DATA PROCESSING ADDENDUM
Effective date: 18 June 2026
This Data Processing Addendum ("DPA") forms part of the Terms of Service or other agreement between 99Fusion Technosoft Pvt. Ltd., operating AcademyLauncher ("AcademyLauncher"), and the Creator, organization or customer using the Platform ("Customer"). It applies when AcademyLauncher processes Personal Data on Customer's behalf.
DEFINITIONS
"Applicable Data Protection Law" means privacy and data-protection law applicable to the processing, including where relevant the India Digital Personal Data Protection Act, 2023 and rules brought into force under it, the EU General Data Protection Regulation, the UK GDPR, and comparable laws.
"Personal Data", "processing", "controller", "processor", "Data Principal" and "data subject" have the meanings given by applicable law. "Customer Data" means Personal Data submitted to or collected through Customer's academy, content, community, forms, transactions or integrations.
ROLES AND SCOPE
Customer determines the purposes and means of processing Customer Data and acts as controller or Data Fiduciary. AcademyLauncher acts as processor or Data Processor when it processes Customer Data to provide the contracted services. Each party may act as an independent controller for data it processes for its own account administration, security, fraud prevention, billing, legal compliance and business operations, as described in the Privacy Policy.
Processing may include collection, recording, organization, storage, retrieval, transmission, support, analysis, deletion and other operations necessary to host academies; manage users; deliver courses, memberships, communities, communications and assessments; process orders; provide support; secure the Platform; and perform Customer's documented instructions.
Data subjects may include Students, prospective Students, Customer personnel, instructors, affiliates, community members and other persons whose data Customer places on the Platform. Data may include identity and contact details, account credentials, purchase and billing records, learning activity, assessment results, communications, uploaded content, technical identifiers and other information selected by Customer.
CUSTOMER INSTRUCTIONS AND RESPONSIBILITIES
AcademyLauncher will process Customer Data only on Customer's documented instructions, including instructions inherent in Customer's configuration and use of the Platform, unless law requires otherwise. If we believe an instruction violates applicable law, we may suspend the affected processing and notify Customer where legally permitted.
Customer is responsible for having a lawful basis, giving required notices, obtaining valid consent where necessary, responding to data-subject requests, configuring retention and access controls, and ensuring its instructions and use of the Platform comply with law. Customer must not upload data that it is prohibited from processing or that requires safeguards the parties have not agreed to.
CONFIDENTIALITY
AcademyLauncher will limit access to Customer Data to personnel and contractors who need access to perform the services and who are bound by appropriate confidentiality obligations. These obligations continue after their engagement ends.
SECURITY
AcademyLauncher will maintain reasonable administrative, technical and organizational safeguards appropriate to the nature of the processing and risks involved. Measures may include access controls, authentication, encryption in transit where supported, logging, backups, vulnerability management, incident response and personnel controls. No system is completely secure, and Customer remains responsible for account credentials, authorized-user permissions, endpoints, integrations and secure configuration.
PERSONAL DATA BREACHES
After becoming aware of a confirmed Personal Data breach affecting Customer Data, AcademyLauncher will notify Customer without undue delay, consistent with applicable law. The notice will provide available information reasonably necessary for Customer to meet its obligations. AcademyLauncher may provide information in phases and will take reasonable steps to contain and remediate the incident. Notification is not an admission of fault or liability.
Customer is responsible for notifications to regulators, Data Principals, data subjects or other parties unless law places that obligation directly on AcademyLauncher.
DATA-SUBJECT AND DATA-PRINCIPAL REQUESTS
Taking into account the nature of processing and available functionality, AcademyLauncher will provide reasonable assistance for requests to access, correct, erase, restrict, port or otherwise exercise applicable rights. If AcademyLauncher receives a request relating to Customer Data for which Customer is responsible, we may direct the requester to Customer. Customer is responsible for verifying requests and determining the lawful response.
SUBPROCESSORS
Customer authorizes AcademyLauncher to use subprocessors to provide hosting, storage, communications, analytics, security, support, payment and other service functions. AcademyLauncher will require subprocessors that process Customer Data to protect it under obligations appropriate to the services they perform. AcademyLauncher remains responsible for its subprocessors to the extent required by applicable law.
Where required, AcademyLauncher will make information about material subprocessors available and provide reasonable notice of material changes. A Customer with a legally supportable objection should contact us promptly; the parties will work in good faith on a reasonable solution, which may include discontinuing the affected feature.
INTERNATIONAL TRANSFERS
Customer authorizes processing in countries where AcademyLauncher or its subprocessors operate, subject to applicable restrictions. Where a legally recognized transfer mechanism is required, the parties will cooperate to implement appropriate contractual clauses or safeguards. Customer is responsible for ensuring that its use of the Platform and transfer instructions comply with laws applicable to it.
RETURN AND DELETION
During the subscription, Customer may access or export Customer Data through available features. Following termination, AcademyLauncher may delete or anonymize Customer Data after a reasonable retrieval period, unless retention is required by law, necessary for security, disputes or legitimate backup cycles, or otherwise agreed. Data in backups may remain until overwritten under normal retention schedules and will remain protected under this DPA.
ASSISTANCE AND COMPLIANCE INFORMATION
AcademyLauncher will provide information reasonably necessary to demonstrate compliance with processor obligations. If legally required and not reasonably satisfied by existing documentation, the parties may agree to a proportionate audit by an independent auditor, subject to confidentiality, security, reasonable notice, minimal disruption and Customer bearing reasonable costs. Audits may not expose information belonging to other customers or compromise Platform security.
GOVERNMENT REQUESTS
AcademyLauncher may disclose Customer Data when legally required. Where permitted, we will notify Customer before disclosure and will limit disclosure to information legally required.
CONFLICT AND LIABILITY
If this DPA conflicts with the Terms of Service regarding processing of Customer Data, this DPA controls for that subject. All liability under this DPA is subject to the limitations and exclusions in the governing agreement to the maximum extent permitted by law.
CONTACT
Privacy and data-processing questions may be sent to support@academylauncher.com. Customer should identify its account and describe the relevant processing or request.