Privacy Policy

 

 

1.Introduction

<<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.

 2.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 <<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.

3.Purpose and Scope

The purpose of this Policy is to outline how <<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 <<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 <<Company>>’s information systems, including board members, directors, employees, and third parties who have access to personal data managed by <<Company>>. We are committed to ensuring that our employees adhere to this and related policies. When third parties process data on behalf of <<Company>>, we seek assurances that your personal data will be protected in accordance with this Policy.

<<Company>> operates a Platform designed to connect women over the age of 50 seeking employment with job recruiters and to facilitate upskilling through courses provided by Learning Partners (collectively referred to as “Services”). This Privacy Policy governs all Services provided by <<Company>> unless explicitly stated otherwise.

4.Types of Personal Data Collected  

The types of personal data we collect about you are contingent upon the context of your interactions with us, the products and services you use, your location, and applicable laws.

By choosing to use our services, you consent to the collection and use of information as described in this Policy. The personal data collected is utilized for providing and enhancing our services. We will not use or disclose your information except as outlined in this Privacy Policy.

Personal data is stored in personnel files or electronic records (on servers located in India) of <<Company>>. The types of personal data that may be collected and held by the Company include:

    1. Personal Identification Data
      1. First Name, Last name
      2. Job title & Company
      3. Signature
      4. Photographs
    2. Identification Data
      1. Aadhar number and PAN
    3. Financial Data
      1. Bank Account information
      2. Salary Information
      3. Payment gateway account details
      4. E-wallet account details
    4. Personal Characteristics
      1. Age
      2. Gender
      3. Date of Birth
      4. Marital Status
      5. Nationality
    5. Contact Data
      1. Postal address
      2. Email address
      3. Phone number
    6. Education and Recruitment Data
      1. Educational qualification(s)
      2. Working goals
      3. Post-qualification experience
    7. Electronic Identification Data
      1. Login credentials (If you are a registered user)
      2. Visitors IP Data
      3. Date and time of website visit
      4. Pages visited and navigation on the website
      5. Browser being used
      6. County of accessing the website
      7. Language of the browser being used
      8. Words searched for
      9. Pixel tags
    8. Inquiries
      1. Personal Data provided in the form (e.g., Name, Address, Phone Number, Country)
      2. Subject of Inquiry
      3. Personal details (Name on the card, billing address)
      4. Payment details (card numbers, card type)
      5. Recordings of calls with students and users showing interest in our Program.
      6. Information about your interactions with customer service and maintenance interactions with us.
    9. User Generated Data
      1. Projects and Assignments submitted
      2. Peer feedback and grading
      3. Program performance data
      4. Response to quizzes, standalone quizzes, exams, and surveys
      5. Web Cam Recordings (during assessments related to online courses)
      6. Posts made to public forums through our platform
      7. Any other information necessary to ensure conformity with test/ assessment rules, area of interests
    10. Marketing Data
      1. Your preferences in receiving marketing information from us
      2. Your communication preferences
    11. Behavioural Data
      1. Data inferred or assumed information relating to your behaviour and interests based on your online activity on our sites
    12. Device related data
      1. Contact List.
      2. Location Information
      3. Storage Permissions
      4. Camera Permissions
      5. Microphone Permissions

We do not collect any payment information processed by third-party payment gateway providers.

 5.Special Categories of Personal Data 

Special Categories of Personal Data include information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, as well as details about your health and genetic and biometric data.

<<Company>> does not collect or process any Special Categories of Personal Data unless specifically required. Should there be a necessity to collect such data for specific purposes, we will obtain your explicit consent in accordance with this Policy and/or provide details at the point of data collection.

Other legal bases for processing Special Categories of Personal Data may include, as permitted by applicable law:

      1. Scientific or historical research
      2. Employment, or social protection law
      3. Reasons of substantial public interest
      4. Establishment, exercise, or defense of legal claims

If you voluntarily provide or post any Special Categories of Personal Data on our Platform for any other reason, you consent to our processing of such data in compliance with applicable law and this Policy. For more information about our processing of your Personal Data, please contact our Data Protection Officer (DPO).

6.Sources of data collection

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

Data Collected Directly from You:

    1. When you create or update your user profile, including uploading resumes, cover letters, or other career-related documents.
    2. When you engage with our platform’s networking features, such as messaging recruiters or course providers, or participating in forums and discussion boards.
    3. When you apply for scholarships, grants, or referrals offered through our platform or by our partners.
    4. When you participate in online assessments, assignments, or exams related to courses offered by our Learning Partners.
    5. When you browse and interact with our website, including viewing job postings, training courses, or recruiter profiles.
    6. When you provide feedback, complete customer surveys, participate in polls, or interact with our customer service team online.
    7. When you request information or a quote for products or services offered by us, including job placements, training programs, or career services.
    8. When you register for seminars, webinars, workshops, or other outreach initiatives organized by us, our Educational Partners, or our recruiting partners.

Data Collected from third parties:

    1. We may receive personal data such as access or login details, profile pictures, or other textual or visual data from third parties.
    2. We collect information about your visits to our platform and other websites through the use of pixel tags or cookies.
    3. We receive data from recruitment agencies, course providers, and educational institutions with whom we have partnerships or collaborations.
    4. We obtain data from job boards, career websites, or training platforms where your information may be publicly available or shared with us for relevant services.
    5. We receive information from social media platforms if you interact with our services through such platforms or share your profile details.
7.Purpose of Collecting Personal Data

<<Company>> is dedicated to transparency regarding the data we collect, its usage, and the parties with whom it is shared. We collect your Personal Data for the following purposes:

    1. To fulfill or address the purposes for which you provided the information, such as responding to inquiries or processing requests related to job/consulting opportunities and course enrollments, upskilling and generally avail the services under the site.
    2. To share your public profile with prospective employers to facilitate job interviews and employment opportunities.
    3. To manage and process educational activities, including tracking attendance, progress, and completion of courses.
    4. To administer exams, projects, and other assessments. This includes using Personal Data to verify your identity and monitor your performance during assessments to ensure compliance with testing rules and requirements.
    5. To send updates about marketing initiatives, programs, platform maintenance, new services, and events provided by <<Company>> or through third parties, via WhatsApp, email, SMS, phone calls, or other communication channels.
    6. To provide and manage chat room services for user interaction and engagement.
    7. To enhance the quality of our content, products, and services based on user feedback and performance data.
    8. To ensure compliance with security policies, mandatory regulations, and to manage building access.
    9. To provide information to relevant external authorities for tax, social security, and other legal purposes.
    10. Providing information to relevant external authorities for tax, social security and other purposes as legally required;
    11. To conduct surveys and assessments to gauge your satisfaction with our processes, policies, and services.
    12. To set up and maintain accounts and subscriptions with third-party providers of information, research, and communication services.
    13. To make decisions regarding your continued engagement, employment, or membership with <<Company>>.
    14. To handle legal or regulatory disputes, investigations, or claims involving you, <<Company>>, or our partners, including matters related to accidents, negligence claims, and professional discipline.
    15. To monitor the use of our information and communication systems, ensuring compliance with IT and document management policies.
    16. To maintain network and information security, including preventing unauthorized access, malicious software distribution, and ensuring overall system integrity.
    17. For business management, planning, accounting, auditing, and insurance purposes.
    18. To plan or review operational or management options.
    19. To maintain registers and records as required by law or regulation.
    20. To communicate with you, respond to your inquiries, and provide support.
    21. To enhance safety and security, prevent fraud, and protect the rights and property of <<Company>>, our customers, and you.
    22. To enforce applicable terms, conditions, and other policies related to our services.
8.Cookies

Cookies are small text files placed on your device to collect standard internet log information and visitor behavior information. When you access our websites, we may automatically collect information through cookies or similar technologies.

Third-Party Cookies: We may permit third-party advertising companies (such as Facebook, Google, Twitter, Quora, and Bing) to set cookies on our website. These cookies enable these companies to track your activities across various websites where they display advertisements and to record your activities, allowing them to deliver ads that are tailored to your interests. These cookies store data related to the content you view, along with an identifier linked to your device or IP address.

How do we use cookies?

<<Company>> utilizes cookies for several purposes to enhance your experience on our website, including:

    1. User Recognition and Experience Enhancement: To recognize users and improve interactions with our website.
    2. Performance Analysis: To analyze website usage and performance, enabling us to enhance the functionality and delivery of our services.
    3. Service Improvement: To improve the effectiveness of the services and products we offer.

What types of cookies do we use?

There are a few different types of cookies, however, our website uses:

    1. Persistent Cookies: These cookies remain on your device for a set period or until manually deleted. They help us remember your acceptance of our Cookie Policy and other preferences, such as removing the initial cookie message.
    2. Session Cookies: Temporary cookies that are deleted from your device once your web browser is closed. They assist in tracking internet usage during your session.
    3. Analytical/Performance Cookies: These cookies enable us to recognize and count the number of visitors and analyze their navigation on our website, aiding in improvements to the website’s functionality and user experience.
    4. Functionality Cookies: These cookies allow the website to remember your preferences, such as your likes and dislikes, to provide a more personalized experience upon your return.
    5. Targeting Cookies: These cookies record your visits to our website, the pages viewed, and the links clicked. They assist in delivering relevant content and advertisements based on your interests.

How to manage cookies?

Most browsers provide options to refuse or delete cookies. The procedures for managing cookies vary depending on the browser and its version. Please note that disabling certain cookies may impact your ability to access some features of the website.

To remove previously stored cookies, you can manually delete them at any time. However, this action will not prevent the placement of additional cookies unless you adjust your browser settings accordingly.

For detailed instructions on blocking and deleting cookies, you may refer to the following resources:

  1. https://support.google.com/chrome/answer/95647 (Chrome)
  2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox)
  3. https://www.opera.com/help/tutorials/security/cookies/ (Opera)
  4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)
  5. https://support.apple.com/kb/PH21411 (Safari)

Please be aware that these opt-out mechanisms depend on cookies to remember your preferences. If you delete your cookies, use a different device or browser, you will need to repeat the opt-out process. Additionally, opting out of interest-based advertisements will not eliminate all ads but will only exclude ads tailored to your interests.

 9.Data Analytics 

<<Company>> employs various analytics tools and search information providers to evaluate how visitors engage with content on our website. This includes using services such as Google Analytics and Facebook Custom Audiences to track interactions and optimize our offerings.

Google Analytics: We use Google Analytics to analyze website traffic and user behavior. Google Analytics collects data regarding your visit to our website, including pages viewed, time spent, and navigation patterns. This information helps us understand user interactions and improve our services.

Facebook Custom Audiences: We utilize Facebook Custom Audiences to display tailored advertisements to users based on their interactions with our websites or Facebook applications. This service helps us to deliver personalized ads and measure their effectiveness.

Opt-Out Options:

  1. Google Analytics: If you prefer not to have your visit data collected by Google Analytics, you can opt-out by installing the Google Analytics Opt-Out Browser Add-On.
  2. Facebook Custom Audiences: To opt-out of receiving targeted ads through Facebook Custom Audiences, you may adjust your ad settings on Facebook by visiting Facebook’s Opt-Out Page.

For further information on how these services use technologies, please refer to the respective privacy policies:

  1. Google’s Privacy Policy
  2. Adobe’s Privacy Policy
  3. Facebook’s Privacy Policy
10.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.

<<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.

11.Data protection principles

At <<Company>>, we are committed to upholding the highest standards of data protection. When third parties process Personal Data on our behalf, we strive to ensure that these third parties provide adequate assurances regarding the safeguarding of such data. We acknowledge our responsibility for the processing, management, regulation, storage, and retention of all Personal Data, whether in manual records or electronic formats.

<<Company>> adheres to the following data protection principles in the handling of Personal Data:

    1. Fairness, Lawfulness, and Transparency: Personal Data will be processed fairly, lawfully, and transparently. We will provide clear information about the purposes and methods of processing to ensure transparency with data subjects.
    2. Purpose Limitation: Personal Data will be collected only for specific, explicit, and legitimate purposes. We will not process Personal Data beyond the scope of these purposes.
    3. Data Minimization: Personal Data will be adequate, relevant, and limited to what is necessary for the purposes of processing. We will ensure that only the minimum amount of data required is collected and used.
    4. Accuracy: Personal Data will be kept accurate and up-to-date. We will take all reasonable steps to rectify or erase any inaccurate or incomplete data promptly.
    5. Storage Limitation: Personal Data will not be retained for longer than necessary for the purposes for which it was collected. We will establish and adhere to retention periods in line with applicable legal and regulatory requirements.
    6. Security: Personal Data will be processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage. We will implement appropriate technical and organizational measures to safeguard Personal Data.
    7. Compliance with International Data Transfer Laws: Personal Data will be transferred internationally in compliance with relevant laws and procedures governing international data transfers. We will ensure that any cross-border transfers of Personal Data adhere to applicable legal requirements.
12.Legal basis for processing your Personal Data

<<Company>> recognizes that certain jurisdictions require a lawful basis to justify the processing of Personal Data. The lawful basis upon which we rely may vary depending on the specific processing activity undertaken. The following are the legal bases <<Company>> may rely upon, as permitted under applicable law, to process your Personal Data:

    1. Processing is necessary for the negotiation, execution, or performance of a contract to which you are a party, or to take steps at your request before entering into such a contract. This includes activities such as facilitating your engagement with our services, connecting job seekers with potential employers, and enabling course providers to deliver educational content.
    2. Processing is necessary to comply with our legal and regulatory obligations. This includes processing your data for purposes such as tax reporting, responding to lawful requests from governmental authorities, and complying with legal mandates in the jurisdictions where we operate.
    3. Processing is necessary for the purposes of the legitimate interests pursued by <<Company>> or by a third party, provided these interests are not overridden by your interests or fundamental rights and freedoms. Our legitimate interests include, but are not limited to, conducting our business activities, improving and personalizing our services, securing our platforms, managing relationships with users, and carrying out direct marketing activities.
    4. Processing is necessary to protect your vital interests or those of another natural person. This basis applies in situations where processing is required to protect your health or safety, such as in emergency situations.
    5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in <<Company>>. This may include activities related to public safety, social protection, and other tasks that serve the broader community.
    6. Processing is based on your explicit consent, where such consent is required by law. You have the right to withdraw your consent at any time, which will not affect the lawfulness of processing based on consent before its withdrawal. Consent may be sought for activities such as receiving marketing communications, participating in surveys, or processing special categories of Personal Data where applicable.
13.Consent

<<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.

    1. 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, <<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.
    2. 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.
    3. 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 fulfillment 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.
    4. 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.
    5. 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.
14.Advertising and Marketing

<<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.

    1. Marketing Communications: You will receive marketing communications from <<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.
    2. 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.
    3. Third-Party Advertising: <<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.
    4. Opt-Out Option: We respect your right to control the marketing communications you receive. If you receive electronic direct marketing communications from us, each communication will include an option to opt-out. Once you opt-out, your preference will be recorded, and we will cease to send you further marketing communications of that nature. However, please note that opting out of marketing communications does not prevent you from receiving essential communications related to the services you have engaged with or requested from <<Company>>.
15.Disclosure of Personal Data

<<Company>> is committed to maintaining the confidentiality of your Personal Data and does not sell, trade, or rent your personal identification information to any third party. We may, however, share generic aggregated demographic information that is not linked to any personally identifiable information with our business partners, trusted affiliates, and advertisers for the purposes outlined in this Privacy Policy.

We do not disclose, transfer or share your personal information with others except with:

    1. We may share your Personal Data with our affiliates and group companies as required for internal business operations, administrative purposes, and to provide services aimed at enhancing your career prospects.
    2. When you post jobs on the <<Company>> Platform on behalf of a company, your information may be shared with candidates who apply, provided that their resume matches the job requirements. By registering on the Platform and consenting to this Privacy Policy, you agree to such sharing of information.
    3. If we determine that your resume matches a job description or vacancy on our Platform, we may forward your resume to the relevant recruiter. By using our services, you consent to us contacting you or sharing your resume with potential recruiters.
    4. We may disclose your Personal Data to third parties, including enforcement, regulatory, and judicial authorities, in the following situations: a) To comply with court orders, legal processes, or to establish or exercise our legal rights or defend against legal claims. b) To investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person. c) To enforce our Terms of Service or as required by law.
    5. In the event of a merger, acquisition, financing, or sale of assets, or any other situation involving the transfer of some or all of our business assets, we may disclose Personal Data to those involved in the negotiation or transfer.
    6. We may share your Personal Data with government bodies, including tax and social security authorities, to comply with applicable laws (including employment and tax laws), obtain licenses or approvals, or respond to requests during audits or assessments.
    7. We may share your Personal Data with suppliers, subcontractors, and service providers to maintain an efficient and commercially viable business. This includes sharing data with technology, telecom, and internet providers as needed for our operations.
    8. We may share your data with professional advisers, consultants, employment, and recruitment agencies for purposes such as background verification, reference checks, benefits administration, payroll management, disciplinary and grievance procedures, and maintaining emergency contact details.
    9. We may disclose your Personal Data to our legal advisors and external auditors for legal advice and to conduct business audits.
    10. We may share your Personal Data with service providers for business continuity management and contingency planning in the event of business disruptions.
    11. We may share certain data with companies to establish memberships, participate in digital wallets, payment services, or rewards programs.

Third-Party Compliance: We require all third parties to respect the security of your Personal Data and to process it in accordance with the law. Third-party service providers are not permitted to use your Personal Data for their own purposes and may only process it for specified purposes as per our instructions.

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.

16.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:

    1. Request access to your Personal Data.
    2. Request correction of your Personal Data (should your Personal Data be inaccurate, incomplete, or obsolete).
    3. Request deletion of your Personal Data
    4. 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.
    5. Object to the processing of your Personal Data.
    6. Request restrictions on the processing of your Personal Data.
    7. Request the transfer of your Personal Data to you or a third party.
    8. Opt-out of certain transfers to third parties.
    9. 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 ___________ . We may need to verify your identity before we fulfill 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.

17.Children’s Data

<<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, <<Company>> does not collect, process, store, use, disseminate, or transfer the Personal Data of children.

  • Job Seekers:

<<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.

18.Data Security

<<Company>> is committed to implementing and maintaining appropriate technical and organizational measures to ensure a high level of security for Personal Data. This commitment is supported by privacy impact assessments and risk assessments, which are integral to maintaining a secure environment for both manually and electronically held information.

<<Company>>’s security measures are designed to prevent unlawful or unauthorized processing of Personal Data and to safeguard against accidental loss or damage to such information. The company has established written security management policies and procedures aimed at preventing, detecting, containing, and correcting any breaches that may compromise the confidentiality, integrity, availability, or security of your Personal Data. These policies assign specific responsibilities and accountabilities to designated individuals and include a risk management program that is regularly assessed to ensure an adequate framework of controls is in place.

In addition, as part of its organizational security measures, employees at <<Company>> must:

    1. ensure that all confidential files or written information are securely stored and accessed only by authorized personnel.
    2. ensure that all files or written information of a confidential nature are not left where they can be read by unauthorized individuals.
    3. egularly verify the accuracy of data entered into the company’s systems.
    4. use provided passwords cautiously and must not share them unless absolutely necessary.
    5. use computer screen blanking feature to ensure that Personal Data is not left visible on screen when not in use.

Personal Data should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised by Company’s policies.  Where such storage is necessary, the following precautions must be taken:

    1. Data should only be recorded on portable devices when absolutely necessary.
    2. Data on such devices must be protected by encryption. An encrypted folder should be created, and all sensitive files should be stored within this folder.
    3. Laptops, USB drives, and similar devices must not be left unattended in locations where they may be stolen.

Failure to comply with <<Company>>’s data security policies may result in disciplinary action, including dismissal with or without notice, depending on the severity of the violation.

Third-Party Security Measures:

<<Company>> requires all service providers, contractors, and other third parties to maintain a similar level of data protection when processing Personal Data. While <<Company>> strives to protect your Personal Data, it should be noted that 100% security cannot be guaranteed, and <<Company>> shall not be liable for any misuse or loss of Personal Data by third-party cloud service providers.

19.International Data Transfers

<<Company>> primarily operates its website and services on servers located in India. However, due to the global nature of our business, your Personal Data may be stored on servers located in other countries where <<Company>> operates or provides services.

<<Company>> engages subcontractors, service providers, and other third parties to facilitate our products and services, which may require the transfer of your Personal Data to servers located outside of your jurisdiction. The data protection laws in these jurisdictions may differ from those in your home country.

In cases where <<Company>> transfers Personal Data internationally, we will comply with applicable legal requirements. This may include entering into data transfer agreements with recipients of Personal Data, such as the Standard Contractual Clauses for European Personal Data. Additionally, where applicable, <<Company>> will enter into Data Processing Agreements with third parties, service providers, contractors, and other recipients of Personal Data.

<<Company>> is committed to ensuring that transfers of Personal Data to public authorities are proportionate, necessary, and do not exceed what is required in a democratic society. In instances where public authority requirements conflict with our data protection standards, <<Company>> will seek a practical solution that aligns with the principles outlined in this policy.

<<Company>> is dedicated to taking all necessary steps to ensure that your Personal Data is treated securely and in accordance with our data privacy and security standards.

20.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.

21.Organizations and responsibilities

<<Company>> is committed to maintaining comprehensive records of data processing activities as required by applicable laws and regulations.

    1. Data Protection Officer (DPO): The DPO holds the primary responsibility for overseeing data protection and ensuring adherence to data protection principles and relevant legislation. The DPO is tasked with keeping the Data Processing Register current, demonstrating <<Company>>’s compliance with data protection principles through its documented activities. Individual members of staff are obligated to contribute by ensuring that the measures outlined in the Data Processing Register are accurately implemented in practice.
    2. Internal Monitoring: <<Company>>’s compliance with relevant policies and regulatory requirements concerning data protection will be periodically monitored by a designated governance group. This internal oversight ensures that the organization adheres to its Data Management Strategy, supporting ongoing compliance efforts.
    3. Training and Supervision: All employees, volunteers, consultants, partners, or other parties handling Personal Data on behalf of <<Company>> will receive appropriate training and supervision as necessary. This ensures that all individuals involved in data processing are well-versed in <<Company>>’s data protection practices and policies.
    4. Review and Adherence: The collection, storage, use, and sharing of Personal Data will be subject to regular review by the DPO, the Governance Group, and relevant business areas. <<Company>> will adhere to pertinent codes of conduct, as identified and deemed appropriate for its operations.
    5. Data Protection Impact Assessments (DPIAs): Where a processing activity is likely to pose a high risk to individuals’ rights and freedoms, <<Company>> will conduct a Data Protection Impact Assessment (DPIA) prior to initiating the processing. If necessary, the relevant supervisory authority will be consulted before proceeding with the activity.
22.Conflicts of law

This Policy is designed to comply with the laws and regulations of the jurisdictions in which <<Company>> operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail. <<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.

23.Retention of Personal Data

<<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, <<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.

 24.Data protection procedures

<<Company>> has implemented comprehensive measures to safeguard the Personal Data of its stakeholders:

    1. <<Company>> employs personnel with specific responsibilities for processing and controlling Personal Data, ensuring accountability at every level.
    2. Employees are provided with ongoing training to heighten their awareness of the importance of protecting Personal Data, teaching them how to securely handle such data, and ensuring they understand the significance of confidentiality.
    3. <<Company>> maintains full accountability for all Personal Data it holds, including its origin, who it is shared with, and potential sharing partners.
    4. Regular risk assessments are conducted to identify vulnerabilities in the handling and processing of Personal Data, allowing <<Company>> to implement measures to mitigate the risks of mishandling and potential data breaches. These assessments include evaluating the impact of both intended and potential misuse of Personal Data.
    5. <<Company>> recognizes the importance of obtaining, recording, using, sharing, storing, and retaining Personal Data with the individual’s explicit consent. Consent procedures are regularly reviewed, ensuring that consent is freely given, specific, informed, and unambiguous. Individuals have the absolute right to withdraw consent at any time.
    6. <<Company>> has established robust mechanisms for detecting, reporting, and investigating suspected or actual data breaches. In the event of a significant breach, particularly one that may cause harm to affected individuals, <<Company>> will report the breach to the relevant supervisory authority without undue delay, within 72 hours, and will notify affected individuals directly if their rights and freedoms are at high risk.
    7. <<Company>> is aware of the implications of international data transfers and takes necessary steps to ensure that Personal Data transferred internationally is protected in accordance with applicable legal requirements.
25.Breach Notification

In the event of a data breach likely to result in a risk to individuals’ rights and freedoms, <<Company>> will notify the relevant supervisory authority within 72 hours of 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, <<Company>> will do so without undue delay.

26.External Link on our Platform

For convenience, <<Company>> may provide links to third-party websites (“Third Party Sites”) that may be of interest. <<Company>> does not disclose Personal Data to these Third-Party Sites unless there is a lawful basis for doing so. <<Company>> does not endorse or take responsibility for the privacy practices of these Third-Party Sites. Users are encouraged to review the privacy policies of any Third-Party Sites they visit to understand how their Personal Data may be collected and used.

<<Company>> utilizes YouTube API Services for video playback. When a YouTube video is played, the application communicates directly with YouTube, not with <<Company>>. Users should review the Google Privacy Policy available at https://policies.google.com/privacy to understand how YouTube handles user data. <<Company>> does not retain records of videos watched or other YouTube API data.

We take no responsibility for the content or practices of any third-party services in the Third Party Sites. We encourage you to carefully review the terms of services/use of any third-party services or Third Party Sites you access.

27.No Impersonation

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

28. Trust and safety

<<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. <<Company>> will take stringent action against users posting such content.

29.Use of this platform and our Terms of Service

This website is the property of <<Company>>. The use of the platform is governed by <<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.

30.Updates to the policy

<<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.

31.Data Protection Officer

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

Name:_____________

Email Address:_____________