গোপনীয়তা নীতি

GENERAL

• This privacy policy describes how Indiavidual Learning Limited, trading under the name “Embibe” collects, uses, shares and protects personal information that we collect from you, the end-user of the Embibe website (https://www.embibe.com), microsites, applications (hereinafter called “apps”) and services (collectively, “Platform”).
• Embibe respects your privacy rights and is deeply committed to safeguarding them.
• Please note that:
  • Our privacy policy may be revised, updated, or changed from time to time in accordance with recent regulations and laws, and we recommend viewing the policy regularly to become familiar with any changes. This policy supplements other notices and privacy policies and does not intend to override them.
  • We encourage you to refer to our Terms and Conditions of Use available at https://www.embibe.com/tos 

WHAT ARE THE INFORMATION THAT WE COLLECT

Your personal information may be collected, stored, and processed for legitimate business purposes only.

• Traffic Data – we automatically track and collect the following categories of information as and when required when you use the platform, IP addresses; domain name servers; time spent on each screen; responses to questions; the app is in the foreground or background; recording of live classes, videos uploaded and any other information on the lessons performed on our platform; recording of in-class chats, discussions, processes, conversations, feedback or events on our course; school calendar; and other information concerning your device, the interaction of your device with the platform and applications.
• Personal Data – we may require you to provide us with certain information that personally identifies you (also known as “Embibe Information”).  We categorise the information as  – Contact Information (such as your email address, password, postal address, postal code, phone number and any details of your contacts), Financial Information (such as bank account or credit card or debit card or any other payment information). Information provided by parents/guardians in case of a child less than 18 years of age. Any information provided by school admins for School,  its students and teachers during onboarding. Any information received through your access to any other social media platform (Facebook, Google, etc.) integrated with Embibe. Personal data is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
• Aggregated Data, such as statistical or demographic data, may also be collected and processed by us for legitimate business purposes. Aggregated data may be derived from your personal data, but it is not considered personal data by law because it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to determine the percentage of users accessing a specific platform feature. Nevertheless, if we combine or link Aggregated Data with your personal data and the combined data can directly or indirectly identify you, we treat the combined data as personal data that will be handled according to this privacy statement.
• We do not collect any Special Categories of Personal Data about you which may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences. However, we collect financial information and passwords, which qualify as sensitive personal data or information under Indian law.
• Our platform may transfer your information to our internal systems in accordance with our justification for legitimate business purposes with appropriate security measures in place. Embibe will take reasonable steps to delete the information as soon as possible in a manner consistent with applicable laws in India.

HOW DO WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your identity, contact and financial data by filling in forms or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: create an account on our Platform; subscribe to our service or publications; request marketing content to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us.
• Automated technologies or interactions. As you interact with our platform, whether or not you are a registered member, we will automatically collect technical data about your equipment, browsing actions and patterns. Cookies are small text files constituting alphanumeric numbers used to collect the information about the Platform activity. These cookies help us analyse web traffic and help you by customising the Platform to your preferences. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. Some features and services may not function properly if your cookies are disabled. We also collect personal data by using cookies and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below: Technical data from the following parties: analytics providers such as Google based outside of India]; advertising networks based in India or abroad; search information providers based in India or abroad using YouTube data API for serving the content please refer Google Privacy Policy and YouTube Terms of Service; Contact, financial and transaction data from providers of technical, payment and delivery services  based in India or abroad; Identity and contact data from data brokers or aggregators based in India or abroad; Identity and contact data from publicly available sources such as Companies House and the Electoral Register in India.

HOW DO WE USE YOUR PERSONAL DATA

• We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we rely on to process your personal data where more than one ground has been set out in the table below.

Most commonly, we will use your personal data for the following purposes:

Purpose/Activity	Type of Data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer on the Embibe Platform To verify your identity when you use the Platform and when you make submissions on the Platform. To improve your experience, for example, to improve our services to you, including updating, enhancing operations and functionality of our platform features, to improve and customise the platform for ease of use. To improve the functionality of the personalised learning experience.	Identity Contact	Performance of a contract with you Consent
To process and deliver your order, including (a) Manage payments, fees and charges (b) Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) Consent
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or to take a survey (c) Communicating with you, in particular about types of classes or courses relevant to your interests and to suit your needs.	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and analyze how customers use our products/services) as well as to enhance our products/services and grow our business.
To administer and protect our business and the platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Identity Contact Device and IPs	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network and cyber security, to prevent fraud andAlso in the context of a business reorganization or group restructuring exercise)Necessary to comply with legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Identity Contact Profile Usage Marketing and Communications Device, IPs, Network	Necessary for our legitimate interests (to analyse how customers use our products/services, to develop them, to grow our business and for our marketing strategy)
To use data analytics to improve our platform, products/services, marketing, customer relationships and experiences	Device, IPs, Network Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

CONFIDENTIALITY, RETENTION & SECURITY

The personal information collected will only be used within the scope of agreed business purposes, in accordance with Indian laws.

• We may share the information collected:
• with the government/government authorities or agencies and legal or judicial authorities for any investigation or to comply with legal process or in response to a request by any of these authorities or to enforce applicable terms and conditions or to protect our, our users and Partners rights, privacy, safety or property.
• with our other entities and affiliates to help in detecting and preventing identity theft, fraud and other illegal activities; correlate or map related accounts to prevent misuse of our products & services and to provide you with our services.
• with our authorised partners who operate under a contract and strict security & confidentiality restrictions. Our Partners provide a host of services including contact information verification, payment processing, customer service, website hosting, data analysis, infrastructure provision, IT services, and other similar services, also

• In a scenario where we or our assets are merged or acquired by the other business entity, or during a restructuring of business or reorganization. If such a transaction occurs the other business entity or the newly combined business entity would be required to follow this Privacy Policy.
• To protect your rights and/or those of our Partners, and to allow us to pursue available remedies or limit the damages that it may sustain in case of unauthorised use/misuse of our products or the content thereon, by third parties.
• We also assure that the data provided by Schools while being onboarded regarding the Student name and other such information will be kept confidential and can only be accessed by Employees of Embibe only who are authorized to have access to it.
• We will retain your personal data only for as long as reasonably necessary to fulfill the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation over our relationship with you.
• To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
• By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) as prescribed by the statutory provisions.
• In some circumstances you can ask us to delete your data: for further information, see your legal rights below.
• In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
• We have adopted reasonable security practices and procedures, in line with international standard IS/ISO/IEC 27001, to include strategic, operational, managerial, technical, and physical security controls to safeguard and protect your data and information. We have implemented such measures, as stated above, to protect against unauthorized access to and unlawful interception of Personal Information. Additionally, we have adopted measures to ensure that your personal information is accessible to our employees or partner’s employees strictly on the need to know basis.
• Our website, applications, portals, and network equipment have industry-standard security precautions in place to protect against the loss, misuse and alteration of information which is in our environment. Whenever you change or access your account information, we facilitate the use of secure systems. The information in our custody and control is protected by adherence to reasonable security procedures in order to safeguard against unauthorized access. We apply encryption or other appropriate security controls to protect Personal Information when stored or transmitted by us.

QUERIES, COMPLAINTS & RIGHTS

• Indiavidual Learning Limited is the controller of the data collected and is responsible for safeguarding your personal data.
• If you have any questions about this privacy policy or our privacy practices, please reach us by email at [email protected]

Or by mail to Attn: Legal Team Indiavidual Learning Limited, First Floor, No.150, Towers B, Diamond District, Old Airport Road, Kodihalli, Bengaluru – 560008, Karnataka.

For privacy practice suggestions and escalations you may reach us at:

Name: Guru Prasad Patnaik

Email: [email protected] 

and/or

Name: Radha Nair

Email:  [email protected]

• You have the right to make a complaint at any time to the appropriate authority. We would, however, appreciate the chance to address your concerns before you approach the appropriate authority.
• Our Platform may include links to third-party websites, content, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.