The "Data Controller" (i.e., Edurup Schools) means the entity that will make the decisions about how your data is used and that is responsible for deciding how it holds personal information about you. Since Edurup Schools is made up of different legal entities, the entity who will be the controller for your data is dependent on the situation where your personal data is collected.
We process your data on the basis of the following:
We collect certain data from you directly, like the information you enter yourself, data about your participation in courses, and data from third-party platforms you connect with Edurup Schools. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.
2.1 Data You Provide to Us
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.
When you create an account and/or use the Services, including through a third-party platform, we collect the following data:
|Account and Related Data||In order to use certain features (like applying for a program), you need to create a user account. When you create or update your account, or provide your information via any other forms or means, we collect and store the data you provide, like your name, email address, password, city, age, guardian name, residential and contact details (if required), date of birth, program/courses you like to learn, IP address, educational qualification, work experience, salary, resume, gender, socio-economic status, industry where you work, job title, company name, photograph, signature, phone number, and assign you a unique identifying number (“Account Data”). If you are a registered user, we may also have access to your login credentials.|
|Profile Data||You can also choose to provide profile information like a photo, social media profile, or other data. Your Profile Data will be publicly viewable by others.|
|Other Identification Data||In order to provide our Services, we may request you to provide certain other identification details such as Social security, tax, Permanent Account Number, Aadhar Card number, or such similar identification details.|
|Shared Content||Parts of the Services let you interact with other users or share content publicly, including by sharing your e-portfolio, sharing your testimonial, sending messages to program managers, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.|
|Program Data||When you enroll into a program, we collect certain data including without limitation which program, courses, assignments and quizzes you’ve started and completed; your exchanges with instructors, teaching assistants, and other students; and essays, answers to questions, other items submitted to satisfy course requirements, web-cam recordings, posts made to public forums through our Services.
To clarify, Edurup Schools, or its educational partners and third-party service providers may also collect certain information from you in conjunction with enrolment, admission, assignments, exams and other assessments related to the programs. For example, as part of a proctored exam for a course, Edurup Schools (or its third-party service providers) may collect certain personally identifiable data from you in order to (a) verify or authenticate your identity or submissions made by you, such as a signature for a test or an assignment log, a photograph or a recording of you (e.g., using a webcam) or information included on a photo identification card or document, or (b) monitor your performance during an exam to confirm that you are abiding by the applicable test rules or requirements (e.g., confirming that you are not using prohibited resources). Edurup Schools may also collect information from you or about your performance or your accomplishments, such as quiz/exam scores, grades, project evaluations, teacher evaluations and other evaluations of your performance or accomplishments.
|Student Payment Data||If you make payments, we collect certain data about your payment (such as your name and email id) as necessary to process your payment. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code. For security, Edurup Schools does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data. However, in the case of scholarships, refunds or referrals, we may collect your bank account, payment gateway or e-wallet account related information.|
|Data About Your Accounts on Other Services||We may obtain certain information through your social media or other online accounts if they are connected to your Edurup Schools account. If you log in to Edurup Schools via LinkedIn or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, educational details, professional details, account ID number, login email address, physical address etc.
Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
|Third Parties||We are also working closely with third parties (including, for example, educational partners, scholarship providers, marketing partners, sales affiliates, subcontractors in technical/advertising networks, analytics providers, and search information providers) and may receive information about you from such sources. We may also receive your information from your employers, educational institution or scholarship providers, where your program is partly or fully sponsored by such a third-party. The third-party sponsoring your participation in the programs may provide us your information, subject to our agreement with them and, therefore, the third-party sponsor may be the controller with respect to such data. In cases where you have been referred under any referral scheme, we will receive your information from the referrer.|
|Behavioural Data||Data inferred or assumed information relating to your behaviour and interests based on your online activity on our sites, which may be derived from the Usage Data (mentioned below).|
|Data Provided through Inquiries||While you inquire about our services, you may provide, or would be requested to provide personal data (stated in the inquiry form, or otherwise) such as name, address, phone number, country, subject of inquiry, personal details (name on the card, billing address), payment details (card numbers, card type), recordings of calls with students and users showing interest in our programs, information about your interactions with customer service and maintenance interactions with us.|
|Legal Requirements||Information needed in order to comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others|
|Any other information||Any other information you choose to directly provide to us in connection with your use of the Services|
The data listed above is stored by us and associated with your account.
Special Category of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade unions memberships, information about your health and genetic and biometric data. We do not collect or process any special or sensitive personal data.
Should we specifically require “special” or “sensitive” personal data in connection with one or more of the uses described below, we will request your explicit consent to use the data in accordance with this policy and/or in the ways described at the point where you were asked to disclose the data.
Other legal basis for our processing of special category data may include, as permitted by applicable law, for scientific research, for employment, social security or social protection law, for reasons of substantial public interest, or as necessary for the establishment, exercise or defence of legal claims. If you voluntarily share with us or post/upload any “special” or “sensitive” Personal Data to our platforms for any other reason, you consent that we may use such data in accordance with applicable law and this policy. You can contact our DPO for more information about our processing of your Personal Data.
2.1 Data You Provide to Us
When you access the Services (including browsing courses), we collect certain data by automated means, including:
|System Data||Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain, and other systems data, and platform types (“System Data”).|
|Usage Data||Usage statistics about your interactions with the Services, including programs and courses accessed, time spent on pages or the Service, pages visited, features used, click data, date and time, and other data regarding your use of the Services (“Usage Data”).|
|Approximate Geographic Data||An approximate geographic location, including information like country, city, and geographic coordinates.|
The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.
3. How We Get Data About You
We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
3.1 Cookies and Data Collection Tools
Edurup Schools uses the following types of cookies:
Some of the third-party partners who provide certain features on our site may also use Local Storage Objects (also known as flash cookies or LSOs) to collect and store data.
We use the 3rd-party browser and mobile analytics services like Google Analytics, Hotjar, GetSiteControl, Mixpanel, WebEngage, Wistia, YouTube and Drift on the Services. These services use Data Collection Tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data. We use this data to improve the Services, better understand how the Services perform on different devices and provide information that may be of interest to you.
3.3 Online Advertising
We use third-party advertising services like Facebook, Google’s ad services, and other ad networks and ad servers to deliver advertising about our Services on other websites and applications you use. The ads may be based on things we know about you, like your Usage Data and System Data (as detailed in Section 2.2), and things that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.
Depending on the types of advertising services we use, they may place cookies or other tracking technologies on your computer, phone, or other devices to collect data about your use of our Services, and may access those tracking technologies in order to serve these tailored advertisements to you. To help deliver tailored advertising, we may provide the service providers with your email address and content that you share publicly on the Services. Additionally, we have third-party sales and marketing affiliates who may collect your information through one of the various channels owned by them and share this information with us, based on your interest in our Services. For example, an affiliate may hold an event and share the details of the attendees with Edurup Schools. Please note that any third parties, including third parties mentioned in Section 2, are not permitted by Edurup Schools to sell or share your data as part of this process. If such third parties sell or share the data as part of the process, Edurup Schools’s sole liability shall be limited to providing you with reasonable assistance in any action you may choose to take against such third parties, at your sole cost and expense.
4.1 How we use your data
We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity.
We use the data we collect through your use of the Services to:
4.2 Criterion For Determining Data Retention Period
It is not possible for us to determine a specific period for which we may retain your data. However, we will retain your data for longer than necessary, taking into account the following:
We share certain data about you with instructors, program managers, other students, companies performing services for us, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
Any data that is voluntarily displayed by you on the Edurup Schools’s platforms may be used by third parties for unsolicited purposes. Please note that we shall not be liable for such unsolicited use by third parties of your data that has been voluntarily displayed by you.
We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.
As an ISO 27001:2013 certified organization, we adhere to the best practices and standards for maintaining the confidentiality, integrity, and availability of your data. Edurup Schools takes appropriate security measures such as using HTTPS to transfer your data to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Edurup Schools, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately.
You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data such as to restrict/object our processing of your data, to erase all data we have stored about you, and the right to ask for the data to be provided to you/ported to any other service in a commonly used machine readable format.
Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.
7.1 Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services
If you have any questions about your data, our use of it, or your rights, contact us at email@example.com .
7.2 Accessing, Updating and Correcting, Porting and Deleting Your Personal Data
You can access and update your personal data that Edurup Schools collects and maintains as follows:
7.3 Revocation of Consent
We recognise that the processing of your data may be based on your consent. In case you wish to withdraw such consent given to us for the processing of your data as identified above, please e-mail us at firstname.lastname@example.org. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and may need to verify your identity before implementing your request.
Further, please note that such revocation of consent shall be prospective in nature, and shall not affect the lawfulness of any data processed based on your consent given prior to revocation.
While we take all measures to protect and secure your data, we understand that you may have grievances about our use of your data, or of our data protection measures. Please feel free to reach out to us at email@example.com with any such complaints.
In case you are not satisfied with our response, you can also reach out to the national data protection authorities in your region (provided you are in the EU). The list of national data protection authorities for EU member states may be accessed here.
Please note that while we urge you to write to us for any grievances or with any complaints you may have, this does not preclude you from directly approaching the national data protection authorities mentioned above.
7.5 Our Policy Concerning Children
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Our Services are not intended for children under 13 (or under 16 in the European Economic Area), and the children under these ages may not use the Services. If we learn that we’ve collected personal data from a child under those ages without verified parental consent, we will take reasonable steps to delete it. Parents or guardians who believe that Edurup Schools may have collected personal data from a child under those ages can submit a request that it be removed to firstname.lastname@example.org
If you live in California, you have certain rights to request information. Users outside of the United States should note that we transfer data to India and other areas outside of the European Economic Area.
8.1 Users in California
If you are a California resident, you have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to email@example.com.
Since the internet industry is still working on Do Not Track standards, solutions, and implementations, we do not currently recognize or respond to browser-initiated Do Not Track signals.
8.2 Users Outside of the U.S.
Edurup Schools in order to provide the Services to you, will transfer your data to India and process it there. By visiting or using our Services, you consent to the storage of your data on servers located in India. If you are using the Services from outside India, you consent to the transfer, storage, and processing of your data in and to India or other countries. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.
That data is also processed outside of Switzerland and the EEA by Edurup Schools, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf, with appropriate safeguards to ensure security of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Edurup Schools and its processors.
When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email with any questions, concerns, or disputes.
The Data Protection Officer appointed by Edurup Schools is Mr. Murali Malladi, who can be reached at firstname.lastname@example.org, and addressed as such.
What are cookies?
Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your activities across websites, including on Edurup Schools. Cookies also allow us to remember things about your visits to Edurup Schools, like your account ID, and to make the site easier to use.
We use both session cookies, which expire after a short time or when you close your browser, and persistent cookies, which remain stored in your browser for a set period of time. We use session cookies to identify you during a single browsing session, like when you log into Edurup Schools. We use persistent cookies where we need to identify you over a longer period, like when you request that we keep you signed in.
|Authentication and security||
For example, cookies help authenticate your access to Edurup Schools and prevent unauthorized parties from accessing your accounts
For example, cookies help us remember the program you’re interested in, so we can provide communication relevant to this program each time you visit.
|Analytics and research||
For example, cookies help us test different versions of Edurup Schools to see which features or content users prefer, web beacons help us determine which email messages are opened, and cookies help us see how you interact with Edurup Schools, like the links you click on.
For example, cookies help us show a personalized list of recommended programs on the homepage.
To learn more about targeting and advertising cookies and how you can opt out, visit www.allaboutcookies.org/manage-cookies/index.html, or if you’re located in the European Union, visit the Your Online Choices site.
Please note that where advertising technology is integrated into the Services, you may still receive advertising on other websites and applications, but it will not be tailored to your interests.
When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide its own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.
What are my privacy options?
12.1 Background And Objectives Of Policy
This document sets forth a prevention policy of payment frauds, to enforce controls and to aid in prevention and detection of payment frauds at Edurup Schools. The intent of the policy is to make you aware of the standard payment procedure that you have to follow for making any payments for availing our Services, and providing guidelines for reporting and conduct of investigations of suspected fraudulent behaviour.
12.2 Standard Payment Process
You have to make all the relevant payments with respect to the Service you are availing through Edurup Schools’s official learning platform ‘Olympus’. No representative from Edurup Schools will request you to make payments through any other medium. In case you have any queries, please feel free to write to us at email@example.com before initiating the payment process. Additionally, if you receive any such unusual request from any of our representatives/purported representatives, you may report this behavior by writing to us at firstname.lastname@example.org.
12.3 Actions Constituting Payment Fraud
Following acts may constitute a payment fraud:
Please note that the aforementioned list is not an exhaustive list with respect to the subject matter, and shall only be construed as an indicative list.
12.4 Reporting Process
If you suspect, or are a victim of payment fraud, please forthwith write to us at email@example.com and share all the relevant proofs and correspondence with respect to the transaction in question. We will look into the matter and conduct the necessary investigation as per our internal process and guidelines. If required, we will take the appropriate disciplinary and legal action against the offender.
12.5 False Reporting
If it is established that you have falsely raised the complaint, then without prejudice to legal rights and remedies that Edurup Schools may have, we will also be entitled to terminate the provision of our Services to you without any legal or financial liabilities towards you.