss, destruction and other forms of unlawful or unauthorised processing.

Access to personal data is limited to persons and service providers who require such access for authorised purposes. We also take reasonable measures to maintain the security and integrity of our Websites, systems and services and to protect personal data during transmission where appropriate.

However, no website, system, network or method of electronic transmission or storage can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect personal data, we cannot guarantee its absolute security.

If we become aware of a personal data breach, we will take reasonable and appropriate steps to contain, assess and address the incident and make any notifications or disclosures required under applicable law.

10. Children’s Privacy

Our Websites are intended for a general audience and may be accessed by individuals of different ages. Paid courses, services and other paid offerings available through the Websites are available only to persons who have completed 18 years of age and are legally competent to enter into a binding contract.

We do not intentionally design our Websites to target children or knowingly collect Personal Data from children for purposes that are not permitted by applicable law.

Where we become aware that Personal Data has been collected from a child in circumstances where such collection or processing is not permitted by applicable law, we will take reasonable steps to address the situation, including deletion of the Personal Data where appropriate.

If you believe that a child has provided Personal Data to us in circumstances that may not be permitted by applicable law, please contact us using the details provided in this Policy.

11. Third-Party Websites and Services

Our Websites may contain links to third-party websites, platforms or services that are not operated or controlled by VisionaryCue.

This Privacy Policy does not apply to the privacy practices, content or security of those third-party websites, platforms or services. We recommend reviewing their applicable privacy policies and terms before providing them with personal data.

Where third-party services or technologies are integrated into our Websites, the processing of personal data by those third parties may also be subject to their own privacy policies and terms, as described in this Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Websites, services, technology, data-processing practices or applicable law.

When we make material changes, we will provide an appropriate notice on the relevant Website or through another legally permitted method.

The updated version will be effective from the date stated in the revised Policy. We encourage you to review this Policy periodically.

13. Contact and Grievance

For privacy-related questions, requests or grievances concerning the processing of your Personal Data, you may contact:

Privacy / Grievance Contact: Kashish Varshney
Designation: Head – Legal & Compliance
Email: support@visionarycue.org
Phone: +91 93154 75711
Registered Office: Unit No. 604, 6th Floor, Tower B, Bhutani Alphathum, Sector-90, Noida – 201305, Uttar Pradesh, India

We will acknowledge and address privacy requests and grievances within the period required under applicable law.

14. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of India.

Any dispute arising in connection with this Privacy Policy shall be subject to the jurisdiction of the courts having jurisdiction over Noida, Uttar Pradesh, subject to applicable law.

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