It is also important to understand the distinguished roles for processing Personal Data as per certain data protection laws and regulations including EU’s General Data Protection Regulation (“GDPR”):
- “data controller” or the “data fiduciary” or “business”; as used under relevant data protection laws – means, who determines the purposes and means of processing; and
- the “data processor” or “service provider”; as used under relevant data protection laws – means, who process the data on behalf of the data controller (or data fiduciary or business).
I. WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT
1. Information we collect from You
1.1. “User Data”
1.1.1. Personal Data collected which we analyze, process and manage on our Users’ behalf are a part of the service provided by the Website. Specifically, this includes the data submitted by our Users while registering / subscribing to our services.
1.1.2. Certain privacy and data protection laws require that Personal Data may only be collected, stored, shared, pursuant to one or more of the parties’ consent (whether explicit or implicit, depending on applicable law), or subject to certain restrictions. Accordingly, whilst the Company supports these laws by providing our Users with features and options for how they use the Website – the User is solely responsible for determining whether and how they wish to use the Website and such features, and to ensure that all individuals using the Website on their behalf or at their request have given their informed consent to these practices, and that all legal requirements applicable to the collection, storing and use of data through the Website are fully met by them.
1.1.3. Accordingly, to the extent that the GDPR, the United Kingdom Consumer Privacy Act (“UKDPA”), the Indian Information Technology Act (“Indian IT Act”) or any similar laws apply:
(a) Our Users would be deemed to be the ‘data controller’ or the ‘data fiduciary’ or ‘business’; as used under relevant data protection laws.
(b) The Company would be deemed to be the ‘data processor’ or ‘service provider’ when processing such data.
1.2. Information collected via use of the Website (“Website User Data”)
1.2.1. We collect Personal Data directly from our Users in connection with the provision of the Website. Depending on the context, such information may include:
(a) user names and contact details such as email address, school/college name, and phone number;
(b) user IDs and passwords;
(c) activity data from the devices on which the Website is accessed (“Activity Data”) and includes technical information with limited individually identifying information such as usernames, machine names, IP/MAC address of the User’s device and identifiers and may include without limitation:
- Configuration Data: Data about how the user’s machine/device has configured the Website and related environment information including third-party applications used in connection with the Website;
- Performance Data: Data relating to how the Website is performing. Examples include metrics of the performance and scale of the Website and details about the response times for user interfaces.
- Service Logs: Service logs are automatically generated by the Website recording events during the operation of the Website.
(d) other information that Users provide to the Company in connection with the provision of the Website.
(e) Facebook user and profile data that we collect when Users integrate Facebook with the Website.
(f) Google profile name, email and profile picture when User signs-up using Google Signup feature.
1.3. “Website Data” – Data relating to our Users, visitors of our website and any other prospective user or partner who visits or otherwise interacts with any our websites, forms, content or emails or communications under our control, for which the Company is deemed to be the ‘data controller’ (“Sites”).
II. HOW WE USE THE INFORMATION
2. Use of the data collected
2.1. Use of Website User Data
2.1.1. The Company processes Website User Data, and the Personal Data contained in it as necessary for the performance of the Website, with our legal and contractual obligations, and to support our legitimate interests in maintaining and improving our Website.
2.1.3. If you wish to revoke such consent, please contact us at .
2.2. More specifically Website User Data are used for the following purposes:
(a) To facilitate, operate and provide our Website;
(b) To train our users and user-facing staff;
(c) To authenticate the identity of our Users, and to allow them access to our Website;
(d) To provide our Users with assistance and support;
(e) To gain a better understanding on how individuals use and interact with our Website and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Website;
(f) To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using the Website, and thereby increase Your engagement and overall satisfaction with the Website. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our Users;
(g) To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
(h) To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our Users may use to provide and improve our respective services, or for any other purpose; and
(i) To comply with applicable laws and regulations.
III. HOW WE SHARE YOUR INFORMATION
3. Sharing of data
3.1. The Company takes caution to allow Personal Data to be accessed only by those who really need access in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it.
3.2. In exceptional circumstances, we may disclose or allow government and law enforcement officials access to Your Personal Data, in response to a subpoena, search warrant, court other or any similar requirement in compliance with the applicable law. Such disclosure may occur if we believe in good faith that (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
3.3. We may share Personal data with third parties in the following circumstances:
3.3.1. Service Providers –
(a) We may engage third party companies and individuals to perform services complementary to our own including hosting and server co-location services, Communication and content delivery networks (“CDNs”), speech-to-text services, data and cyber security services, billing and payment processing services, data and cyber security services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (each such engagement a “Service Provider”).
(b) Our Service Providers shall each be deemed as ‘data processor’ or ‘service provider’ in circumstances where the Company assumes the role of ‘data controller’; and where the Company acts as the ‘data processor’ or ‘service provider’ for our Users, the Service Provider shall be deemed as our ‘sub-processor’ or ‘service provider’.
(c) Service Providers may have access to the Website User Data depending on their specific roles and purposes in facilitating us and may use it for such limited purposes as determined in our agreements with them.
3.3.2. Third Party Websites and Services –
3.3.3. Protecting Rights and Safety
(a) We may share Personal Data with others if we believe in good faith that this will help protect Your rights, property or personal safety of any of our Users, or any members of the general public.
3.3.4. Subsidiaries and Affiliated Companies
(b) In addition, should the Company or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, Personal Data may be shared with or transferred to the parties involved in such an event.
(c) If we believe that such change in control might materially affect Your User Data or Personal Data then stored with us, we will notify You of this event and the choices You may have via e-mail or prominent notice on the Application.
IV. HOW LONG DO WE RETAIN DATA
4. Retaining Data
4.1. Retaining User Data
4.1.1. We retain User Data and Website Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide You with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
4.2. Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at .
V. Data Location
5.1. We and our authorized Service Providers maintain, store and process Personal Data in United Arab Emirates, the Republic of India and other locations, as reasonable necessary for the proper performance and delivery of the Application, or as may be required by law.
6.1. Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types. In addition, we also make use of browser’s local data storage.
VII. Your Privacy Rights and Choices
7. This clause covers the rights available to You on if any data that we access as per clause 1 concerns you.
7.1. Rights generally available
7.1.1. Right to rectification or update Personal Data
If You would like to correct or update personal information that You have provided to us, please contact us at to receive instructions to update your profile.
7.1.2. Marketing communications
If You reside in certain territories (such as the EEA), You may have the right to exercise certain privacy rights available to You under applicable laws. We will process Your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes and/or to complete transactions that you began prior to requesting any deletion.
7.1.3. Right not to provide consent or withdraw consent
We may seek to rely on Your consent in order to process certain Personal Data. Where we do so, You have the right not to provide Your consent or to withdraw Your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
7.1.4. Right to access and/or portability
You may have the right to access the Personal Data that we hold about You and, in some limited circumstances, have that data provided to You so that You can provide or 'port' that data to another provider.
7.1.5. Right of erasure
In certain circumstances, You may have the right to the erasure of Personal Data that we hold about You (for example if it is no longer necessary for the purposes for which it was originally collected).
7.1.6. Right to object to or restrict processing
(a) You may have the right to request that the Company stop processing Your Personal Data and/or to stop sending You marketing communications.
(b) You may have the right to request that we restrict processing of Your Personal Data in certain circumstances (for example, where You believe that the Personal Data we hold about You is not accurate).
7.1.7. Right to lodge a complaint to your local Data Protection Authority
You may have the right to lodge a complaint with your national Data Protection Authority or equivalent regulatory body.
7.2. Exercise of the rights
7.2.1. If you would like to exercise any of the above rights, please contact so that we may consider Your request under applicable law. To protect Your privacy and security, we may take steps to verify Your identity before complying with the request.
VIII. HOW DO WE SECURE YOU DATA
8. Data Security
8.1. The Company would maintain reasonable physical and technical safeguards to prevent unauthorized disclosure of or access to any data, minimize the risks of theft, damage or loss of information; in accordance with the industry standards.
8.2. However, although we make efforts to protect your privacy, we cannot guarantee that our Sites or the Application will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
IX. ADDITIONAL NOTICES AND HOW TO CONTACT US
9.1. Updates & Amendments
9.2. Age bar
We do not knowingly collect Personal Data from children under the age of 13 or 16 (as per the applicable local laws) and do not wish to do so. If we learn that a person under the age of 16 is using the Sites or the Application, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child unless specific consent for storing and processing such Personal Data has been provided by the Parent of such child.
9.3. Data Protection Officer
9.4. Questions, concerns or complaints