Updated: November 2020
This Policy explains how we protect and handle any information you provide to us, including via our websites, our CMS, our dashboard, mobile apps, communications by email and/ or through social media, by telephone and in person. It also covers information we receive from third parties. It also provides you with an overview of the rights you can exercise regarding what we do with your information.
By using our products and services, including browsing our websites, registering or logging in, we may use your information as outlined in this Policy.
1. What information we collect ?
We collect two types of information regarding our Visitors and Users:
- Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”) or browsing of the website. Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information that may be collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc. We may also collect similar information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf.
- Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal or such service, Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists. Generally Individually or Personally Identifiable Information (PII) is collected from clients or prospective clients who want to use our services / products.
- Means of Communication:
We use WhatsApp API’s (https://www.whatsapp.com/business/api) for all communication and messages with students and teachers on the platform.
We are committed to the protection of Personal Data, Please be rest assured that the data is safe with us.
- Usage of CRM (woopra.com):
We would be using woopra for our internal tracking and as a CRM tool, We use this tool to enhance Student/Tutor engagement in real-time.
2. How do we collect such information?
There are two main methods we use:
- We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or any User Website, register a User Account, upload information and content, and/or download and use any of our Apps/ services and/or Mobile Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 6 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 6 below.
- We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services or when you try to reach out to us to understand our service offerings better; when you sign in to our Services via third party services such as Facebook or Google; when you place purchases and/or register domain names; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel (e.g., Our support tickets, emails).
- We also collect information from third party sources as described in Section 6.
3. Why do we collect such information?
We collect such Non-personal and Personal Information for the following purposes:
- To provide and operate the Services;
- To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
- To provide our Users with ongoing customer assistance and technical support;
- To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed in Section 7 below);
- To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
- To enhance our data security and fraud prevention capabilities;
- To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest.
- To personalize your experience using the Services by presenting products and offers tailored to you, and to facilitate social sharing functionality.
- To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;
- To consider Applicants’ candidacy for working with us;
- To comply with any applicable laws and regulations.
- We use Whatsapp API's ( https://www.whatsapp.com/business/api ) and Woopra(https://www.woopra.com) for better engagement and assistance for customers.
Your Personally Identifiable Information and Non-Personally Identifiable Information may be disclosed as follows:
- By you, on message boards, chat, profile pages, dashboard, website and blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages).
- To unaffiliated companies or individuals for market research, product development or similar purposes. These companies or individuals may be provided with access to Personally Identifiable Information Non-Personally Identifiable Information, but we will require by contract that they agree to maintain the confidentiality, security and integrity of such information.
- To third-party sponsors of sweepstakes, contests and similar promotions.
- To third parties in connection with a corporate transaction where all or a portion of our business (e.g., a portion that includes our customer lists) is sold or transferred. We also may disclose your Personally Identifiable Information if disclosure is required by law, which may include laws outside your country of residence, or as part of a lawsuit or government investigation or proceeding, or in order to permit us to exercise or preserve our legal rights or take action regarding potentially illegal activities or to protect the safety of any person.
In addition to the uses otherwise set forth herein, we may use and disclose your Non-Personally Identifiable Information for any purpose, except where we are required to do otherwise under applicable law.
We will only use your Personal Information for the purposes set out in Section 1 where we are satisfied that:
- Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support), or
- Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
- Our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of our campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
4. Where do we store your information ?
The Service is hosted and operated in India, with development, support and maintenance operations in other countries.
5. Users-of-users’ information
We may collect, store and process certain Non-personal and/or Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users brings in their own users to the website and give us access to the information mentioned in Section 1.
For such purposes, We serve and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation) of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal Information, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
We, our company or team cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites, in accordance with the applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they consent to them.
If you are a visitor, user or customer of any of our Users, please read the following: We have no direct relationship with the individual Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by Us on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Users-of-Users’ Personal Information, we will respond to such request within thirty (30) days. Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 8 below.
6. Sharing personal information with third parties
- Law Enforcement, Legal Requests and Duties:Where permitted by local data protection laws, We may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
- Protecting Rights and Safety:We may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of our website or company, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
- Social Media Features and Framed Pages:Our Services may include certain Social Media features and widgets such as the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”) or single sign on features, the “Facebook Connect” or “Google Sign-in”, comments integrated with other social media platforms, scheduling posts on such social media platforms. These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
- Behavioral Targeting/Re-Targeting:Certain Third Party Services and ad networks may display advertising on our Website, on our Apps and on our mobile apps, or on the websites our User’s create or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party Services to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by clicking here (or if you are located in the European Union click here (provided by YourChoicesOnline.eu). Please note this does not opt you out of receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will continue to receive advertising for which you have not opted out.
- User Data Supplementation:We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and Services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
7. Communications from Us
- Promotional Messages:We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from Us or our partners (acting on our behalf) through such means.If you do not wish to receive such promotional messages or calls, you may notify Us at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.
- Service and Billing Messages:We may also contact you with important information regarding our Services, or your use thereof.For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a website Visitor or User (which can be done by deactivating your account).
8. Your rights in relation to your personal information
It is imperative that you have control over your Personal Information. That’s why We have taken steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a PubNinja Academy Visitor or User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please contact us firstname.lastname@example.org
We will make all reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personally Identifiable Information provided until after the completion of such purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.
9. Questions and Complaints
Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly. Our target response time is 30 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with your local supervisory authority for data protection.
You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.
10. Retention Period
Our website, apps, other products or services are not directed at children under the age of 13 and we endeavor not to knowingly collect any Personally Identifiable Information from children under the age of 13.
If you are under the age of 13, we request that you do not provide us with your information and do not use our websites and apps.
If you are aged 13, 14 or 15, we request that you seek your parent or guardian’s permission before providing us with your information or using our websites or apps.
If you are a parent or guardian of a child under 13, please contact us at email@example.com , if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. We will delete or otherwise cease processing your child’s personal information within a reasonable time.
12. Contact Us
You may also send us mail at the following address:
Attention: Data Privacy Officer (DPO) at PubNinja Academy
Eleven Learning Pvt Ltd.
D-24, Wallfort City,
Bhatagaon, Ring Road no 1,
Raipur 492001 - Chhattisgarh