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Privacy policy

Privacy Policy

    Introduction

    2nd Careers Inc. (“the Company”), including its subsidiaries and affiliates (collectively referred to as "Company," "we," "us," or "our"), is committed to safeguarding the privacy and security of personal data in accordance with applicable laws and regulations. This Privacy Policy (hereinafter referred to as the "Policy") outlines how we collect, use, disclose, and protect your personal information. We are dedicated to ensuring that personal data is handled lawfully and responsibly to uphold the trust of our stakeholders, customers, and the community. By implementing this Policy, we aim to manage personal data in a manner that aligns with legal requirements and respects individual privacy.

    Aim

    The aim of this Policy is to safeguard the personal data of individuals associated with our organization. This Policy provides a comprehensive overview of the principles and practices that the Company follows in processing personal data ("Personal Data") of individuals who visit, use, interact with, or transact through our website or mobile application, including guest users and browsers (collectively referred to as "you" or "user"). By accessing or using the Company Platform, you acknowledge and consent to the terms set forth in this Privacy Policy, as well as our Terms of Service. We encourage you to periodically review this Privacy Policy to stay informed about any updates or changes regarding the collection, use, and disclosure of your information.

    Purpose and Scope

    The purpose of this Policy is to outline how the Company collects, uses, and shares information about you through our online interfaces, including but not limited to our website and mobile applications (collectively referred to as the "Platform"). This Policy also details how the Company ensures the security of your data, manages data transfers, and processes requests from data subjects.

    This Policy applies to all systems, personnel, and processes within the Company's information systems, including board members, directors, employees, and third parties who have access to personal data managed by the Company. 

    The Company operates a Platform designed to connect Professionals over the age of 50 seeking employment with Employers and to facilitate upskilling through courses provided by Partners (collectively referred to as "Services"). This Privacy Policy governs all Services provided by the Company unless explicitly stated otherwise.

    Types of Personal Data Collected 

    The personal data we collect depends on your interactions with 2nd Career, the services you use, and applicable legal requirements. By using our services, you consent to the collection and use of your information as outlined in this Privacy Policy. This data may include personal identification details, contact information, demographic details, and information related to your education, employment, and use of our platform. Additionally, we may collect data on your online activity, device information, and preferences to enhance our services.

    Sources of data collection

    The Company collects data from various sources, including directly from users and through interactions with our websites and services.

    Direct Data: We collect data directly from you when you create or update your profile, interact with our platform, apply for programs or services, participate in assessments, provide feedback, or register for events.

    Third-Party Data: We also receive personal data from third-party sources, such as employers, educational partners, recruitment agencies, social media platforms, and websites you interact with through cookies or pixel tags.

    Purpose of Collecting Personal Data 

    We collect personal data to fulfil several essential purposes, including responding to inquiries, processing requests related to job opportunities, and managing course enrolments. The data is used to facilitate job placements, track educational activities such as attendance and assessments, and send updates about new services, programs, or events. Additionally, we use personal data to enhance user interactions, improve our offerings based on feedback, and ensure compliance with security policies, legal requirements, and external regulations. Data is also used for business operations, including auditing, planning, dispute resolution, and maintaining necessary legal records.

    Cookies 

      We use cookies on our website to enhance your browsing experience. Cookies are small text files placed on your device that collect information about your internet activity. These cookies help us recognize users, analyze website performance, and improve our services. We may also allow third-party companies, like advertising partners, to set cookies to track your interests and deliver tailored ads.
    • You can manage or delete cookies through your browser settings, but disabling certain cookies may affect your website experience. For more information on managing cookies, please consult your browser’s help section.

    Data Analytics

    We use data analytics tools to evaluate visitor engagement with its website content. Tools such as MixPanel help track user interactions and optimize services. These Analytics tool collects information like pages viewed and navigation patterns to enhance user experience. The tool for data analytics can vary/change at any point in the future. 

    Aggregated Data 

    "Aggregated Data" refers to information that has been processed and combined in such a manner that all personally identifiable details have been removed. This data is generalized and anonymized to provide broad, non-specific insights. Aggregated Data does not contain any information that can be used to identify an individual.

    The Company utilizes Aggregated Data to conduct internal analyses, enhance our services, and for commercial purposes. We aggregate Personal Data with other data sources on an anonymous basis to produce insights that are shared with our affiliates, subsidiaries, and business partners. This sharing is intended for purposes including, but not limited to, strategic planning, marketing, and improving our services.

    Aggregated Data may be shared with our business partners and service providers who assist in our operations and marketing efforts. However, since Aggregated Data does not include Personal Data, it remains devoid of any information that could identify specific individuals.

    Data protection principles 

    We are committed to adhering to the highest standards of data protection. When processing Personal Data, we ensure that third-party processors provide adequate assurances of data security. Our approach to data protection is governed by the principles including but not limited to Purpose Limitation, Fairness, Lawfulness, Transparency, Data Minimization, Accuracy, Security. 

    Legal basis for processing your Personal Data

    We process Personal Data based on various lawful grounds, depending on the specific activity and applicable law. These include processing necessary for the performance of a contract, such as facilitating user engagement, job placements, or course deliveries, and for complying with legal obligations, like tax reporting and responding to government requests. We may also process data for our legitimate business interests, such as improving services, securing our platform, and managing user relationships, provided these interests do not override individual rights. In some instances, processing may be necessary to protect vital interests, such as in emergencies, or for tasks in the public interest. Additionally, we may rely on your consent where required, such as for marketing communications or handling special categories of data, and you can withdraw this consent at any time.

    Consent 

    The Company may obtain your consent to collect, store, and use certain types of Personal Data when required by law. Your consent is fundamental to our processing activities, and we aim to ensure that it is obtained, managed, and respected in accordance with the highest legal standards.

      Obtaining Consent: We will seek your express consent before collecting or using your Personal Data for purposes that require such consent by law. Once express consent is obtained for a specific purpose, the Company is authorized to collect or receive any supplementary information necessary to fulfill that same purpose. Should a new purpose for data usage arise, express consent will again be sought.
    • Implied Consent: In certain circumstances, your consent may be implied. For example, consent may be inferred when you are provided with notice and a reasonable opportunity to opt out of your Personal Data being used for purposes such as mail-outs, marketing of new services or products, and similar activities, and you choose not to opt out. Implied consent enables us to proceed with these activities under the assumption that you do not object.
    • Withholding or Withdrawing Consent: You have the right to withhold or withdraw your consent at any time, subject to certain legal or contractual exceptions. For instance, if your Personal Data is necessary for the performance of a service you have requested or the fulfilment of a legal obligation, withholding or withdrawing consent may affect our ability to provide you with that service. In such cases, you will be informed of the consequences of withholding or withdrawing consent.
    • Consent by Usage: By using this website, acknowledging this Privacy Policy, or voluntarily providing us with your Personal Data, you consent to the collection, storage, and processing of your Personal Data in accordance with this Privacy Policy and our Terms of Service. This consent extends to all processing activities outlined within these documents, and your continued use of our platform signifies your acceptance of these terms.
    • Consequences of Refusal or Withdrawal: If you refuse or withdraw your consent, or if you choose not to provide us with the necessary Personal Data, we may be unable to offer you the full range of services available on our platform. You will be informed of the specific services affected by your decision and provided with alternative options where possible.

    Advertising and Marketing 

      The Company is committed to offering you control and transparency regarding the use of your Personal Data for marketing and advertising purposes. Our approach to advertising and marketing is guided by your preferences and legal requirements.

    • Marketing Communications: You will receive marketing communications from the Company if you have explicitly requested information from us, provided your details, and consented to receive such communications. This includes updates about our services, offers, and events that we believe may be of interest to you based on your interactions with our platform.
    • Personalized Marketing: We may utilize your Personal Identification, Identity, Contact, Electronic, and User-generated Data to create a personalized marketing experience. By analyzing this data, we form a view of your preferences, interests, and potential needs. This analysis helps us to tailor our services, offers, and advertisements to better suit your interests, ensuring that the marketing communications you receive are relevant and valuable to you.
    • Third-Party Advertising: The Company engages with third-party advertising partners to display ads on our behalf across the internet, social networking sites, and blogs. These third parties may collect Personal Data related to your visits to our platform and your interactions with our products and services. This data is then used to target advertisements that are more likely to be relevant to you based on your browsing behavior and preferences.
    • Trademark and Logo: You grant the Company the right to use your name, trademarks, service marks, logos, or any other identifying symbols or indicia ("Client Marks") associated with the Client Content for the purpose of promoting, marketing, and distributing your courses and related materials on the Platform. This license includes the right for the Company to use the Partner Marks in connection with its marketing, promotional materials, advertisements, and other business-related activities

    Disclosure of Personal Data 

    We are dedicated to protecting the confidentiality of your Personal Data and do not sell, trade, or rent it to third parties. However, we may share aggregated demographic data that is non-identifiable with business partners and advertisers. Personal Data may be shared with affiliates, group companies, or trusted third parties for internal operations, career services, and job placements. This includes sharing your information with candidates when you post jobs or with recruiters when your resume matches their job vacancies. Additionally, we may disclose your data to government authorities, law enforcement, legal advisors, or external auditors when required by law or to protect our rights. Personal Data may also be shared in cases of mergers, acquisitions, or business transfers, and with suppliers, subcontractors, and service providers essential for business operations. 

    User Responsibility: By using the information shared with you through our Platform, you agree to use it solely for the intended purposes related to our Services. Any misuse of such information for personal or other business purposes will result in the immediate deletion of your account and a permanent block from accessing the Platform.

    Data subject rights 

      In certain jurisdictions, individuals are granted specific rights concerning the processing of their Personal Data. This is particularly applicable if you or any of our subsidiaries or affiliates with which you interact is located within the European Union. However, these rights may also be recognized in other jurisdictions. It is important to note that these rights are not universally available and may not apply in all contexts. Depending on the applicable law, you may have the following rights:

      Request access to your Personal Data.
    • Request correction of your Personal Data (should your Personal Data be inaccurate, incomplete, or obsolete).
    • Request deletion of your Personal Data
    • Withdraw your consent to processing (where we processed Personal Data on the basis of your consent). Please note that withdrawing your consent applies only to future processing activities.
    • Object to the processing of your Personal Data.
    • Request restrictions on the processing of your Personal Data.
    • Request the transfer of your Personal Data to you or a third party.
    • Opt-out of certain transfers to third parties.
    • Request to opt out of automated decision making.

    To exercise a right that you believe you may be entitled to under applicable law, please write to us at info@2ndcareers.com. We may need to verify your identity before we fulfil your request.

    Please be aware that the conditions and extent of these rights can vary depending on the jurisdiction. Our response and any subsequent processing of your request will be governed by the applicable laws relevant to the specific rights being exercised. We may refuse requests that are unreasonably repetitive, require disproportionate technical effort, compromise the privacy of others, interfere with ongoing investigations, or are otherwise impractical. It is our policy to ensure that you are not discriminated against for exercising any of your rights.

    If you believe that our processing of your Personal Data violates applicable data protection laws, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority.

    Children’s Data

    The Company is committed to the privacy and protection of children’s data. Our platform and services are not intended for use by children. The age at which an individual is considered a child varies across jurisdictions:

      Under the GDPR: A child is defined as anyone aged 16 years or below.
    • In the United Kingdom: A child is anyone aged 13 or below.
    • In India: The valid age for providing consent is 18 years.

    As a general policy, the Company does not collect, process, store, use, disseminate, or transfer the Personal Data of children.

      Employers: Access to our platform is restricted to Professionals aged 50 years and above.
    • Employers or Partners: You acknowledge that you are above the age of 18 years to use our services.

    The Company does not knowingly collect or intend to collect children’s data. If we become aware that we have inadvertently collected Personal Data from a child, we will take immediate steps to delete that information from our records.

    Data Security 

    We implement stringent security measures to protect Personal Data, including technical and organizational safeguards to prevent unauthorized access, loss, or damage. Employees are required to securely store confidential data, verify its accuracy, and use strong password protection. Portable devices, if necessary, must be encrypted to protect data. Non-compliance with these policies may result in disciplinary action.

    Additionally, 2nd Career ensures third-party service providers maintain equivalent data protection standards. While every effort is made to safeguard data, the company cannot guarantee complete security and disclaims liability for third-party cloud service mishandling.

    International Data Transfers

    2nd Career operates primarily on servers based in the United States, due to the global nature of its business, your Personal Data may be transferred to and stored in other countries where 2nd Career or its partners operate. These international transfers may involve jurisdictions with different data protection laws.

    To ensure compliance, 2nd Career enters into data transfer agreements, such as Standard Contractual Clauses, and Data Processing Agreements where required. The company ensures that any transfer of Personal Data to public authorities is necessary, proportionate, and limited to what is required. 2nd Career is committed to ensuring secure and compliant international data transfers.

    Record management 

    Records management encompasses a set of activities essential for systematically controlling the creation, distribution, use, maintenance, and disposition of recorded information, which serves as evidence of business activities and transactions. Effective records management is crucial for ensuring compliance with information laws, maintaining the quality of records, and ensuring that Personal Data is retained only as long as necessary for its original purpose, thereby supporting the principle of data minimization.

    Organizations and responsibilities 

    The Company has a Data Protection Officer (“DPO”), who monitors, and ensures that the Company adheres to data protection principles and laws, Any personal data is shared with the employees on a “need to know basis”. All the company employees, Partners, and Employers are obligated to keep the data confidential. 

    Conflicts of law

    This Policy is designed to comply with the laws and regulations of the jurisdictions in which the Company operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail. The Company will ensure that its data protection practices align with the most stringent legal requirements applicable to its operations, prioritizing legal compliance over internal policy where necessary.

    Retention of Personal Data

    The Company retains Personal Data no longer than necessary for the purposes for which it was collected. The duration of retention is determined by the specific purposes of data collection and usage, and in compliance with applicable laws, or as required to establish, exercise, or defend legal rights. Users may exercise their rights as detailed herein. Should an extension of the retention period be necessary, the Company will seek explicit consent from the affected individuals. Moreover, data may be disposed of prior to the expiration of the retention period if the purpose for which it was collected is fulfilled.

    Data protection procedures 

    At 2nd Career, we are committed to safeguarding your personal data. The Company team members are responsible for managing and protecting this information, ensuring clear accountability throughout the company. Our employees receive regular training on securely handling data and maintaining confidentiality. We also ensure that your consent is obtained in a clear and informed manner. In the event of a significant data breach, we will notify the relevant authorities to inform you directly if your rights may be at risk. Additionally, we take the necessary precautions when transferring personal data internationally, ensuring compliance with all applicable legal protections., 

    Breach Notification 

    In the event of a data breach likely to result in a risk to individuals' rights and freedoms, the Company will notify the relevant supervisory authority within a reasonable time upon becoming aware of the breach. If the breach poses a high risk to individuals, those affected will be informed directly. Should the breach warrant public notification, the Company will do so without undue delay.

    External Link on our Platform 

    2nd Career may provide links to third-party websites ("Third Party Sites") for user convenience. However, 2nd Career does not share Personal Data with these Third-Party Sites unless there is a lawful basis for doing so, and it does not endorse or take responsibility for their privacy practices. Users are encouraged to review the privacy policies of any Third-Party Sites they visit to understand how their Personal Data may be handled. 

    No Impersonation 

    Users of the Company’s platform must use their actual names and provide accurate contact information. Misrepresentation or impersonation of another person is strictly prohibited. The Company reserves the right to terminate accounts found in violation of this policy and pursue appropriate legal action.

    Trust and safety 

    The Company prioritizes the trust and safety of all its users. The platform strictly prohibits content promoting abuse, fraud, multi-level marketing (MLM), job openings that charge fees, suicide, self-harm, or content intended to shock or disgust users. The Company will take stringent action against users posting such content.

    Use of this platform and our Terms of Service 

    This website is the property of the Company. The use of the platform is governed by the Company’s Terms of Use and this Privacy Policy, which together form a binding agreement. By using the platform, users indicate their acceptance of these terms.

    Updates to the policy 

    The Company may update this Privacy Policy periodically. Reasonable steps will be taken to inform customers, business partners, and other data subjects affected by any revisions. The updated Privacy Policy will be posted on this page and, where necessary, communicated via email.

    Data Protection Officer

    In compliance with applicable laws, The Company has appointed a Data Protection Officer (DPO). The DPO can be reached at the following details:

    Name: Shanthi Naresh 

    Email Address: shanthi@2ndcareers.com