Privacy Policy

This Privacy Policy (the “Policy”) governs the manner in which the Platform collects, uses, maintains and discloses information of its users. The Policy also describes the practices that We apply to such user information, user’s privacy rights and choices regarding their information. To clarify, this Policy applies to all users of the Platform (referred to as “Learners”, “You”, “Your”).


By accessing and using the Platform, providing Your Personal Information, or by otherwise signalling Your agreement when the option is presented to You, You consent to the collection, use, and disclosure of information described in this Policy and Terms of Use and we disclaim all the liabilities arising therefrom. If You do not agree with any provisions of this Policy and/or the Terms of Use, You should not access or use the Platform or engage in communications with us and 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 be required to delete such information upon informing You of the same and revoke Your access if required without incurring any liability to You. Capitalized terms used but not defined in this Privacy Policy can be found in our Terms of Use. Please read this Policy carefully prior to accessing our Platform and using any of the services or products offered therein. If you have any questions, please contact us at the contact information provided below.

PERSONAL INFORMATION

“Personal Information” shall mean the information which identifies a Learner i.e., first and last name, identification number, email address, age, gender, location, photograph and/or phone number provided at the time of registration or any time thereafter on the Platform.

“Sensitive Personal Information” shall include (i) passwords and financial data (except the truncated last four digits of credit/debit card), (ii) health data, (iii) official identifier (such as biometric data, aadhar number, social security number, driver’s license, passport, etc.,), (iv) information about sexual life, sexual identifier, race, ethnicity, political or religious belief or affiliation, (v) account details and passwords, or (vi) other data/information categorized 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”) and in context of this Policy or other equivalent / similar legislations.

Usage of the term ‘Personal Information’ shall include ‘Sensitive Personal Information’ as may be applicable to the context of its usage.

INFORMATION WE COLLECT:

We may collect both personal and non-personal identifiable information from You in a variety of ways, including, but not limited to, when You visit our Platform, register on the Platform, and in connection with other activities, services, features or resources we make available on our Platform. However, please note that-

PERSONAL IDENTIFIABLE INFORMATION

HOW WE USE and SHARE THE INFORMATION COLLECTED

We may collect and use Your Personal Information for the following purposes:

YOUR CHOICES:

YOUR RIGHTS:

In general, all Learners have the rights specified herein this section. However, depending on where you are situated, you may have certain specific rights in respect of your Personal Information accorded by the laws of the country you are situated in. To understand Your rights, please refer to the Country Specific Additional Rights below.

If you are a Learner, you may exercise any of these rights by using the options provided to you within the Platform upon your login. If however, you are facing any issues or require any clarifications, you can always write to us at the address noted in the ‘Grievances’ section below, and we will address your concerns to the extent required by the applicable law.

PROTECTION OF YOUR INFORMATION:

We take all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of Personal Information or such other data on the Platform. Our disclosure of any such information is limited to –

THIRD PARTY WEBSITES

You may find links to the websites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. The content or links that appear on these sites are not controlled by us in any manner and we are not responsible for the practices employed by such websites. Further, these websites/links thereto, including their content, may be constantly changing and the may have their own terms of use and privacy policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that terms and policies published on such websites.

CROSS-BORDER DATA TRANSFER

Your information including any Personal Information is stored, processed, and transferred in and to the Amazon Web Service (AWS) servers and databases located in India. We may also store, process, and transfer information in and to servers in other countries depending on the location of our affiliates and service providers.

Please note that these countries may have differing (and potentially less stringent) privacy laws and that Personal Information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies, and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process.

If you use our Platform from outside India, including in the USA, EU, EEA, and UK, your information may be transferred to, stored, and processed in India. By accessing our Platform or otherwise giving us information, you consent to the transfer of 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 required for us to retain for the purposes stated hereinabove, including for the purpose of complying with legal obligation or business compliances.

Further, please note that we may not be able to delete all communications or photos, files, or other documents publicly made available by you on the Platform (for example: comments, feedback, etc.), however, we shall anonymize your Personal Information in such a way that you can no longer be identified as an individual in association with such information made available by you on the Platform. We will never disclose aggregated or de-identified information in a manner that could identify you as an individual.

Note: If you wish to exercise any of your rights (as specified in ‘Your Rights’ section below) to access, modify and delete any or all information stored about you, then you may do so by using the options provided within the Platform. You can always write to us at the email address specified in the ‘Grievances’ section below

MODIFICATION TO PRIVACY POLICY:

We may modify, revise or change our Policy from time to time; when we do, we will revise the ‘updated date’ at the beginning of this page. We encourage You to check our Platform frequently to see the recent changes. Unless stated otherwise, our current Policy applies to all information that we have about You.

GRIEVANCES:

If you have any questions about this Policy, wish to exercise your rights, concerns about privacy or grievances, please write to us with a thorough description via email to support@learnfix.com.

COUNTRY SPECIFIC ADDITIONAL RIGHTS

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 European Union (EU) or European Economic Area (EEA), you have the following rights under the UK and EU General Data Protection Regulation (GDPR) respectively. All requests should be sent to the address noted in the “Grievances” section above, and we will fulfil requests to the extent required by applicable law.

We collect and process Personal Information about you only where we have a legal rationale to do so. Specific legal rationale applied for the same will depend on the type of Personal Information collected and the context in which the same 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:


CCPA DATA PRACTICES DURING THE LAST 12 MONTHS:

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:

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:

We have disclosed each category of Personal Information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.

CONSUMER RIGHTS AND REQUESTS UNDER THE CCPA

The CCPA gives consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, and sell, and (2) delete certain Personal Information that we have collected or maintained. you may submit these requests to us as described below, and we honor these rights where they apply.

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (i) treat the request as if it had been submitted in accordance with the designated manner, or (ii) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.

Request to Know: As a California resident, you have the right to request: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the categories of sources from which the Personal Information is collected; (4) the categories of Personal Information about you that we have sold and the categories of third parties to whom the Personal Information was sold; (5) 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; (6) the business or commercial purpose for collecting, disclosing, or selling Personal Information; and (7) 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 a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and direct any service providers (as defined under applicable law) to delete your Personal Information from their records. However, we are not required to honor a deletion request if 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 address provided by us in our Terms of Use or the Platform page. Regarding requests to delete, 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: We are required by law to verify the identities of those who submit requests to know or to delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the Personal Information that we already maintain about you. As a part of this process, you will be required to provide your name and email address, and mobile number (if the same have been voluntarily provided by you at the time of registering on the Platform or otherwise while using the Platform). We will inform you if we cannot verify your identity. Please note-

Authorized Agents: Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with signed permission to do so; (2) verify your identity directly with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

Excessive Requests: If requests from a User are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the User of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

CCPA Non-Discrimination: You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against Users/consumers for exercising their rights under the CCPA.