Please read this Policy carefully prior to accessing our Platform and using any of the services or products offered therein. If you have any questions, please contact us at the contact information provided below.
“Personal Information” shall mean the information which identifies a Learner i.e., first and last name, identification number, email address, age, gender, location, photograph and/or phone number provided at the time of registration or any time thereafter on the Platform.
“Sensitive Personal Information” shall include (i) passwords and financial data (except the truncated last four digits of credit/debit card), (ii) health data, (iii) official identifier (such as biometric data, aadhar number, social security number, driver’s license, passport, etc.,), (iv) information about sexual life, sexual identifier, race, ethnicity, political or religious belief or affiliation, (v) account details and passwords, or (vi) other data/information categorized as ‘sensitive personal data’ or ‘special categories of data’ under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, General Data Protection Regulation (GDPR) and/or the California Consumer Privacy Act (CCPA) (“Data Protection Laws”) and in context of this Policy or other equivalent/similar legislations.
Usage of the term ‘Personal Information’ shall include ‘Sensitive Personal Information’ as may be applicable to the context of its usage.
2. INFORMATION WE COLLECT:
We may collect both personal and non-personal identifiable information from You in a variety of ways, including, but not limited to, when You visit our Platform, register on the Platform, and in connection with other activities, services, features or resources we make available on our Platform. However, please note that-
We may collect and use Your Personal Information for the following purposes:
(a) To provide access to our Platform and/or the services/products offered therein: We use Your information as collected by us to allow You to access the Platform and the services/products offered therein, including without limitation to provide customer service, fulfil purchases through the Platform, verify User information and to resolve any glitches with our Platform. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between You and us.
(b) To improve our Platform and maintain safety: We use Your information to improve and customize the Platform and services/products offered by us. Further, we also use Your information to prevent, detect, investigate, and take measures against criminal activity, fraud, misuse of or damage to our Platform or network, and other threats and violations to a third party's or our rights and property, or the safety of our Users, or others. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between You and us.
(c) To communicate with You or market our services/products: We may use the email address submitted by You to communicate with You about Your orders on our Platform, our offers, new products, and services or even receive Your feedback on the Platform or any services/products offered therein. It may also be used to respond to Your inquiries, questions, and/or other requests. If at any time You would like to unsubscribe from receiving future emails, please write to us at the contact information provided below. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between You and us.
(d) Service Providers: We may employ third-party companies and individuals due to the following reasons:
We want to inform users of this Service that these third parties have access to their Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.
We do not use Personal Information for making any automated decisions affecting or creating profiles other than what is described in this Policy.
We do not sell, trade, or otherwise exploit Your personal-identifiable information to others. Limited to the purposes stated hereinabove, we may share generic aggregated demographic information not linked to any personal identifiable information regarding visitors and Users with our business partners and trusted affiliates.
4. YOUR CHOICES:
(a) Limit the information You provide: You always have the option to choose the information You provide to us, including the option to update or delete Your information. However, please note that lack of certain information may not allow You access to the Platform or any of its features, in part or in full. For example: information required for Your registration on the Platform.
(b) Limit the communications You receive from us: Further, You will also have the option to choose what kind of communication You would like to receive from us. However, there may be certain communications that are required for legal or security purposes, including changes to various legal agreements, that you may not be able to limit.
(c) Reject Cookies and other similar technologies: You may reject or remove cookies from Your web browser; You will always have the option to change the default settings on Your web browser if the same is set to ‘accept cookies’. However, please note that some of the services/products offered on the Platform may not function or be available to You, when the cookies are rejected, removed or disabled.
5. YOUR RIGHTS:
In general, all Learners have the rights specified herein this section. However, depending on where you are situated, you may have certain specific rights in respect of your Personal Information accorded by the laws of the country you are situated in. To understand Your rights, please refer to the Country-Specific Additional Rights below.
If you are a Learner, you may exercise any of these rights by using the options provided to you within the Platform upon your login. If however, you are facing any issues or require any clarifications, you can always write to us at the address noted in the ‘Grievances’ section below, and we will address your concerns to the extent required by the applicable law.
(a) Right to Confirmation and Access: You have the right to get confirmation and access to your Personal Information that is with us along with other supporting information.
(b) Right to Correction: You have the right to ask us to rectify your Personal Information that is with us that you think is inaccurate. You also have the right to ask us to update your Personal Information that you think is incomplete or out-of-date.
(c) Right to be Forgotten: You have the right to restrict or prevent the continuing disclosure of your Personal Information under certain circumstances.
(d) Right to Erasure: If you wish to withdraw/remove your Personal Information from our Platform, you have the right to request erasure of your Personal Information from our Platform. However, please note that such erasure will remove all your Personal Information from our Platform (except as specifically stated in this Policy) and may result in the deletion of your account on the Platform permanently, and the same will not be retrievable.
Remember, you are entitled to exercise your rights as stated above only with respect to your information, including Personal Information, and not that of other Learners. Further, when we receive any requests or queries over email to the address specified in the ‘Grievances’ section below, then, as per the applicable Data Protection Laws, we may need to ask you a few additional information to verify your identity in association with the Platform and the request received.
6. PROTECTION OF YOUR INFORMATION:
We take all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of Personal Information or such other data on the Platform. Our disclosure of any such information is limited to –
(a) our employees, contractors and affiliated organizations (if any) that (i) need to know that information in order to process it on our behalf or to provide services available on our Platform, and (ii) that have agreed not to disclose it to others.
(b) a response to a court order, or other governmental request. Without imitation to the foregoing, we reserve the right to disclose such information where we believe in good faith that such disclosure is necessary to –
(i)comply with applicable laws, regulations, court orders, government and law enforcement agencies requests;
(ii)protect and defend a third party's or our rights and property, or the safety of our users, our employees, or others; or
To the extent permitted by law, we will attempt to give You prior notice before disclosing Your information in response to such a request.
7. THIRD PARTY WEBSITES
8. CROSS-BORDER DATA TRANSFER
Your information including any Personal Information, and user image information is stored, processed, and transferred in and to the Amazon Web Service (AWS) servers and databases located in India, including https://s3-ap-southeast-1.amazonaws.com/. We may also store, process, and transfer information in and to servers in other countries depending on the location of our affiliates and service providers.
Please note that these countries may have differing (and potentially less stringent) privacy laws and that Personal Information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies, and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process.
If you use our Platform from outside India, including in the USA, EU, EEA, and UK, your information may be transferred to, stored, and processed in India. By accessing our Platform or otherwise giving us information, you consent to the transfer of information to India and other countries outside your country of residence.
9. DURATION FOR WHICH YOUR INFORMATION IS STORED
We will retain Your information for as long as it is required for us to retain it for the purposes stated hereinabove, including for the purpose of complying with legal obligations or business compliances.
Further, please note that we may not be able to delete all communications or photos, files, or other documents publicly made available by you on the Platform (for example: comments, feedback, etc.), however, we shall anonymize your Personal Information in such a way that you can no longer be identified as an individual in association with such information made available by you on the Platform. We will never disclose aggregated or de-identified information in a manner that could identify you as an individual.
Note: If you wish to exercise any of your rights (as specified in ‘Your Rights’ section below) to access, modify and delete any or all information stored about you, then you may do so by using the options provided within the Platform. You can always write to us at the email address specified in the ‘Grievances’ section below
We may modify, revise or change our Policy from time to time; when we do, we will revise the ‘updated date’ at the beginning of this page. We encourage You to check our Platform frequently to see the recent changes. Unless stated otherwise, our current Policy applies to all information that we have about You.
If you have any questions about this Policy, wish to exercise your rights, concerns about privacy or grievances, please write to us with a thorough description via email.
COUNTRY SPECIFIC ADDITIONAL RIGHTS
Your Rights: If you are located in India, you may have the following rights under the Personal Data Protection Bill (PDPB) when it becomes legislation. All requests can be made by using the option provided to you within the Platform upon your login. You may also write to us as stated in the “Grievances” section above, and we will address you concerns to the extent required by law.
Your Rights: If you are located in the United Kingdom (UK) European Union (EU) or European Economic Area (EEA), you have the following rights under the UK and EU General Data Protection Regulation (GDPR) respectively. All requests should be sent to the address noted in the “Grievances” section above, and we will fulfil requests to the extent required by applicable law.
We collect and process Personal Information about you only where we have a legal rationale to do so. The specific legal rationale applied for the same will depend on the type of Personal Information collected and the context in which the same is being processed, including the Services involved.
C. TERMS APPLICABLE IF YOU ARE A CALIFORNIA STATE RESIDENT
If you are a California state resident, then you have the following rights to the extent, and in the manner, set out in the CCPA:
The above rights, the manner in which you can exercise the same and the category of and the manner in which we collect your information, are detailed below.
1. CCPA NOTICE AT COLLECTION:
For purposes of the CCPA, in collecting the information described above, we collect the categories of Personal Information listed below from you:
a. Identifiers: We may collect your name, email address, mobile number, username, unique personal identifier, and Internet Protocol (IP) address. We use Identifiers as set forth in the “How We Use and Share the Information Collected” section of this Policy, like your name, contact information, and device and online identifiers.
b. Characteristics of Personal Information described in the California Customer Records statute: We may collect your name, email address, username, unique personal identifier, and gender. We use Categories of Personal Information described in the California Consumer Records statute as set forth in the ‘How We Use and Share the Information Collected’ section of this Policy.
c. Internet or other electronic network activity information: We collect cookies as described above, We will automatically receive information from your browser and your device, which includes the date and time of your visit to the Platform as well as your location, Internet Protocol (IP) address, domain server, browser type, access time, and data about which pages you visit on the Platform. We use Internet or other electronic network activity information as set forth in the “How We Use and Share the Information Collected” section of this Policy.
d. Geolocation data: We may collect your IP address. We may use Geolocation Data as set forth in the “How We Use and Share the Information Collected” section of this Policy.
e. Audio, electronic, visual or similar information: We may collect your profile picture or other audio or visual information uploaded as content to the Platform. We use audio, electronic, visual or similar information as set forth in the “How We Use and Share the Information Collected” section of this Policy.
f. Inferences: We may make inferences based on the Personal Information collected (such as the likelihood of retention or attrition). We use Inference information as set forth in the “How We Use and Share the Information Collected” section of this Policy.
2. CCPA DATA PRACTICES DURING THE LAST 12 MONTHS:
a. Personal Information collected: As described in this Policy, we have collected the categories of Personal Information listed below during the preceding 12 months:
We have disclosed each category of Personal Information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.
3. CONSUMER RIGHTS AND REQUESTS UNDER THE CCPA
The CCPA gives consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, and sell, and (2) delete certain Personal Information that we have collected or maintained. you may submit these requests to us as described below, and we honor these rights where they apply.
If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (i) treat the request as if it had been submitted in accordance with the designated manner, or (ii) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.
a. Request to Know: As a California resident, you have the right to request: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the categories of sources from which the Personal Information is collected; (4) the categories of Personal Information about you that we have sold and the categories of third parties to whom the Personal Information was sold; (5) the categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling Personal Information; and (7) the categories of third parties with whom we share Personal Information. Our response will cover the 12-month period preceding our receipt of a verifiable request.
b. Request to Delete: As a California resident, you have a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and direct any service providers (as defined under applicable law) to delete your Personal Information from their records. However, we are not required to honour a deletion request if an exemption applies under the law.
c. Submitting a Request:
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