Privacy Policy

v1 _ Last Updated on 2 November 2023.

This Privacy Policy (referred to as the "Policy") outlines how our Platform collects, utilises, maintains, and shares user information. The Policy also defines the procedures we follow for user data, user privacy rights, and user choices related to their information. To clarify, this Policy is applicable to all Platform users (referred to as "Learners," "You," or "Your").

When you access and use our Platform, provide your Personal Information, or otherwise signify your agreement when prompted, you consent to the collection, use, and disclosure of information as described in this Policy and our Terms of Use. We hereby disclaim all liabilities arising from these actions. If you disagree with any provisions of this Policy and/or the Terms of Use, please refrain from accessing or using the Platform or engaging in communications with us. You are required to leave the Platform immediately. If any information you have provided or uploaded on the Platform violates the terms of this Policy or Terms of Use, we may have to delete such information after notifying you, and if necessary, revoke your access without incurring any liability. Any capitalised terms not defined in this Privacy Policy can be found in our Terms of Use. We urge you to carefully read this Policy before accessing our Platform or using any of the services or products offered therein. If you have any questions, please reach out to us using the contact information provided below.

Personal Information
The term "Personal Information" refers to data that can identify a learner. This may include, but is not limited to, first and last names, identification numbers, email addresses, age, gender, location, photographs, and/or phone numbers provided during registration or at any time thereafter on the Platform.

On the other hand, "Sensitive Personal Information" encompasses:
- Passwords and financial information (excluding the truncated last four digits of credit/debit cards).
- Health-related data.
- Official identifiers (such as biometric data, Aadhar number, social security number, driver's licence, passport, etc.).
- Information related to sexual orientation, sexual identity, race, ethnicity, political or religious beliefs or affiliations.
- Account details and passwords.
- Any other data/information classified as 'sensitive personal data' or 'special categories of data' under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, General Data Protection Regulation (GDPR), and/or the California Consumer Privacy Act (CCPA) ("Data Protection Laws"), or other equivalent/similar legislation applicable in the context of this Policy.
- The use of the term 'Personal Information' in this Policy also includes 'Sensitive Personal Information' whenever relevant to the context of its usage.
Information We Collect
We gather both personal and non-personal identifiable information from you through various means, including, but not limited to, when you visit our Platform, register on the Platform, and engage in other activities, services, features, or resources offered on our Platform. However, please be aware of the following:
- We only request personal information when it is essential, such as during the registration process for accessing content on the Platform.
- We do not share your personal information with anyone, except as required to comply with applicable laws, improve our products and services, or safeguard our rights.
- We do not store personal information on our servers unless it is necessary for the ongoing operation of our Platform.
- Personal Identifiable Information: We may collect personal identifiable information, including your name and email address, to grant you access to the Platform and the services/products available within. We collect such information only if you voluntarily provide it to us. You have the option to decline to provide this personal identification information, but doing so may limit your access to services or products on the Platform or certain activities.
- Non-Personal Identifiable Information: When you interact with our Platform, we may collect non-personal identifiable information, such as browser type, language preference, referring site, date and time of each user request, operating system, Internet service providers used, and similar data.
- Cookies: To enhance the user experience, our Platform may utilise "cookies." A cookie is a piece of information that a website stores on a visitor's computer and that the visitor's browser provides to the website each time they return, primarily for record-keeping purposes. You can configure your web browser to reject cookies or receive notifications when cookies are sent. However, please note that doing so may result in certain parts of the Platform not functioning correctly.
How We Use And Share The Collected Information
We collect and use your Personal Information for the following purposes:
- Providing Access to SelfupGrad Platform and Services/Products: We utilize the information we collect to grant you access to the SelfupGrad Platform and the services/products it offers. This includes, but is not limited to, providing customer support, processing purchases, verifying user information, and resolving any Platform-related issues. The legal basis for this processing is your consent or, where applicable, our legitimate interests in efficiently managing our Platform and performing contractual obligations between you and us.
- Platform Improvement and Safety:Your information is used to enhance and tailor the Platform and the services/products we offer. Additionally, we employ your information to prevent, detect, investigate, and take action against criminal activities, fraud, misuse or damage to our Platform or network, and other potential threats or violations of third-party rights, our rights and property, and the safety of our users and others. The legal basis for this processing is your consent or, where applicable, our legitimate interests in the proper administration of our Platform and the performance of contractual obligations between you and us.
- Communication and Marketing: We may use the email address you provide to communicate with you regarding your orders on our Platform, share our offers, new products, services, and gather feedback on the Platform or services/products offered therein. It may also be used to respond to your inquiries, questions, and requests. If you wish to unsubscribe from future emails, please contact us using the information provided below. The legal basis for this processing is your consent or, where applicable, our legitimate interests in the proper administration of our Platform and the performance of contractual obligations between you and us.
We do not employ Personal Information to make automated decisions or create profiles beyond what is described in this Policy.

We do not sell, trade, or exploit your personal-identifiable information to third parties. With the exceptions mentioned above, we may share generic aggregated demographic information that is not linked to any personal-identifiable information about visitors and users with our business partners and trusted affiliates.
Your Choices
You have the following options when it comes to your information and interactions with SelfupGrad:
- Limit Information Provided: You always have the choice to decide what information you provide to us, including the ability to update or delete your information. However, please be aware that certain information is essential for accessing the Platform and its features. For example, the information required for your registration on the Platform.
- No Harmful or Dangerous Content: Content that incites or promotes violence, physical or emotional harm, or poses a threat to any individual's safety is expressly prohibited on the Platform. The Platform is intended for permitted uses as specified in this Agreement.
- Control Communications: You can select the type of communications you'd like to receive from us. However, there may be specific communications necessary for legal or security purposes, such as updates to legal agreements, which you may not be able to limit.
- Manage Cookies and Similar Technologies: You have the option to reject or remove cookies from your web browser. You can adjust your web browser's settings if it's currently set to 'accept cookies.' However, please note that rejecting, removing, or disabling cookies may affect the functionality and availability of some services/products on the Platform.
Your Rights
In general, all Learners have the rights detailed in this section. However, depending on your location, you may possess specific rights regarding your Personal Information as granted by the laws of your country. To understand your rights fully, please refer to the "Country Specific Additional Rights" section below.

As a Learner, you can exercise these rights by utilising the options provided within the Platform upon your login. If you encounter any issues or need clarification, feel free to contact us using the information provided in the "Grievances" section below, and we will address your concerns in accordance with applicable laws.
- Right to Confirmation and Access: You have the right to receive confirmation and access to your Personal Information held by us, along with supporting information.
- Right to Correction:You can request us to rectify any of your Personal Information that you believe is inaccurate. You also have the right to ask us to update your Personal Information if you find it incomplete or outdated.
- Right to be Forgotten: Under certain circumstances, you have the right to restrict or prevent the further disclosure of your Personal Information.
- Right to Erasure: If you wish to withdraw or remove your Personal Information from our Platform, you have the right to request the erasure of your Personal Information. Please be aware that such erasure will result in the removal of all your Personal Information from our Platform (except as specifically stated in this Policy). It may also lead to the permanent deletion of your Platform account, and the data will not be recoverable.
Please note that these rights apply exclusively to your information, including Personal Information, and not that of other Learners. Additionally, when we receive any requests or inquiries via email to the address specified in the "Grievances" section below, we may, in accordance with applicable Data Protection Laws, require some additional information from you to verify your identity in connection with the Platform and the received request.
Protection Of Your Information
We employ all reasonably necessary measures to safeguard Personal Information and other data on the Platform against unauthorised access, use, alteration, or destruction. Our disclosure of such information is restricted to:
- Our employees, contractors, and affiliated organisations (if any) who (i) require the information for processing on our behalf or to provide services available on our Platform, and (ii) have committed not to disclose it to others.
- Response to a court order or other government request. Without limiting the above, we reserve the right to disclose such information when we have a good faith belief that it is necessary to:
  - Comply with applicable laws, regulations, court orders, government and law enforcement agencies' requests.
  - Protect and defend the rights and property of third parties or SelfupGrad, or the safety of our users, employees, or others.
  - Prevent, detect, investigate, and take action against criminal activity, fraud, misuse, unauthorised use of our Platform, and enforce our Terms of Use or other agreements or policies
To the extent permitted by law, we will make reasonable efforts to provide you with prior notice before disclosing your information in response to such a request.
Third-Party Websites
You may come across links to websites and services provided by our partners, suppliers, advertisers, sponsors, licensors, and other third parties. Please note that we have no control over the content or practices of these sites in any manner, and we are not responsible for their operations.

Additionally, these websites or links to them, including their content, may undergo changes, and they may have their own terms of use and privacy policies. Your interactions and activities on any other website, including those with a link to our site, are governed by the terms and policies published on those websites.
Cross-Border Data Transfer
Your information, including any Personal Information, is stored, processed, and transferred to servers and databases located in India, specifically on the Amazon Web Service (AWS) infrastructure. Additionally, we may also store, process, and transfer information to servers in other countries based on the locations of our affiliates and service providers.

Please be aware that these countries may have privacy laws that differ from those of your home country and may have potentially less stringent privacy regulations. Consequently, Personal Information may become subject to the laws and disclosure requirements of these countries, which could include disclosure to governmental bodies, regulatory agencies, and private entities, in response to applicable governmental or regulatory inquiries, court orders, or similar legal processes.

If you use our Platform from outside India, including in the USA, EU, EEA, and UK, your information may be transferred, stored, and processed in India. By accessing our Platform or providing us with information, you consent to the transfer of your information to India and other countries outside your country of residence.
Duration For Which Your Information is Stored
We will retain your information for as long as it is necessary for the purposes stated in this policy, including compliance with legal obligations or business requirements.

Please be aware that we may not be able to delete all communications, photos, files, or other documents that you have publicly shared on the Platform (e.g., comments, feedback, etc.). However, we will anonymize your Personal Information in a manner that prevents your identification as an individual in association with such publicly shared information on the Platform. We will never disclose aggregated or de-identified information in a way that could identify you as an individual.

Note: If you wish to exercise any of your rights, as specified in the "Your Rights" section above, including accessing, modifying, or deleting any or all information stored about you, you can do so using the options provided within the Platform. You can also reach out to us via the email address specified in the "Grievances" section below.
Modification Of Privacy Policy
We may periodically modify, revise, or update our Policy as needed. When we make such changes, we will update the "updated date" at the beginning of this page. We encourage you to regularly check our Platform to stay informed about recent changes. Unless otherwise specified, our current Policy applies to all the information we have about you.
Grievances
If you have any questions about this Policy, wish to exercise your rights, or have concerns related to privacy or grievances, please don't hesitate to contact us via email at info@selfupgrad.com. Please provide a detailed description of your matter, and we will address your concerns promptly.

COUNTRY SPECIFIC ADDITIONAL RIGHTS

Terms Applicable If You Are An Indian Resident
Your Rights:
If you are located in India, you may have the following rights under the Personal Data Protection Bill (PDPB) once it becomes legislation. All requests can be made through the options provided within the Platform upon your login. Alternatively, you can contact us as stated in the "Grievances" section above, and we will address your concerns in compliance with the law.
- Right to Confirmation and Access: You have the right to get confirmation and access to your Personal Information that is with us along with other supporting information.
- Right to Correction: You can request us to rectify any of your Personal Information that you believe is inaccurate. You also have the right to ask us to update your Personal Information if you find it incomplete or outdated.
- Right to Data Portability: Under certain circumstances, you have the right to request that we transfer the Personal Information you provided to another organisation or to you.
- Right to be Forgotten: You have the right to restrict or prevent the ongoing disclosure of your Personal Information under certain circumstances.
- Right to Erasure: If you wish to withdraw or remove your Personal Information from our Platform, you have the right to request the erasure of your Personal Information. Please be aware that such erasure will result in the removal of all your Personal Information from our Platform (except as specifically stated in this Policy). It may also lead to the permanent deletion of your Platform account, and the data will not be recoverable.
Terms Applicable If You Are A Resident Of United Kingdom (UK), A European Union (EU) Country Or European Economic Area (EEA)

Your Rights:
If you are located in the United Kingdom (UK) or a European Union (EU) country or the European Economic Area (EEA), you have the following rights under the UK and EU General Data Protection Regulation (GDPR) respectively. Please send all requests to the address provided in the "Grievances" section above, and we will address them in accordance with applicable law.
We collect and process Personal Information about you only where we have a legal basis to do so. The specific legal basis applied will depend on the type of Personal Information collected and the context in which it is being processed, including the Services involved.
Terms Applicable If You Are A California State Resident
If you are a California state resident, then you have the following rights to the extent, and in the manner, set out in the CCPA:
The above rights, the manner in which you can exercise the same and the category of and the manner in which we collect your information, are detailed below.

CCPA Notice At Collection
For purposes of the CCPA, in collecting the information described above, we collect the categories of Personal Information listed below from you:
- Identifiers: We may collect your name, email address, mobile number, username, unique personal identifier, and Internet Protocol (IP) address. We use Identifiers as described in the "How We Use and Share the Information Collected" section of this Policy, such as your name, contact information, and device and online identifiers.
- Characteristics of Personal Information described in the California Customer Records statute: We may collect your name, email address, username, unique personal identifier, and gender. We use the Categories of Personal Information described in the California Customer Records statute as set forth in the "How We Use and Share the Information Collected" section of this Policy.
- Internet or Other Electronic Network Activity Information: We collect cookies, as described above. We automatically receive information from your browser and your device, including the date and time of your visit to the Platform, your location, Internet Protocol (IP) address, domain server, browser type, access time, and data about which pages you visit on the Platform. We use Internet or other electronic network activity information as detailed in the "How We Use and Share the Information Collected" section of this Policy.
- Geolocation Data: We may collect your IP address. We use Geolocation Data as specified in the "How We Use and Share the Information Collected" section of this Policy.
- Audio, Electronic, Visual, or Similar Information: cted" section of this Policy. Audio, Electronic, Visual, or Similar Information: We may collect your profile picture or other audio or visual information uploaded as content to the Platform. We use audio, electronic, visual, or similar information as described in the "How We Use and Share the Information Collected" section of this Policy.
- Inferences: We may make inferences based upon the Personal Information collected, such as the likelihood of retention or attrition. We use Inference information as set forth in the "How We Use and Share the Information Collected" section of this Policy.
CCPA Data Practices During The Last 12 Months:
Personal Information collected: As described in this Policy, we have collected the categories of Personal Information listed below during the preceding 12 months:
- Identifiers
- Characteristics of Personal Information described in the California Customer Records statute
- Internet or other electronic network activity information
- Geolocation data
- Commercial information
- Audio, electronic, visual, thermal, olfactory, or similar information
- Inferences
Categories of sources: We have collected the Personal Information identified in this Policy from you and our payment processors.

Business and commercial purposes for collecting: We have collected the categories of Personal Information listed above for the following purposes:
- Operate the Platform
- Provide our Services to you
- Honor our Terms and Conditions and contracts
- Ensure the privacy and security of our Platform and Services
- Manage our relationships with you
- Communicate with you
- Analyze use of the Platform and our Services
- Enhance your experience
- Track visits to the Platform
- Provide you with a more personal and interactive experience on the Platform
- Usage analytics purposes
Personal Information Sold: We have not sold categories of Personal Information during the preceding 12 months.

Personal Information disclosed for a business purpose: We have disclosed for a business purpose the categories of Personal Information listed below during the preceding 12 months:
- Identifiers
- Characteristics of Personal Information described in the California Customer Records statute
- Internet or other electronic network activity information
- Geolocation data
- Commercial information
- Audio, electronic, visual, thermal, olfactory, or similar information
- Inferences
We have disclosed each category of Personal Information to the following categories of third parties:
- Corporate parents, subsidiaries, and affiliates.
- Advisors (accountants, attorneys).
- Service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support).
- Operating systems and platforms.
Consumer Rights And Requests Under The CCPA
The California Consumer Privacy Act (CCPA) provides consumers with the following rights:
- Request to Know: As a California resident, you have the right to request:
  - The specific pieces of Personal Information we have collected about you.
  - The categories of Personal Information we have collected about you.
  - The categories of sources from which the Personal Information is collected.
  - The categories of Personal Information about you that we have sold and the categories of third parties to whom the Personal Information was sold.
  - The categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose.
  - The business or commercial purpose for collecting, disclosing, or selling Personal Information.
  - The categories of third parties with whom we share Personal Information.
  - Our response will cover the 12-month period preceding our receipt of a verifiable request.
- Request to Delete: As a California resident, you have the right to request the deletion of certain Personal Information collected or maintained by us. We will delete your Personal Information from our records and direct any service providers to delete your Personal Information from their records, except where an exemption applies under the law.

Submitting a Request
- Submission of Instructions: You may submit a request to know or to delete by email to the address provided in the 'Grievances' section above or by submitting a request via mail to the address provided by us in our Terms of Use or the Platform page. We may present you with the choice to delete select portions of your Personal Information, but a global option to delete all Personal Information will be offered and more prominently presented.
- Verification Process: To verify your identity, we will match the identifying information provided in the request to the Personal Information we already maintain about you. You will be required to provide your name, email address, and mobile number (if voluntarily provided by you). We will inform you if we cannot verify your identity.
- Authorised Agents: Authorised agents may submit requests via the methods identified in this Policy. If you use an authorised agent, we may require you to provide the agent with signed permission and verify your identity directly with us.
- Excessive Requests:If requests are manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act on the request, with a notification of the reason for refusal. The fee will be based on administrative costs.
CCPA Non-Discrimination
We do not discriminate against users for exercising their rights under the CCPA and do not offer financial incentives, price or service differences due to the exercise of these rights.

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COUNTRY SPECIFIC ADDITIONAL RIGHTS