Key Information

Ofcourse (Parent Company – Octopodo Internationals Pvt Ltd.) is the data controller of the Personal Data (as defined
below) we process about you, meaning that we determine the means and purposes of collecting, using, storing,
disclosing, or otherwise processing your Personal Data.

We collect the Personal Data set out in the “What Personal Data We Collect” section of this Privacy Policy below,
including account registration details such as name and email, details of Content Offerings you undertake, survey
information (where you provide it), identity verification data, and information about your use of the Mobile
Application/Site (as defined below) and Services.

We use your Personal Data for the purposes set out in the “Legal bases and Purposes for Processing your Personal
Data” section of this Privacy Policy below. These purposes include providing the Mobile Application/Site and
Services to you, maintaining the security and performance of the Mobile Application/Site, conducting research
relating to Content Offerings, sharing information with our Content Providers and our suppliers, direct marketing,
and performing statistical analysis of the use of our Mobile Application/Site and Services.

You can find information about us and how we collect, use, store, disclose, or otherwise process your Personal Data
in each section of this Privacy Policy:

1. Purpose and who we are
2. What Information this Privacy Policy Covers
3. What Personal Data We Collect
4. Legal bases and Purposes for Processing your Personal Data
5. How We Use AI
6. External Links
7. How we share Personal Data
8. Retention of Personal Data
9. Confidentiality & Security of Personal Data
10. Changing Our Privacy Policy
11. Modification
12. No Information from Children Under 13
13. Sensitive Personal Information Categories
14. Disclosure of Personal information
15. Jurisdiction
16. Contact us

1. Purpose and who we are

The purpose of this Privacy Policy is to describe how Ofcourse, our subsidiaries, affiliates, and our international
branches, (“Ofcourse,” “us,” “we,” or “our”) collects, uses, stores, discloses, and otherwise processes your
Personal Data (as defined below), including through our websites, mobile applications (collectively, the “Site”),
products, and Services.

Please read this Privacy Policy carefully to understand what we do. If you do not understand any aspects of our
Privacy Policy, please feel free to contact us at support.ofcourse@gmail.com. Your use of our Mobile Application/Site is
also governed by our Terms of Use. Terms used but not defined in this Privacy Policy can be found in our Terms of
Use.

Ofcourse (Octopodo Internationals Pvt. Ltd.) is a Private limited company with a principal place of business at
102/B-1 wing, Sundaram Residency, Bhestan, Surat, Gujarat, India – 395023.

2. What Information this Privacy Policy Covers

This Privacy Policy applies to the Personal Data that we process in connection with your use of our Mobile
Application/Site and Services. Some of our Site’s functionality can be used without revealing any Personal Data, but
for features or Services related to the Content Offerings, Personal Data is required. In order to access certain
features and benefits on our Mobile Application/Site, you may need to submit, or we may collect, “Personal Data”
(i.e., information that can be used to identify you and which may also be referred to as “personally identifiable
information” or “personal information”). Personal Data can include information such as your name, email address,
identity documents, Education details, professional details, among other things. You are responsible for ensuring
the accuracy of the Personal Data you submit to Ofcourse. Inaccurate information may affect your ability to use the
Mobile Application/Site, the information you receive when using the Mobile Application/Site, and our ability to
contact you. For example, your email address and mobile number should be kept current because that is one of the
primary manners in which we communicate with you.

3. What Personal Data We Collect

We may collect and process your Personal Data:

directly from you (e.g., when you provide us with account information or you communicate with us),

from third parties, including affiliates, business partners, etc. (e.g., when you complete third party surveys or
interact with third party and/or partner sites).

For us to provide you with our Products or Services, you may be required to provide Personal Data directly to third
parties. Please see the section entitled “Personal Data third parties collect from you directly” for more
information.

Personal Data we collect directly from you

We may collect your Personal Data directly from you, including the following:

Identity and Contact Data: such as your name, date of birth, mailing address, email address, and phone number.

Account Registration Data: if you register for an account on the Mobile Application/Site, you may be required to
provide us with certain Personal Data including name, email address, educational information, professional
information. You may also voluntarily provide us with additional Personal Data including when you update or change
information for your account.

Communications with Ofcourse. We may receive and record Personal Data when you send us an email message or otherwise
contact us, including through the use of an in-platform orbits (community forum) feature.

Product or Service Information: Information about what Products or Services you have registered for.

Information about your interests, preferences and affiliations insofar as they relate to the Product and/or Services
that we provide (e.g., when you sign-up for email or account updates).

The Content of your Communications such as information provided voluntarily in surveys you complete, or in other
exchanges with us, including via email or through the use of an in-platform messaging/chat feature with free-text
functionality like orbits community posts and voice-enabled

features (including audio waves). You should not include any unnecessary Personal Data or information of a sensitive
nature, whether relating to you or another person, in Ofcourse’s free-text functionality i.e. Orbits (Community
forums).

Education, Career and Skills Information including information about your education, career, skills, interests,
goals, and plans, as well as your professional and educational experience and qualifications.

Demographic Information such as country of residence, gender, and age.

Other Personal Data you provide: e.g., information you voluntarily provide to us when you participate in our public
forums such as ORBITS & COMMUNITIES (“Forums”), and/or participate in Content Offerings or other Services on the
Mobile Application/Site.

ORBITS

In relation to the ORBITS, please note that you should not include any information of a personal or sensitive nature,
whether relating to you or another person, in an ORBITS post. We may publish any information you post including via
extensions of our platform that use third-party services, like mobile applications. Please also reference our Terms
of Use for additional information about proper use of our COMMUNITY FORUMS & ORBITS

If you participate in a Content Offering, we may collect certain user-generated content, such as assignments you
submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to
in-video quizzes, standalone quizzes, exams, and surveys. You should not include any information of a personal or
sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for
information required to participate in or submit such assignments, exams, or surveys.

AUDIO WAVES:

Audio waves is our special service to have an interaction among admin , host ,experts with students and other users.
You should never reveal any sort of your or any other person’s personal information in the audio waves (i.e.
discussion rooms).

Personal Data we collect from your device(s) as you use the Mobile Application/Site

When you visit the Mobile Application/Site, we may track, collect, and aggregate information from your device(s)
indicating, among other things, which pages of the Mobile Application/Site were visited, the order in which they
were visited, when they were visited, and which hyperlinks were clicked on. We also collect information from the
URLs from which you linked to the Mobile Application/Site.

Collecting such information may involve logging the IP address, operating system, and browser software used by each
user of the Mobile Application/Site. We may be able to determine from an IP address a user’s Internet Service
Provider and the geographic location of their point of connectivity. Location data may be used to route your traffic
to the nearest regional server to reduce latency and improve your experience.

Personal Data we collect from third parties

We may obtain your Personal Data from third parties, including the following:

Text and/or Images on third party sites: We may receive Personal Data when you access or log-in to a third party
Mobile Application/Site, e.g., Facebook, google ,apple etc. from the Sites. This may include the text and/or images
of your Personal Data available from the third party site.

Survey data: We may receive Personal Data when you provide information in response to a survey operated by a Content
Provider.

Data relating to your use of partner sites: This may include information such as the amount of time spent on the
partner site and pages viewed. Partner sites providing Content Offering-related tools and services to Ofcourse users
may collect non-financial individual-level user data regarding the individual’s use of that partner site while the
partner sites provide those services to Ofcourse. The partner sites may share that data with Ofcourse for the
purpose of improving our Services, the partner site’s services, and the individual’s education experience.

Account registration / invitation data: When an organization invites you to join the Ofcourse platform through its
Enterprise program, Ofcourse may receive Personal Data about you that the organization provides as part of the
invitation / sign-up process.

Personal Data third parties collect directly from you

Our third party partners may collect your Personal Data directly from you in relation to our Products and Services.

4. Legal bases and Purposes for Processing your Personal Data

We set out in this section each of the legal bases under applicable Indian law that we rely on, why and how we use
your data, and the categories of Personal Data we process

Identity Verification. Ofcourse may offer you the ability to verify your identity for select Services. In order to
enroll for these Services, you may be required to provide us or our third-party identity verification vendor with
Personal Data such as your name, address, date of birth, a headshot taken using a webcam or device camera, and a
photo identification document. Coursera’s third-party identity verification vendor may use this Personal Data to
generate biometric facial data.

5. How we use AI

Support learning: these Features support learning e.g., by dubbing content into a student’s native language (like AI
Dubbing does) or by helping students with self-study (e.g., by creating AI generated Inputs i.e. comments) or by
providing feedback (such as with Ofcourse AI, Dialogue, Tools Based Practice Generation, and Roleplay).

Enable assessment and review: these Features allow for peer review, grade assessment, Test, case studies, work
project and written feedback provision (such as AI Enabled Peer Review, AI Open Ended Questions, and AI Integrity
Check). Certain Features also generate assessments (Assessment Generator) or pick up signs of potential exam
misconduct (Course Proctoring).

6. External Links

For your convenience we may provide links to sites operated by organizations other than Ofcourse (“Third Party
Sites”) that we believe may be of interest to you. We do not disclose your Personal Data to these Third Party Sites
unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices
of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review
the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personal
Data.

7. How we share Personal Data

The different Ofcourse entities share common goals and certain resources. As such, your Personal Data may be shared
amongst these entities and our affiliates and subsidiaries, and other affiliated organisations.

We may share your Personal Data with third parties as follows:

Ofcourse Contractors. We use various third party service providers, vendors, and contractors (collectively,
“Contractors”) to support Coursera’s activities, including the purposes listed in this section of the Privacy
Policy. Our Contractors will have access to Personal Data to the extent necessary for provision of their services to
Ofcourse. These Contractors may include vendors and suppliers that provide us with technology, services, and/or
content related to the operation and maintenance of the Mobile Application/Site or the Content Offerings, or related
to Coursera’s other business activities. This may include for targeted advertising and custom audience activities.
Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the
Contractor to perform its limited function for us.

Ofcourse Customers. For learners who are part of an Ofcourse Education program, Ofcourse may share your course
progress, completion status, and other analytics or usage information (“Analytics Data”) with your Ofcourse
Enterprise program for organizational purposes such as verifying enrollment, tracking completion of required or
optional training, supporting internal learning and development programs, and generating related reporting.

Ofcourse Partners. Ofcourse may share Personal Data, including Analytics Data, with university and industry partners,
and other commercial partners including for the Purposes set out in the table above.

Instructors/ Experts: We may share your Personal Data and your performance in a given Content Offering with the
instructor/expert or instructors/experts who taught it, with teaching assistants or other individuals designated by
the instructor/expert or instructors/experts to assist with the creation, modification, or operation of the Content
Offering, and with the Content Provider(s) with which they are affiliated.

Content Providers: We may share your Personal Data, including Analytics Data, with Content Providers and other
business partners of Ofcourse so that Content Providers and other business

partners may share information about their products and services that may be of interest to you where they are
legally entitled to do so.

Badge / Certificate Issuers: Ofcourse may provide limited personal information (including name, email address, and
badge metadata) to its third party digital credentialing platform to allow you to set up an account to receive your
course completion badge.

Government Authorities: Ofcourse may share your Personal Data with various government authorities (such as regulatory
bodies, law enforcement activities, and national security organizations) as set out in the Table above including in
response to lawful subpoenas, court orders, or other legal processes.

External advisors: Ofcourse may share your Personal Data with external advisors including lawyers and consultants
when we believe it is appropriate (e.g., to protect and defend the rights, property, or safety of Ofcourse).

Affiliates, Subsidiaries, or Acquirers. Ofcourse may disclose and/or transfer your Personal Data to an affiliate,
subsidiary, acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all
or substantially all of the equity, business, or assets of Ofcourse to which your Personal Data relates.

8. Retention of Personal Data

We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is collected and
processed, to comply with our legal and regulatory obligations, to exercise our legal rights, and to protect
ourselves from legal claims. The length of time we retain Personal Data for depends on the purposes for which we
collect and use it, the nature of your interaction with us, or as required to comply with applicable laws and to
establish, exercise, or defend our legal rights.

Biometric facial data generated as part of the identity verification process is deleted upon successful completion of
verification and in any event, no later than 5 years after collection. Other information uploaded as part of the
identity verification process, including your name, address, date of birth, and a photo identification document, is
deleted upon request and in any event, no later than 5 years after collection.

9. Confidentiality & Security of Personal Data

We will use industry standard physical, technical, and administrative security measures to keep your Personal Data
confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy
Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as
permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security
of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security
systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to
protect the security of your login information. Please note that e-mail communications are typically not encrypted
and should not be considered secure.

If you request deletion of your Personal Data, we will delete the Personal Data associated with that account,
including your learner profile, course history, and any certificates or certifications issued through our platform.
Once your account is deleted, certificates and certifications cannot be accessed, verified, or reissued, and we
recommend downloading any certificates and certifications you wish to keep before submitting a deletion request.
Following deletion, we may retain limited Personal Data where necessary for lawful and legitimate purposes, which
may vary depending on your location, such as complying with legal obligations. In addition, residual information may
remain within our databases, access logs, or other records, which may or may not contain your Personal Data.

10. Changing Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change.
Any change, update, or modification will be effective immediately upon posting on our Mobile Application/Site. We
will notify you of any material change to this Privacy Policy by

posting a notice on our Site’s homepage for a reasonable period of time following such update or by sending an email
to the email address associated with your user account, and by changing the effective date (located at the top of
this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this
Privacy Policy.

11. Modifications

We may amend this Privacy Policy from time-to-time in accordance with the requirements or a successor data transfer
framework. The most recent version of the Privacy Policy will always be posted to this website. Anytime that we do
make such changes, we will also update the effective date listed at the top of the Privacy Policy. Please be sure to
review the most recent version of the Privacy Policy each time that you visit this website so that you are aware of
how we collect, use, and retain Personal Data.

12. No Information from Children Under 13

Ofcourse strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is
prohibited, and certain regions and Content Offerings may have additional requirements and/or restrictions. In line
with this belief, we do not knowingly collect or process Personal Data through the Mobile Application/Site or
Services from persons under 13 years of age, and no part of the Mobile Application/Site or Services is directed to
persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Mobile
Application/Site or Services at any time or in any manner. We will take appropriate steps to delete any Personal
Data of persons less than 13 years of age that has been processed through the Mobile Application/Site or Services
without verified parental consent upon learning of the existence of such Personal Data.

13. Sensitive Personal Information Categories

Depending on how and why you interact with the Mobile Application/Site and Services, some of the personal information
that Ofcourse may collect and use about you, identified in “Collection and Use of Personal Information” above, may
be considered “sensitive” under applicable U.S. State Privacy Laws in certain circumstances:

Government ID (e.g. driver’s license, state identification card, or passport number);

Demographic information (e.g. racial or ethnic origin);

Biometrics information processed for identification purposes;

We only use or disclose sensitive personal information for the following purposes:

Perform the services or provide the goods you reasonably expect;

To prevent, detect, and investigate security incidents;

To resist malicious, deceptive, fraudulent, or illegal actions directed at Ofcourse and to prosecute those
responsible for those actions;

To ensure the physical safety of natural persons;

For short-term, transient use, including, but not limited to, non-personalized advertising;

To perform services on behalf of Ofcourse;

To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured,
manufactured for, or controlled by Ofcourse, and to improve, upgrade, or enhance the service or device that is
owned, manufactured by, manufactured for, or controlled by Ofcourse;

To collect or process sensitive personal information where such collection or processing is not used for the purpose
of inferring characteristics about you;

Other activities in accordance with new or additional regulations that may be issued pursuant to applicable Indian
law.

Where required under applicable Union of India Privacy laws or other applicable legislation, we will

(i) request your consent, or (ii) provide you with the opportunity to opt-out, in each case (i) and (ii), for our
collection and use of sensitive personal information for the purposes listed above or other purposes that are
communicated to you at the time that consent is requested.

14. Disclosure of Personal Information

We may disclose the personal information identified in the “Collection and Use of Personal Information” section of
this Union of India Privacy Laws Notice to third parties as follows (depending on how and why you interact with the
Mobile Application/Site and Services):

Service Providers

We may disclose personal information to our service providers in order to have them perform services that assist us
in fulfilling the purposes listed above. Our service providers provide us with a range of services including:
hosting our Mobile Application/Site, legal, auditing and accounting professional services, postal and email
delivery, conducting analysis to improve our products and Mobile Application/Site, fulfilling requests you make,
performing identity verification, and answering

your questions. We may disclose personal information to our service providers in order to improve our Mobile
Application/Site and Services, such as to identify bugs, repair errors, or ensure that services function as
intended, or conduct internal research and analysis to improve our technology.

Ofcourse Partners

We may disclose personal information to Ofcourse partners (e.g. Universities, educational institutions, or industry
partners) who (i) offer degree Programs hosted on the Mobile Application/Site, in which you enroll or express an
interest; or (ii) create content, programs, projects or other courses which Ofcourse provides on the Mobile
Application/Site and in which you enroll.

Ofcourse Customers

Where your access to our Services is provided to you as part of your relationship with your employer, academic
institution, or corporate sponsor we may disclose to them (or an authorized entity acting on their behalf)
information about your participation and learning progress on Ofcourse.

Advertising Partners

We may disclose limited personal information to advertising partners in order to show you

advertising that is more likely to be of interest to you. You can learn more about this in the “Privacy Rights”
section of this U.S. State Privacy Laws Notice and the Ofcourse Cookies Policy. You can opt-out of this disclosure
by visiting Ofcourse’s Do Not Sell / Share My Personal Information link and opting out of ‘Targeting Cookies’.

Research Partners

We may share course data (including quiz or assignment submissions, grades, and Forum discussions), information about
your activity on our Mobile Application/Site, and demographic data from surveys operated by us with our partners and
research institutes for research related to online education.

Other Disclosures

On an ad hoc basis as necessary, we may also disclose personal information to third parties (such as our partners,
service providers, and law enforcement and government agencies) to secure our Mobile Application/Site and Services
and rights and interests of Ofcourse and its partners, including to detect, prevent, and investigate security
incidents or violations of our Terms of Use or applicable laws, or in the context of legal proceedings. We may also
disclose personal information to an acquirer, assignee, or other successor entity in connection with a sale, merger,
or reorganization of

all or substantially all of the equity, business, or assets of Ofcourse. Additionally, we disclose personal
information to third parties at your direction (for example, if you choose to make your Ofcourse profile public, or
post in a publicly-available Ofcourse Forum, Ofcourse will make the relevant Personal Information available to other
users of the Mobile Application/Site).

15. Jurisdiction

Any matter/dispute shall be subject to the jurisdiction of the district court of Surat, Gujarat, India Only.

16. Contact Us

Please contact us with any questions or comments about this Privacy Policy, our privacy practices, by email at
support.ofcourse@gmail.com.