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Notice | Family 11, Notices
This is the notice Edsol Edtech Pvt. Ltd. gives you at the point it collects your personal data, as Section 5 of the Digital Personal Data Protection Act, 2023 read with Rule 3 of the Digital Personal Data Protection Rules, 2025 requires. It is presented as a set of short, versioned notice blocks, one for each place…
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NTC-GL-023 | Version 1.0.0 | Effective 03 August 2026 | Last Modified On 03 August 2026
This is the notice Edsol Edtech Pvt. Ltd. gives you at the point it collects your personal data, as Section 5 of the Digital Personal Data Protection Act, 2023 read with Rule 3 of the Digital Personal Data Protection Rules, 2025 requires. It is presented as a set of short, versioned notice blocks, one for each place Pensieve Labs asks you for personal data, so that the notice can be shown next to the field you are filling in rather than buried in a long policy. Each block carries an identifier of the form NB-NN, and each links back to the standing notice at 2.
This notice governs personal data Edsol Edtech Pvt. Ltd. collects as a Data Fiduciary in its own right, on its own public surfaces: the website at https://pensievelabs.org, the Trust Center at https://trust.pensievelabs.org, the Support Center at [TO BE SUPPLIED], and the forms rendered on them.
It does not apply to personal data inside a hospital's tenant, where the hospital is the Data Fiduciary and Pensieve Labs is a Data Processor acting on the hospital's documented instructions. No patient, clinical or diagnostic record is ever collected through these surfaces, and you should not submit one to them. The two-role boundary, and the full itemised description of what Pensieve Labs holds as a Data Fiduciary, are in the Privacy Policy (POL-GL-053). Cookies and pixels on these surfaces are described in the Cookie Policy and Consent Notice (POL-GL-054), which this notice does not restate.
It does not vary by deployment model, because it concerns Pensieve Labs's own collection, not the Platform's operation.
1.1 Section 5 of the Act requires a notice, given before or with every request for consent, and Rule 3 sets its content. The following table lists each requirement and points to where this notice satisfies it.
| Requirement | Provision | How this notice meets it |
|---|---|---|
| Notice precedes or accompanies the request for consent | Section 5(1) | Each block at 3 renders before or beside the field, before you submit |
| Standalone, understandable independently of any other information | Rule 3(a) | Each block is self-contained and links to the standing notice at 2; it is not embedded in the Terms of Use |
| Itemised description of the personal data | Rule 3(b)(i) | The Personal data column at 3, and POL-GL-053 clause 3.1 |
| Specified purpose, and a specific description of the goods or services or the uses enabled | Rule 3(b)(ii) | The Specified purpose and Goods or services enabled columns at 3 |
| Clear and plain language | Rule 3(b) | Every block is written to a plain-language standard |
| The communication link and means to withdraw consent, with ease comparable to that with which it was given | Rule 3(c)(i) | 2, the rights request form (FRM-GL-505), and the unsubscribe link in every marketing message (POL-GL-072) |
| The means to exercise rights under the Act | Rule 3(c)(ii) | FRM-GL-505 and 2 |
| The means to make a complaint to the Board | Rule 3(c)(iii) | 2 and the Grievance Redressal Policy (POL-GL-066) |
| The option to access the notice and the consent request in English or a language in the Eighth Schedule to the Constitution | Sections 5(3) and 6(3) | 4 |
| The business contact of a person who can answer questions about the processing | Section 8(9) and Rule 9 | The Grievance Officer named in POL-GL-066, repeated in every rights response |
This is the full notice that appears at the link each block carries. It is published at https://trust.pensievelabs.org and at the collection-notice address on the website.
2.1 Who is collecting your data. Edsol Edtech Pvt. Ltd., a Private Limited Company trading as Pensieve Labs, is the Data Fiduciary for the personal data collected on the surfaces at the head of this notice. Its contact for privacy is info@pensievelabs.org.
2.2 What is collected and why. The exact data, purpose and goods or services enabled are itemised block by block at 3. Pensieve Labs collects only what the stated purpose needs.
2.3 What Pensieve Labs never does with it. It does not sell, rent, licence or trade your personal data; it does not use it for behavioural advertising; and it does not use it to train, fine-tune or evaluate any machine-learning model. These commitments are stated in full in POL-GL-053 clause 2.3.
2.4 Who else processes it. The service providers that operate Pensieve Labs's own systems, and the data each touches, are listed in the Subprocessor Register (DIS-GL-009). This notice does not restate that list.
2.5 Your lawful basis. Where you send Pensieve Labs your data for a purpose you have chosen, it is processed as a legitimate use under Section 7(a). Where the purpose is marketing, including the newsletter, it rests only on your consent under Section 6, withdrawable at any time. The Act provides no marketing legitimate-use ground and no legitimate-interests basis, and Pensieve Labs relies on none.
2.6 Withdrawing consent. Where processing rests on consent, you may withdraw it at any time, and withdrawal is as easy as giving it was: the unsubscribe link in any marketing message, the preference route in POL-GL-072, or the rights request form (FRM-GL-505). Withdrawal does not affect processing already done, or processing on a different basis, such as records a law requires Pensieve Labs to keep.
2.7 Exercising your rights. You have the rights to access, correction, completion, updating, erasure, grievance redressal and nomination. Exercise them through FRM-GL-505; Pensieve Labs does not restate the mechanics here.
2.8 Grievance and the Board. The Grievance Officer, the acknowledgement and response timelines, and the route to escalate to the Data Protection Board of India once it is operational, are all in POL-GL-066. That contact is repeated in every response Pensieve Labs sends you.
2.9 Language. English and Hindi today, and any other Eighth Schedule language on request: see 4.
3.1 Each row below is a collection point on a Pensieve Labs surface. The block at that point shows the short text at 3.3, which is written to render beside a form field. The retention trigger is stated here; the retention period for each category is owned by POL-GL-053 clause 7.2 and is not restated, so the two cannot drift apart.
3.2 The itemised description.
| Block | Collection point | Personal data collected | Specified purpose | Goods or services enabled | Retention trigger |
|---|---|---|---|---|---|
NB-01 |
Marketing contact form | Name, work email, organisation, role, message, any bed count or location you state | To answer your enquiry and assess fit | A reply, and a proposal if you proceed | From last contact where no relationship follows |
NB-02 |
Demonstration request | Name, work email, telephone, organisation, role, stated interest | To arrange and run a demonstration | A scheduled demonstration of the Platform | From last contact where no relationship follows |
NB-03 |
Newsletter signup | Work email, and name where given | To send the Trust Center and product newsletter | Delivery of the newsletter you asked for | From your unsubscribe, plus the evidence period |
NB-04 |
Trust Center email gate | Work email | To unlock email-tier documents and record what was released | Access to email-tier Trust Center documents | From last access to the gated document set |
NB-05 |
Trust Center access request | Name, work email, organisation, role, stated reason, approval decision | To decide the request and provision or decline a credential | A Trust Center credential, or a reasoned decline | From the decision |
NB-06 |
Careers application | Application, curriculum vitae, correspondence, references | To assess your application for a role | Consideration for the role you applied to | From the recruitment decision |
NB-07 |
Support ticket | Name, work email, ticket content, any file you attach | To resolve your ticket and improve the Platform | Resolution of the issue you raised | From closure of the ticket |
NB-08 |
Event registration | Name, work email, organisation, attendance record | To register you for, and run, the event | A place at the event or webinar | From the event |
NB-09 |
Security report | Name or handle, contact address, report content | To triage and fix the report and to communicate with you | Handling of your report, and credit where you wish | From closure of the report |
3.3 The block text. This is the text rendered at each point, with Edsol Edtech Pvt. Ltd. as the Data Fiduciary in each. The data collected is in the table above; each block stays short.
NB-01 Marketing contact form. Used to answer your enquiry and assess fit. Never sold and never used to train a model. Exercise your rights or withdraw, as easily as you gave the data: FRM-GL-505. Full notice: POL-GL-053.
NB-02 Demonstration request. Used to arrange and run a demonstration. Rights and withdrawal: FRM-GL-505. Full notice: POL-GL-053.
NB-03 Newsletter signup. Sent only on your consent. Unsubscribe from a link in every issue, as easily as you subscribed. How marketing and withdrawal work: POL-GL-072. Rights: FRM-GL-505.
NB-04 Trust Center email gate. Used to unlock email-tier documents and record what was released. Access is governed by POL-GL-500 and POL-GL-052. Rights: FRM-GL-505.
NB-05 Trust Center access request. Used to decide your request and provision or decline a credential, and the decision is recorded. Form and rules: FRM-GL-504. Rights: FRM-GL-505.
NB-06 Careers application. Used to assess you for the role. The full candidate notice, including verification and retention, is POL-IN-320. Rights: FRM-GL-505.
NB-07 Support ticket. Used to resolve your issue. Do not include patient or clinical data; if it reaches us it is treated as the hospital's data under DPA-GL-001, not ours. Support: POL-GL-056. Rights: FRM-GL-505.
NB-08 Event registration. Used to register you for and run the event. We contact you afterwards only where you asked, or on consent. Rights: FRM-GL-505.
NB-09 Security report. Used to triage and fix the issue, reach you, and credit you where you wish. Disclosure terms and safe harbour: POL-GL-059. Rights: FRM-GL-505.
4.1 The requirement. Sections 5(3) and 6(3) of the Act require Pensieve Labs to give you the option to access this notice and the consent request in English or in any language specified in the Eighth Schedule to the Constitution of India. The Eighth Schedule lists 22 languages: Assamese, Bengali, Bodo, Dogri, Gujarati, Hindi, Kannada, Kashmiri, Konkani, Maithili, Malayalam, Manipuri, Marathi, Nepali, Odia, Punjabi, Sanskrit, Santhali, Sindhi, Tamil, Telugu and Urdu. The duty sits in the Act, not in Rule 3.
4.2 Pensieve's position today. The standing notice and every block are available in English and Hindi now. The remaining Eighth Schedule languages are provided on request to info@pensievelabs.org, and the collection surfaces carry a language selector so the choice is offered at the point of notice, not only afterwards.
4.3 An open design point. [UNVERIFIED: no binding Board or Government guidance was located confirming whether all 22 Eighth Schedule languages must be pre-rendered by default or may be offered on selection; Pensieve Labs builds to the conservative reading, that the choice must be genuinely available at the point of notice, and will pre-render further languages if guidance requires it.]
5.1 How consent is captured. Where consent is the basis, it is taken by a clear affirmative action, is not bundled with anything unnecessary, uses no pre-ticked box, and is limited to the personal data necessary for the stated purpose, as Section 6(1) of the Act requires.
5.2 What the consent record contains. Section 6(10) places on Pensieve Labs the burden of proving that a valid notice was given and valid consent obtained. To meet it, each consent is recorded with: the notice block identifier and the version of the notice shown; the itemised personal data and the specified purposes; the language in which the notice and request were presented; the affirmative action you took; your identifier and a timestamp; and, on withdrawal, the withdrawal event and the resulting cessation. The record is held in the Consent and Lawful Basis Register (REG-GL-207).
5.3 The reference you receive. On giving consent you receive a unique consent reference, of the form CNS-<year>-<serial>, by which you can later identify and withdraw that specific consent. Quote it when you write to info@pensievelabs.org or use FRM-GL-505, though you are not required to have it.
5.4 How long the record is kept. The consent and withdrawal record is retained for as long as the consent is relied on and for the evidence period after withdrawal stated in POL-GL-053 clause 7.2, so that Pensieve Labs can show that a withdrawal was honoured.
6.1 The statutory position. Sections 6(7) to 6(9) let a Data Principal give, manage, review and withdraw consent through a Consent Manager, a company registered with the Board that meets the First Schedule conditions. Rule 4, which governs that registration, commences on or about 14 November 2026.
6.2 Pensieve's own tools are not a Consent Manager. Pensieve Labs's preference centre and the routes in this notice are its own capture; they are not a Consent Manager in the statutory sense, and this notice does not describe them as one. Where a registered Consent Manager exists and you route consent through it, Pensieve Labs will honour a give or withdraw instruction received that way once the mechanism is available.
| Subject | Document that owns it |
|---|---|
What personal data Pensieve Labs holds as a Data Fiduciary, and full retention periods |
POL-GL-053 |
| Cookies and pixels on the collection surfaces | POL-GL-054 |
| Grievance Officer, timelines and complaint to the Board | POL-GL-066 |
| Marketing communications, consent and unsubscribe | POL-GL-072 |
| Rights request mechanics and the intake form | FRM-GL-505 |
| Candidate and recruitment privacy | POL-IN-320 |
| Service providers and where they process | DIS-GL-009 |
| Trust Center access request form | FRM-GL-504 |
| Consent and lawful basis record | REG-GL-207 |
| Version | Date | Author | Summary |
|---|---|---|---|
| 1.0.0 | 2026-08-03 | Legal | First issue. The Section 5 and Rule 3 itemised notice as nine short versioned blocks renderable beside a form field; requirement-by-requirement mapping; the standing notice; the collection-point table; the Eighth Schedule language position with the open design point marked; the consent record and reference; and the Consent Manager position. |
NTC-GL-023 v1.0.0 | Last Modified On 03 August 2026 | Review due 03 February 2027 | Published at https://trust.pensievelabs.org