Privacy Policy
Last updated: 26 August 2026
1. Who we are
BOLKAR is a live online English speaking practice service operated as a sole proprietorship by Mugdha Labhade. This policy explains what personal data we collect, why we collect it, how we use it, and what rights you have under the Digital Personal Data Protection Act, 2023.
2. What we collect
When you visit bolkar.in
- Pages you visit, time spent, and how you arrived at the site
- Approximate location derived from your IP address (city or region level)
- Device and browser type
- A first-party cookie containing a random session identifier, used only by us
We do not use third-party advertising trackers.
When you contact us or book a demo
- Your name
- Your WhatsApp number
- Your email address, if you provide it
- What you want to use English for
- Your messages to us
When you enrol
- The information above
- Payment confirmation details received from Razorpay
We never receive or store your card number, CVV, UPI PIN, or bank credentials. These are handled entirely by Razorpay.
When you attend sessions
- Attendance records
- Session recordings, including video, audio, and chat
- Automated transcripts generated from those recordings
- Feedback notes prepared for you
3. Why we use it
- To respond to your enquiry and arrange a demo
- To enrol you, take payment, and issue an invoice
- To deliver sessions and send you links, reminders, materials, and practice tasks
- To prepare individual feedback based on your speaking in sessions
- To issue your certificate
- To improve our programmes and trainer quality
- To understand how learners find us, so we can reach more people
4. Recordings and transcripts
All sessions are recorded. Recordings include all participants, not only the trainer. You may keep your camera off and use a display name that does not identify you.
Recordings are made available to learners who miss a session. Transcripts are used to prepare your individual feedback.
Automated processing. We use automated tools, including AI language models, to help draft feedback from session transcripts. Every draft is reviewed and edited by your trainer before it is sent to you. No decision about you is made solely by automated means.
Transcripts may be shared with these tools for this purpose. We do not share recordings or transcripts with any other third party.
5. Who can access your data
- Your trainer
- BOLKAR's operator (Mugdha Labhade)
- Service providers who process data on our behalf, listed below
We do not sell your personal data to anyone.
6. Service providers we use
| Provider | Purpose |
|---|---|
| Razorpay | Payment processing and invoicing |
| Zoom | Hosting live sessions, recording, transcription |
| WhatsApp (Meta) | Messaging, session links, reminders, practice tasks |
| Email and internal record keeping | |
| Cloud storage and AI providers | Storing recordings and drafting feedback |
Each of these providers has its own privacy policy governing how it handles data.
7. How long we keep it
| Data | Retention |
|---|---|
| Session recordings | Up to 3 months after your cohort ends, then deleted |
| Transcripts | Retained beyond recordings, for feedback and quality improvement |
| Enquiry and enrolment records | Retained while you are a learner and afterwards for our records |
| Payment and invoice records | Retained as required for accounting and tax purposes |
| Website usage data | Retained in aggregate form |
8. Your rights
Under the Digital Personal Data Protection Act, 2023, you may:
- Ask what personal data we hold about you
- Ask us to correct anything inaccurate
- Ask us to delete your personal data, subject to records we are legally required to keep
- Withdraw consent for processing, understanding that this may mean we cannot continue to deliver the programme to you
- Nominate another person to exercise these rights on your behalf
- Raise a grievance with us
To exercise any of these, contact our Grievance Officer below. We respond within 24 hours and will complete requests as soon as reasonably possible.
9. Grievance Officer
Mugdha Labhade
mugdhalabhade62@gmail.com
+91 70303 96001
10. Cookies
We use one first-party cookie containing a random session identifier. It helps us understand how visitors move through our site and where they came from. It is not shared with any advertising network and is not used to track you across other websites. You can clear or block cookies in your browser settings.
11. Children
BOLKAR programmes are intended for adults. If a learner is under 18, a parent or guardian must consent to enrolment and to session recording.
12. Security
We take reasonable measures to protect your data, including restricted access to recordings and transcripts. No system is completely secure, but we work to keep your information safe and will inform you if a breach affects you.
13. Changes to this policy
We may update this policy. The current version is always published on this page with the date it was last updated.