As Published on 16th Oct 2021
In this policy, the words “we”, “our”, and “us” refer to IBSA and the privacy mechanism outlined identify personally identifiable or personal information that may be collected, how such information is used, and the choices You have regarding our use of this information.
If any information You have provided or uploaded on the Platform violates the terms of this Policy, IBSA may be required to delete such information upon informing You of the same and revoke Your access if required without incurring any liability to You.
IBSA has taken reasonable precautions as per applicable Indian law and implemented industry standards to treat Personal Information as confidential and to protect it from unauthorized access, improper use or disclosure, modification and unlawful destruction or accidental loss of the Personal Information.
User are allowed to access the Platform, register for courses and avail services available with IBSA as a guest and without creating an account on the Platform or providing any Personal Information, IBSA takes no responsibility or validate the information provided by the guest, except as otherwise required under any law, regulation or an order of competent authority. In order to have access to all the features and benefits on our Platform, a User is required to first create an account on our Platform. To create an account, a User is required to provide Personal Information as may be required during the time of registration. Other information requested on the registration page, including the ability to receive promotional offers from IBSA, is optional. IBSA may, in future, include other optional requests for information from the User to help IBSA to customize the Platform to deliver personalized information to the User. Without User’s agreement, IBSA will not share, rent or sell any Personal Information with third parties in any way other than what is disclosed in this Policy. IBSA may keep records of telephone calls received and made for making enquiries, registered courses, feedback or other purposes for the purpose of rendering services effectively and efficiently.
4. Personal Information
“Personal Information” shall mean the information which identifies the User, name, identification number, email address, age, gender, or phone number provided to IBSA at the time of registration or any time thereafter. Personal information may include “sensitive personal information or data” as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and in this context, includes passwords or any financial account information provided by You during registration.
We request You to not provide us with any Personal Information unless specifically requested by us. In such events, we bear no liability to such Personal Information provided by You.
5. Automatic Information Collection
Our system collects information that is sent over the internet without Your control. Some examples of the information we collect and analyse include the Internet protocol (IP) address used to connect Your computer to the internet; login; email; password; computer and connection information such as browser type and version, operating system, and platform; course enrolled history, which we sometimes aggregate with similar information from other users to create features, reports such as popular courses, most used features etc; the full Uniform Resource Locator (URL) click stream to, and from our Platform, including date and time; cookie number; courses or videos You viewed or searched for; the email id You used to call our customer service.
6. Information Security
To protect the security of Your Personal information during transmission, we use Secure Sockets Layer (SSL) software, which encrypts information You input. To prevent unauthorized access to sensitive information, it is important for You to monitor those who have access to Your password and to Your computer, laptop or any other device through which Your account can be accessed. Be sure to sign off when finished while using a shared computer.
However, please do note that given the nature of internet transactions, IBSA does not take any responsibility for the transmission of information including Personal Information shared by You other than as set forth in this Policy. Any transmission of information on the internet is done at Your risk and shall not be responsible for the circumvention of the privacy settings or security measures either by You or any third-party.
7. Use of your personal information
While availing our services You will provide access to IBSA with Your Personal Information. If that information is wrong, You can request us to modify or delete the same. IBSA will take all reasonable measures to ensure that the Personal Information is modified and used for rendering services to You and as otherwise in compliance with laws. When editing or deleting Personal Information, we may ask You to verify Your identity before we can act on Your request. IBSA may at its discretion reject any request that is contrary to law, requires un-reasonable technical efforts. We do not assure that we will delete all residual copies and archives made by any third party without our knowledge and consent. We never retain Your Personal Information longer than it is required for the purposes of providing services through the Platform or as required by applicable Indian law. At times, we may also require to transfer Your Personal Information to third-party service providers, for instance to authorize transactions we may share Your financial data with such third-party providers. You hereby consent to Your transfer of Personal Information in all such instances. IBSA carries out all such transfers strictly in accordance with law.
IBSA shall use Your Personal Information to ensure services with respect to the Platform are presented to You in the most effective manner, to secure the Platform and make improvements, to carry out our obligations to You, and to communicate with You. The said communication can either be by calls, text or emails and for purposes which include transactional, service, or promotional calls or messages. If at any time You wish to not receive any communication from our end You can opt-out of the same by writing to us on email@example.com .
Your Personal Information may be shared with third parties who have a need or authority to receive such information, if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to comply with (i) in response to any authority having to receive such information under law (ii) any order of court (iii) detect, prevent, or otherwise address fraud, security or technical issues (iv) protect against harm to the rights, property or safety of IBSA, our users or the public as required or permitted by law.
9. User choices with regard to access of information
IBSA does not make any unsolicited calls or otherwise market any products or services, except for in relation to the purpose for which such information has been provided or taking any feedback, addressing any complaints, informing You about new features or free/paid courses. User shall not disclose their Personal Information to any third parties that is not authorised by IBSA and verify the identity of such person who seek information. IBSA will communicate with the Users through call, SMS, email or notices posted on the Platform or through any other means available, which shall include but not be limited to text, other forms of messaging, calls etc. The Users can change their e-mail and contact preferences at any time by logging into their account or by emailing at firstname.lastname@example.org.
IBSA may, if You so choose, send direct mailers to You at the address given by You. You have the option to ‘opt-out’ of this direct mailer by way of links provided at the bottom of each mailer. We respect Your privacy and to the extent that You choose not to receive such mailers, we will take all steps to remove You from the list. Should You evidence any violation of our terms and policies, please write to us at email@example.com and report such incident.
All the information provided to IBSA by You, You as a User confirms that the same including sensitive Personal Information, is true, accurate and voluntary. User has the right to withdraw information at any time, in accordance with the terms of this Policy and the Terms of Service.
10. Report, Analysis & Confidentiality
IBSA may have to use Personal Information without reference to any persona or identity for research, statistical analysis improving the Platform of functionalities offered thereon and business intelligence purpose and may transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.
All IBSA employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every User’s sensitive personal data and information.
11. Sharing of Information
IBSA may also disclose or transfer User’s personal and other information which a User provides, to another third party as part of reorganization or a sale of the assets of IBSA corporation division or company. Any third party to which IBSA transfers or sells its assets will have the right to continue to use the personal and other information that a User provide to us.
To the extent necessary to provide Users with the services on the Platform, IBSA may provide User’s Personal Information to third party contractors who work on behalf of or with IBSA to provide Users with such services, to help IBSA communicate with Users or to maintain the Platform. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Platform, including the providers of online communications services, online payment gateway services, will have rights to use and disclose the Personal Information collected in connection with the provision of these services in accordance with their own privacy policies.
Furthermore, please note that we cannot control the actions of other Users of the Platform with whom You may choose to share Your Personal Information, and any such actions on Your behalf shall be solely Your responsibility.
12. Interest-Based Ads
On unaffiliated sites, IBSA may display interest-based advertising using information You make available to us when You interact with our Platform, content, or services. Interest-based ads, also sometimes referred to as personalised or targeted ads, are displayed to You based on information from activities such as subscription on our Platform, visiting sites that contain IBSA content or ads. In providing interest-based ads, we follow applicable Indian laws, as well as the Code for Self-Regulation in Advertising by the Advertising Standards Council of India and the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance (a coalition of marketing, online advertising, and consumer advocacy organizations).
We do not provide any personal information to advertisers or to third party sites that display our interest-based ads. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalised ad or content are part of the group that the ad or content is directed towards (for example, users in eastern India who bought or browsed for literature books). Also, some third-parties may provide us information about You (such as the sites where You have been shown ads or demographic information) from offline and online sources that we may use to provide You more relevant and useful advertising.
13. Revision of terms & Grievance reporting
IBSA may update or amend this Policy at any time, with or without advance notice. In the event there are significant changes in the way IBSA treats User’s personally identifiable information, IBSA will display a notice on the Platform or send Users an email. IBSA’s current Policy to all information that IBSA has about Users and their account.
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