Section 43A of the Information Technology Act, 2000; and
Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPI Rules”)
Personal information is defined under the SPI Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. The SPI Rules further define “sensitive personal data or information” of a person to mean personal information about that person relating to:
financial information such as bank accounts, credit and debit card details or other payment instrument details;
physical, physiological and mental health condition;
name, age, address, e-mail, phone number, date of birth, sexual orientation;
medical records and history;
information received by body corporate under lawful contract or otherwise;
visitor details as provided at the time of registration or thereafter; and
call data records.
How We Collect Information
Information relating to your use of the Services, including, without limitation, any information submitted by you at the time of registering and creating your personal account to access the features of our website and/or Application including without limitation, any information pertaining to a User’s educational background, details of a User’s educational institution, etc.;
Information relating to various courses offered by us (“Courses”), including, without limitation, (a) any exchange of information with the Course instructor or other Users, (b) any data submitted by the User in relation to the Course, including, but not limited to log, lessons, download history, score sheet, tests, reports, assessments, bookmarks, answers and any notes created by the User in relation to the Course, and (c) any data submitted by you to us, online or offline, in relation to the Services;
Information automatically recorded from your browser or mobile device, including standard log files, web beacons, or pixel tags, Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system, and the date, time and screens accessed while using the Services;
Use and Disclosure
Except as otherwise stated above, we may use Data and/or Personal Information to understand and analyze the User demographics, usage trends and preferences of our Users for marketing, analytics and research purposes, to improve the way Services are rendered, to operate, maintain, enhance, and provide all of the features, to communicate with our Users; and provide them with the latest information pertaining to our Services as well as similar or incidental services, including but not limited to targeted advertising, provided by third parties. Such targeted advertising and/or updates could be in the form of notification in the Application, e-mails, SMS, push message alerts whether using the Application or not, etc.
We may send direct mailers for the promotion of new products and services launched by us and other targeted advertisements for third-party entities (“Mailers”) to the User at the e-mail address shared by the User. The User has the option to “opt-out” of these Mailers by way of links provided at the bottom of each Mailer or by sending an e-mail to the e-mail address provided by us. We respect every User’s privacy and in the event that a User chooses to not receive such Mailers, we will take all steps to remove the User from our mailing list.
We enable our Users to share information and resources. If you make your Data or Personal Information available to other Users by posting it on any publically accessible part of the website or to any other User(s) of the Services, it may be collected and used by the recipients without restriction.
If you have used any Social Media account to register with us or elected to have your activity on our Services published to such Social Media account, you are giving us the permission to use, share, and store such Data and/or Personal Information with the concerned Social Media. To control the Data and/or Personal Information that you share, you should review and, if appropriate, modify your privacy settings on such Social Media accounts. You will have the option to determine whether and how you wish to publish your Data and/or Personal Information on your Social Media account through us. Any Data or Personal Information held and stored by such Social Media shall be governed by their respective privacy policies, which you should read and be well versed with.
In the event that we are acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the Data and/or Personal Information that we have collected from Users as part of such merger, acquisition, sale, or other change of control.
We may also disclose Data and/or Personal Information if required to do so by law or in the bona fide belief that such action is necessary to comply with state and central laws applicable to the territory of India or Singapore, or in response to a court order, warrant, judicial or other administrative subpoena. In some cases, we may make such disclosures without first providing notice to our Users.
We also reserve the right to disclose any Data and/or Personal Information that we believe, in good faith, is appropriate or necessary to take precautions against liability; or to protect ourselves from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Services; to fight fraud and credit risk; or to protect our rights, property, or personal safety and that of our Users, or others.
Protection of Children
We also reserve the right to remove, at our sole discretion, any content or material posted by a User which may be of defamatory or sexual nature or offensive to other Users in any manner, and take appropriate legal action against such User in accordance with our Terms and Conditions.
Security and Account Protection
We use certain physical, managerial, and technical safeguards designed to preserve the integrity and security of your Data and Personal Information. Once we receive your Data and/or Personal Information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that we do not ensure or warrant that such Data and/or Personal Information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If we learn of a security breach, then we will attempt to notify you by posting a notice on the website and Application so that you can take appropriate protective steps.
Retention of Information and Cookies
We retain Data and Personal Information that we process on behalf of our Users for as long as we deem appropriate. We will retain and use this Data and/or Personal Information to comply with our legal obligations, resolve disputes, and enforce our agreements with Users, and/or for such period as required by the laws applicable in India.
Copyright and Disclaimer
The copyright in all materials provided on and as part of the Services are held by us, whether or not a copyright notice appears on the document or the screen displaying such information. Please see the Terms and Conditions for further details with regard to copyright of material provided on and as part of the Services.
We make no warranties or representations of any kind concerning the accuracy, suitability, or safety of the information provided through the Services or any linked External Web Services for any purpose. All such information is provided “as is”, and with specific disclaimer of any warranties or merchantability, fitness for a particular purpose, or title.