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1. INFORMATION THAT WE COLLECT
ACIPL collects data to operate effectively and provide you the best experience with our services. You will provide some of this data directly, such as when you sign up for our email communication or register for our program through our Website or Landing pages. We also collect the information in other various ways such as on social media channels, in-person communication, or during the pre-counselling process when we may contact you for additional clarification regarding your profile or to organize one-to-one meetings for you.
We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this policy, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time, but have included:
- Database providers from trusted sources
- Social networks when you grant permission to access your data
- Partners with which we offer co-branded services or engage in joint marketing activities
- Publicly-available sources such as open government databases or other data in the public domain
Please note that in relation to any data provided by third-party database provider it is their responsibility to ensure that they have obtained the necessary consent from you to share your personal information.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a service, you may not be able to use that service.
The data we collect depends on the context of your interactions with ACIPL. The data we collect can include the following:
- Name and contact data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
- Credentials. We collect your username and password when you create your personal account on our websites.
- Demographic data. We collect data about you such as your date of birth, Parents/Guardian Name, Photograph, Address, age, gender, country, blood group, citizenship and preferred language.
- Educational and professional background. We collect data about your employment history, education history and possibly your standardized test scores.
- Videos and pictures. Photographs or video recordings may be taken during our physical events; we may use the visual or video captures of your person on our websites or promotional material.
- Other information you may provide to us, such as in feedback forms or through the “Contact Us” feature on our websites.
Information Collected by Automated Means When you visit our websites, we may collect certain information by automated means, such as cookies, web beacons and web server logs. The information we may collect in this manner includes:
- IP address
- Unique device identifier
- Browser characteristics
- Device characteristics
- Operating system
- Language preferences
- Referring URLs
- Information on actions taken on our websites
- Dates and times of visits to our sites and other usage statistics
- Location data
The kinds of sensitive personal information which we may process are:
- financial information such as bank account, payment instruments etc. to the extent you provide the same
You may also choose to provide your Aadhaar details for identification purposes. Please note that it is not mandatory for you to provide your Aadhaar details for identification purposes, and you may provide other identification documents such as passport or driving license.
Legal Basis For Processing Of personal information For European Economic Area (EEA) Users: The legal basis for collecting and processing the personal information described above, will be on the following grounds, depending on the nature of the personal information concerned and the context in which we collect it:
- if you have consented to the collection and processing of your personal information;
- if personal information is required to perform a contract with you;
- if processing of your personal information is necessary for us to comply with a legal obligation;
- if processing of your personal information is necessary to us to protect your vital interests or the vital interests of another natural person;
- if processing of your personal information is necessary for us to perform a task in the public interest; or
- if the processing of personal information is in our legitimate interests (such as processing for network and information security, direct marketing, preventing fraud or criminal acts) and not overridden by your data protection interests or fundamental rights and freedoms.
If you have questions about or require further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact our grievance officer using the contact details provided given below.
1.1 COOKIES, AND OTHER TRACKING WEBSITES
A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links webpages to web servers and their cookies and is used to transmit information collected through cookies back to a web server. Through these automated collection methods, we may obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website.
As the visitor clicks through the website, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our websites. To the extent required by applicable law, we will obtain your consent before collecting personal information using cookies or similar automated means.
The providers of third-party apps, tools, widgets and plug-ins on our Website, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers.
1.2 PAYMENT INFORMATION
We might collect your billing name, billing address and payment method when you subscribe to ACIPL. We do not collect and store details like Credit / Debit Card numbers, PIN, CVV/CVC, Expiry Date, OTP, or any other information related to payment method/mode, we redirect the payee to the respective payment gateway page.
2. HOW DO WE USE YOUR INFORMATION
We may use information to protect ACIPL, our students or our Website. We may disclose personal information when we are required to or we believe it is appropriate to comply with the law (e.g., a lawful subpoena, warrant or court order); to enforce or apply this Policy or our other policies or agreements; to initiate, render, bill, and collect for amounts owed to us; to protect our or our users’ rights, property or safety; to protect our users from fraudulent, abusive, or unlawful use of the Services; or if we believe that an emergency involving the danger of death or serious physical injury to any person requires or justifies disclosure of personal information or we may also share it if a government agency or investigatory body wants us to do so, or anytime when we are investigating potential fraud. We may use information for general legal and compliance requirements.
We use information as otherwise permitted by law. To such extent, we may share your information for reasons not described in this policy.
2.2 PERSONAL INFORMATION
We use personal information to facilitate our Services, to process your requests or transactions, to provide you with information, products and services you request, to administer and assist us with the operation of our business, and for the purpose for which the information was provided. We may use the information we collect to send you news relevant to you or in accordance with your preferences. These might be our own offers or products, or third-party offers or products we think you might find interesting. We may also send you advertisements and promotional material from third parties.
2.3 LEGAL USE
The information shall be used as otherwise permitted by law.
2.4 THIRD PARTY SERVICE PROVIDERS
In the event that we engage with third party service providers in connection with our Services, we may share personal information with such service providers who need access to such information to carry out their work for us. For example, we may use credit card processing or verification companies to verify credit card information or to verify your identity. Other than such service providers, we do not share personal information with third parties unless (1) you have indicated to us that you wish to receive information from such parties; (2) you otherwise give us your consent to do so; or (3) in response to a request for information.
2.5 TRANSACTIONAL COMMUNICATIONS
The information provided by you will be used to contact you for confirmation of our educational services. We might send emails or SMS, WhatsApp messages, or Calls or Invite in Events offline/online in case you are a Subscribed User. We provide all Users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partners, and from us in general, after providing Us with personal information. If the User wants to opt-out from receiving promotional SMS, he/she please register your phone number with DND processes as per our Terms & Conditions of Use.
3. DISCLOSURES AND TRANSFER
All sensitive personal information that we collect is disclosed or transferred only under the following circumstances and to entities/individuals who adhere to the same levels of security standards as maintained by us, to ensure the security, integrity, and privacy of your sensitive personal information. Such entities/individuals are identified below:
Disclosures To Affiliates/Group Companies: We and our affiliates/group companies receive such information from and may share such information with each other for (a) research and development in relation to the provision of the relevant product or service; (b) marketing and advertising the relevant product or service to you; (c) tailoring product or service offerings for your benefit; or (d) driving analytics on how our services are used and improving our services, our affiliates’ services and your experiences using them.
Mandatory Disclosures Or Transfers: As required by (a) applicable laws; or (b) any judicial or governmental proceeding.
[Disclosures Or Transfers To Service Providers: We will share such information with third parties who perform services on our behalf or to the extent we may be providing any third-party services to you as set out in paragraph 2.3 above]
Corporate Changes: In connection with the sale of our business or assets or an acquisition of our business by a third party or any other M&A transaction involving us.
TRANSFER FROM THE EEA
Personal information of EEA data subjects are transferred outside the EEA to jurisdictions that have an “adequate level of protection” as determined by the European Commission. In case of other jurisdictions, such as India, we do so on the basis of lawful measures, such as contracts that include the EU standard contractual clauses.
4. DATA RETENTION
All personal information including Aadhaar details collected by us will be retained only as long as it is necessary for the purposes for which it is collected. To determine such duration, we usually consider the: (a) quantum, sensitivity, and nature of personal information; (b) purposes of processing the personal information, and alternative means to achieve those purposes; (c) potential risk of harm from unauthorized use of such personal information; and (d) legal requirements in relation to the personal information.
5. PERSONAL INFORMATION OF MINORS
Our services and Website are not directed at persons under the age of 16, and we do not knowingly collect personal or sensitive personal information from persons under the age of 16. In relation to personal information collected from persons between the ages of 16 and 18, we assume that the legal guardian or parents have consented to such collection and such continued use is made available by the legal guardian or parents. If you are a parent/guardian and believe your child has provided us with their personal information without your consent, please contact our grievance officer whose contact details are given below.
6. YOUR RIGHTS
Right of Access And Modification: You can access your personal information at any time to review any such information that you have supplied. You may modify any such information that has been found to be inaccurate or incomplete during such review.
Right to Withdraw Consent: You may also withdraw your consent in relation to processing of any sensitive personal information that you have provided to us, by contacting our grievance officer, using the details provided below. Please note however that this may affect our ability to provide you with services and may therefore lead to discontinuation of such services for which this information was being used for, at our sole discretion.
5(A) Additional Rights of EEA Users
Right to Erasure: You have the right to request that we erase your personal information where one of the following grounds applies:
- you believe that the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
- you withdraw your consent based on which the processing of the personal information was carried out and there is no other legal ground for the processing;
- you object to the processing of the personal information in accordance with applicable laws and there are no overriding legitimate grounds for the processing;
- you believe that your personal information has been unlawfully processed.
However, we will have the ability to refuse your request for the right to erasure in certain circumstances, as may be permitted under applicable laws.
Right To Withdraw Consent: If we have collected and processed your personal information based on your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (a) the lawfulness of any processing we conducted prior to your withdrawal, or (b) processing your personal information under other legal basis noted above.
Other Rights: You have the right (in accordance with applicable laws) to: (a) object to processing of your personal information; (b) request us to restrict processing of your personal information; and (iii) request portability of your personal information. You can exercise these rights by contacting our grievance officer whose contact details are provided below.
Subscribed Users are solely responsible for maintaining the confidentiality of the passcode and user identification and all activities and transmission performed by the Subscribed Users through his user identification and shall be solely responsible for carrying out any online or off-line transaction. ACIPL assumes no responsibility or liability for their improper use of information relating to such usage of credit cards / debit cards used by the mapper online/off-line. All the disclaimers mentioned in Terms & Conditions of Use of the Website shall be applicable.
We are strive to ensure the security, integrity, confidentiality and privacy of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain and have implemented reasonable security practices commensurate to the standards required under applicable laws. For example, we limit access to this Information to authorized employees only who need to know that information in order to operate, develop or improve our application/Services/products/Website. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
If you choose to visit the Website and/or application, your visit and any dispute over privacy is subject to this Policy and the Terms & Conditions of Use. In addition to the foregoing, any disputes arising under this Policy shall be governed by the laws of India, and courts at Kota, Rajasthan shall have exclusive jurisdiction over such disputes.
Name: Dhananjay Srivastava
Designation: Grievance Officer