Privacy Policy

SubmitAbility Technology Pvt Ltd (“Company”, “we”, “us”, or “our”) operates AscentAbility, a software-as-a-service platform designed to assist students write secondary essays for their application to medical schools in the United States of America (“Platform”). We provide our services (“Services”) through our website (the “Website”) and the Platform. References to the “Services” in this Privacy Policy include all features, functionalities, and content made available through the Platform and the Website. We process and handle personal data collected through the Platform and the Website in accordance with applicable data protection and privacy laws, including laws applicable in the jurisdictions in which we operate and provide our Services.

This Privacy Policy (“Privacy Policy”) explains how we collect, use, share, disclose, and protect personal information about the users of the Services and visitors of the Website or Platform (collectively referred to as “you”, “your” or “Users”). We have created this Privacy Policy to demonstrate our commitment to the protection of your privacy and your personal information. Your use of and access to the Services is subject to this Privacy Policy and our Terms and Conditions (“Terms and Conditions”).

IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE OR AN ENTITY, YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

Generally, some of the Services require us to know who you are so that we can best meet your needs. When you access the Services, or through any interaction with us via emails, telephone calls, or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. We collect and process your personal data based on your consent obtained at the time of registration for the specific purposes described in this Privacy Policy (as set out under the paragraph titled ‘Privacy Statements’). Without prejudice to the generality of the above, information collected by us from you may include the following:

• contact data, including your name, email address, and phone number;
• location data, including your country, state, and city of residence;
• academic and application data, including names of medical schools you are applying to, priority ratings assigned by you to individual schools, dates of receipt of secondary applications, and your application submission status;
• secondary application essays and other written content you create or upload to the Platform, which may contain sensitive personal information including details relating to your health, personal background, or identity;
• school portal credentials (usernames and passwords), if entered by you into the Platform;
• financial information, including transaction reference numbers and subscription status (card and payment instrument details are handled directly by our payment processors and are not stored by us);
• technical and usage data, including IP address, browser type, device information, and interaction data with the Platform; and
• other information you voluntarily provide to us through emails, correspondence, feedback, or survey responses.

We may process personal data that is publicly available in accordance with applicable law.

All information provided to us by a User is voluntary. By registering on the Platform and providing your information, you consent to the collection and use of your personal data for the purposes described in this Privacy Policy. Any User that does not agree with any provisions of the same has the option to discontinue the Services provided by the Platform immediately.

You understand that we may use certain information of yours for the following purposes:

• for the purpose of providing you the Services, including delivering Platform features such as essay management, version tracking, progress tracking, school organisation, and PDF export functionality;
• for payment processing and management of your subscription;
• for communication purposes, including to provide you with a better experience of the Services and to obtain feedback;
• for marketing purposes, including to send you promotional emails, product updates, and newsletters. You may opt out of marketing communications at any time by using the unsubscribe link/button in our emails or by contacting us directly at support@ascentability.com
• for commercial purposes and in an aggregated, anonymized, and non-personally identifiable form for research, statistical analysis, and product improvement;
• for transfer of such research, statistical, or intelligence data in aggregated, anonymized, and non-identifiable form to third parties and affiliates;
• for debugging and customer support-related issues; and
• to comply with applicable legal and regulatory obligations.

By affirming your assent to this Privacy Policy, you provide your consent to such use, collection, and disclosure as required under applicable law and as set out in this Privacy Policy.

You are responsible for ensuring that the personal data you provide to us is accurate and up to date. If your personal information changes, you may correct, delete inaccuracies, or amend information by contacting us at support@ascentability.com. If you provide any information that is untrue, inaccurate, out of date, or incomplete, or if we have reasonable grounds to suspect the same, we may, inter alia, at our sole discretion, discontinue the provision of the Services to you.

If you wish to cancel or delete your account or request that we no longer use your information to provide you Services, please contact us at support@ascentability.com. Upon receipt of a voluntary termination request, the account will be deactivated immediately. The account may be reactivated within 30 days by logging back into the Platform, following which all account data will be restored. If the account is not reactivated within 30 days of the termination request, we will permanently delete or anonymise the personal data associated with the account.

For the avoidance of doubt, cancellation of a subscription does not automatically result in deletion of your account. If you cancel your subscription, you may continue to access and retrieve your written content and account data for the remainder of the applicable application cycle, ending on July 1 of the following year. After that date, access to the account and its contents may be disabled or removed in accordance with this Privacy Policy and applicable law.

We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. Your data may be anonymised and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymised data will be solely for analytic purposes. Certain limited records, including logs and transaction data, may be retained for compliance, security, and audit purposes as required under applicable law. Please note that your withdrawal of consent or cancellation of account may result in us being unable to provide you with its Services or to terminate any existing relationship that we may have with you.

In the course of providing the Services, we share personal data only as described in this Privacy Policy with certain third-party processors, including:

• Cloud Infrastructure Provider: Amazon Web Services (AWS): cloud hosting, storage, compute, and delivery of all Platform data. Platform data is primarily hosted on infrastructure provided by this processor.
• Payment Processor: HDFC Bank Payment Gateway: payment processing for subscription transactions. Card data is handled by the payment processor under Payment Card Industry Data Security Standards (PCI-DSS). We do not receive or store card or payment instrument details.

We may also disclose personal data to courts and/or government authorities where required by applicable law, court order, or government direction. We may additionally disclose data in connection with a merger, acquisition, or sale of all or substantially all of our assets, subject to this Privacy Policy continuing to apply to your data.

We reserve the right to sell or license anonymized or aggregated data to third parties for research, marketing, or analytics purposes. Such data will not directly identify you. If we intend to sell or share personal data that identifies you, we will provide you with prior notice and the opportunity to opt out (or, where required by law, seek your express opt-in consent) before doing so. Please refer to the Regional Supplemental Privacy Policy below for how to exercise these rights if you are located in a specific jurisdiction.

When you access the Website or use the Services, we may use cookies and similar tracking technologies to collect certain information automatically. We use the following categories of cookies:

• Strictly necessary cookies: which are essential for the Website to function;
• Functional cookies: which remember your preferences; and
• Analytics cookies: which help us understand how Users interact with the Platform, so that we can improve the Services.

The cookies we deploy are limited to those necessary for the operation of the Platform, user experience, and internal analytics. Disabling strictly necessary cookies will impair your ability to use the Services. Marketing emails sent by us may include tracking pixels that allow us to determine whether an email has been opened.

Where applicable law requires your consent before we place non-essential cookies, we will present a consent mechanism on your first visit to the Website.

SubmitAbility Technology Pvt Ltd is incorporated and operates in India. Personal data collected from users in the United States and other jurisdictions is transferred to and processed in India. By using the Platform, you acknowledge this international transfer of your personal data.

We implement appropriate safeguards for cross-border transfers as required by applicable laws. Where we share data with third-party processors as described above, the terms and conditions of the respective processor will govern their handling of data.

We implement appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include access controls and encrypted transmissions over our cloud infrastructure.

Subject to applicable law, you have the following rights in relation to your personal data:

You may request access to your personal data and obtain a copy of it. You may request correction of any inaccurate, incomplete, or outdated information we hold about you. You may request deletion of your personal data when it is no longer needed for the purposes for which it was collected, or where you withdraw your consent, subject to applicable legal retention requirements. You may withdraw your consent at any time where processing is based on consent, although this will not affect processing already carried out and may impact your ability to use certain Services. Where applicable law provides for a right to nominate another person to exercise your data protection rights on your behalf in the event of your death or incapacity, you may register a nominee by contacting us at support@ascentability.com.

You may also raise any complaints regarding your personal data with our Grievance Officer as described in this Privacy Policy.

We will respond to all verified rights requests in the manner and within the timeframes prescribed under applicable law. Please refer to the Regional Supplemental Privacy Policy below for jurisdiction-specific rights and escalation pathways.

Our Services are intended for individuals who are 18 years of age or older. We do not knowingly collect, use, or disclose personal data from individuals under the age of 18. Processing of personal data of children requires verifiable parental consent. If you become aware that a person under the age of 18 has provided personal data to us through the Platform, please contact us at support@ascentability.com. We will investigate and, where appropriate, delete such data promptly.

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable regulatory requirements, or Platform features. We will publish the updated Privacy Policy on the Platform with a revised Effective Date. Your continued use of the Services after any modifications constitutes your acceptance of the revised Policy.

If you encounter a violation of any of our Terms and Conditions or this Privacy Policy, or if you have any questions about how we handle your personal data, you may contact our Grievance Officer whose contact details are given below:

Grievance Officer / Data Protection Officer: Vishal Shah
Email: vishal@ascentability.com
Address: 4A Readymoney Terrace, Dr. Annie Besant Road, Worli, Mumbai-400018

If you are not satisfied with our response, you may make a complaint the data protection authority as may be competent under applicable law.

This Privacy Policy shall be interpreted, construed, and enforced in accordance with applicable law. Any disputes arising out of or in connection with this Privacy Policy shall be subject to the jurisdiction of the courts in Mumbai, India or authorities as determined by the applicable law.

The following shall apply to users in specific jurisdictions.

India
If you are located in India, the processing of your personal data is governed by the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025 (“DPDP Rules”). Your consent to the collection and processing of your personal data is obtained through a clear affirmative action at the time of registration and is free, specific, informed, unconditional, and unambiguous. You may withdraw your consent at any time by contacting us at support@ascentability.com. In addition to the rights set out in the main body of this Privacy Policy, you have the right to obtain a summary of your personal data being processed and the processing activities undertaken in relation to your data; to have your personal data erased once the purpose of collection has been fulfilled or upon withdrawal of consent, subject to applicable legal retention requirements; to nominate another individual to exercise your data protection rights on your behalf in the event of your death or incapacity by contacting us at the details provided in the Grievance Redressal section above; and to raise a grievance with the Grievance Officer as specified above, and, if unresolved, escalate to the Data Protection Board of India.

United States
If you are a resident of the United States, your personal data may be additionally protected under the privacy laws of your state. Depending on the state in which you reside, you have the right to confirm whether we are processing your personal data and to access it; to correct any inaccuracies in the personal data we hold about you; to delete personal data you have provided to us or that we have obtained about you; to obtain a portable copy of your personal data; to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; and, if you are a resident of California, to limit our use and disclosure of sensitive personal information to what is necessary to perform the Services. We will not discriminate against any user for exercising their privacy rights. If we decline a request, we will inform you of the reason and provide information on how to appeal our decision; unresolved appeals may be escalated to the Attorney General of your state or, for California residents, to the California Privacy Protection Agency. We will respond to all verified rights requests within the period prescribed under the law applicable to your state of residence. To submit a rights request or to exercise any of the above rights, please contact us at support@ascentability.com.