Privacy Policy

1. Introduction

Numberone Edtech Private Limited (together with its subsidiaries, and affiliates, hereinafter "NumberOne Academy," "us," "we," or "our" or "the Company") is committed to security and management of personal data, to function effectively and successfully for the benefit of our stakeholders, customers and for the community. In doing so, it is essential that people's privacy is protected through the lawful and appropriate means for handling the personal data. Therefore, we have implemented this privacy policy (hereinafter referred to as ''Policy'').

2. Aim

This policy aims to protect personal data of the various stakeholders connected to our organization. This policy is aimed at providing individuals notice of the basic principles by which the Company processes the personal data of individuals ("Personal Data") who visits, uses, deals with and/or transacts through the website, mobile applications and includes a guest user and browser (hereinafter 'you', 'user').

3. Purpose and Scope

The purpose of this policy is to describe how NumberOne Academy collects, uses, stores, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to www.numberone.academy and Mobile app (hereinafter the "Platform"). This policy is also designed to provide information on how NumberOne Academy ensures data security, conducts data transfers and process requests from its data subjects.

This policy control applies to all systems, people and processes that constitute the organization's information systems, including board members, directors, employees and other third parties who have access to Personal Data available within NumberOne Academy.

The Company is also committed to ensure that its employees conduct themselves in line with this, and other related, policies. Where third parties process data on behalf of NumberOne Academy, the Company endeavours to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.

NumberOne Academy offers e-learning experience through our upskill courses that deliver exceptional results, taking your business and career to the next level (hereinafter individually or collectively referred to as "Program"). This Privacy Policy applies to all our services unless specified otherwise.

4. Types of Personal Data collected

The Personal Data that we collect about you depends on the context of your interactions with us, the products, services and features that you use, your location, and the applicable laws.

Personal Data is stored in personnel files or within the electronic records (on servers in India) of NumberOne Academy. The following types of Personal Data may be held by us, as appropriate, on relevant individuals:

A. Personal Identification Data

  • Your name including Last Name
  • Mobile Number
  • Email Address
  • Date Of Birth
  • Gender
  • Full Address

B. Business Data

  • Company Name
  • Full Address
  • GST Number
  • Business Topic Preferences

C. Electronic Identification Data

  • Login credentials (If you are a registered user)
  • Visitors IP Data
  • Date and time of website visit
  • Pages visited and navigation on the website
  • Browser being used
  • Language of the browser being used
  • Words searched for
  • Pixel tags
  • Information about your interactions with customer service and maintenance interactions with us.

D. Marketing Data

  • Your preferences in receiving marketing information from us
  • Your communication preferences

E. Behavioural Data

  • Data inferred or assumed information relating to your behaviour and interests based on your online activity on our sites

F. Payment Related Data

  • Billing name, billing address and payment method
  • We do not collect any payments information processed by third-party payment gateway providers.

5. Special Categories of Personal Data

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, or 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 this website for any other reason, you consent that we may use such data in accordance with applicable law and this policy.

6. Sources of data collection

The data collected by us is derived directly from the data provided by the user or by use of our Platform (including the use of any third party services through our Platform).

Data Collected when You:

  • Request a quote for the various products and services offered by us
  • Place a feedback, complete any customer surveys circulated or interact with our customer services online
  • View our courses offered services or visit our website pages on the internet or visit our Mobile application
  • Browse our website
  • When you appear for assignments or any other assessments in relation to online course
  • When you avail refunds and referrals

Data Collected from third parties

We receive your Personal Data from third parties. Third parties from whom we receive your Personal Data include, our service providers, other networks connected to our service, our advertising partners, our marketing and advertising affiliates, analytics providers, and such other third-party sources.

We may collect, process and store your account associated with any social media account (such as your Facebook and Google account) that you use to sign into the Platform or connect with or use the Platform. When you sign in to your account with your social media account information, or otherwise connect to your social media account with the Platform, You consent to our collection, storage, and use, in accordance with this Privacy Policy, of the information that you make available to us through the social media interface. This could include, without limitation, any information that you have made public through your social media account, information that the social media service shares with us, or information that is disclosed during the sign-in process. Please see your social media provider's privacy policy and help centre for more information about how they share information when you choose to connect your account.

Data Collected through Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on NumberOne Academy. They allow us to remember things about your visits to NumberOne Academy, like your preferred language, and to make the site easier to use.

NumberOne Academy and service providers acting on our behalf (like Google Analytics, Google Webmaster and third-party advertisers) use server log files and automated data collection tools like browser cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, "Data Collection Tools") when you access and use the website. These Data Collection Tools automatically track and collect certain system data and usage data when you use the websites. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

Furthermore, we may allow third-party advertising companies (such as Facebook, Google, Twitter) to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display Ads and record your activities, so they can show Ads that they consider relevant to you as you browse the Internet. These cookies store information about the content you are browsing, together with an identifier linked to your device or IP address.

7. Data Analytics

We use analytics tools and search information providers to measure how visitors interact with content on our website/platform. We also use Facebook Custom Audiences to ask Facebook to show you ads that are customized based on your interaction with our websites or our Facebook applications and to measure how you interact with those ads. Additional information on how these services use such technologies can be found on Google's website, Adobe's website and Facebook's website.

If you do not wish to have data relating to your visits to our websites collected through Google Analytics, you may opt-out by installing the Google Analytics opt-out browser add-on. You may opt-out of Facebook Custom Audiences by visiting Facebook's opt-out page.

8. Aggregated Data

"Aggregated Data" means records that have been stripped of Personal Data and has been manipulated or combined to provide generalised, anonymous information. Your identity and personal information are not available in Aggregated Data. We combine your Personal Data on an anonymous basis with other information to generate Aggregated Data for internal and commercial use and for sharing with affiliates, subsidiaries and business partners for planning and marketing purposes.

9. Data protection principles

Where third parties process data on behalf of NumberOne Academy, we endeavour to obtain assurances from such third parties that your Personal Data will be safeguarded consistently. We understand that it will be accountable for the processing, management and regulation, and storage and retention of all Personal Data held in the form of manual records and on computers.

All Personal Data obtained and held by us will:

  • be processed fairly, lawfully and in a transparent manner
  • be collected for specific, explicit, and legitimate purposes
  • be adequate, relevant and limited to what is necessary for the purposes of processing
  • be kept accurate and up to date. Every reasonable effort will be made to ensure that inaccurate data is rectified or erased without delay
  • not be kept for longer than is necessary for its given purpose
  • be processed in a manner that ensures appropriate security of Personal Data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
  • comply with the relevant laws and procedures for international transferring of Personal Data applicable to us.

10. Consent

We may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law.

Once consent is obtained from the individual to use his or her information for those purposes, NumberOne Academy has the individual's implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new use is identified.

Consent may also be implied where a user is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client, customer, member does not opt-out. Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), individuals can withhold or withdraw their consent for NumberOne Academy to use their personal information in certain ways.

Further, by using this website/ Mobile App/ acknowledging this privacy policy / by voluntarily providing us with your Personal Data, you consent to collection, storage, and processing of your Personal Data in accordance with this privacy policy and our Terms of Service.

If you refuse or subsequently withdraw your consent, or if you choose not to provide us with any required Personal Data, we may not be able to provide you the services that can be offered on our Platform.

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 hello@numberone.academy. 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.

11. Purpose of collecting Personal Data

We collect your Personal Data for the following purposes

  • To fulfil or meet the reason you provided the information for;
  • We use your information for managing and processing purposes, including, but not limited to, tracking attendance, progress and completion of a Program. As part of our management and processing of the Program, we will use certain Personal Data to administer exams, projects, and other assessments for the Program. For example, as part of a training, NumberOne Academy may use certain information collected from you in order to verify your identity or to monitor your performance during the training to confirm that you are abiding by the applicable rules or requirements;
  • To send you updates about the Programs, other NumberOne Academy events, platform maintenance or new services provided by NumberOne Academy, among other things, through itself or through third parties, via WhatsApp, email, SMS, phone call or any other medium;
  • Provide Community services;
  • To enhance the quality of our content and product offerings;
  • Compliance with security and other mandatory policies and building access;
  • Providing information to relevant external authorities for tax, social security and other purposes as legally required;
  • Conducting surveys to assess your satisfaction, including but not limited to its processes or policies;
  • Setting up and maintaining accounts and subscriptions with third parties that provide information and research services or communication services;
  • Making decisions about your continued engagement or membership;
  • Dealing with legal or regulatory disputes or investigations involving you, our work, or other partners, employees, workers and contractors, including accidents at work, potential and actual negligence claims and professional discipline matters;
  • To monitor use of our information and communication systems to ensure compliance with our policies;
  • To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution;
  • Business management and planning, including accounting, auditing and insuring;
  • Planning or reviewing options in relation to the operation or management;
  • Keeping registers required by law or regulation;
  • Communicating with you, for example to respond to inquiries;
  • Enhancing the safety and security of the services and preventing fraud, or protecting our or our customers', or your rights or property; and
  • Enforcing applicable terms and conditions and other applicable policies.

12. Advertising and Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or if you provided us with your details and expressly consented to receiving that marketing.

We may use your Personal Data and user generated data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

We also enter into agreements with third parties to serve Ads on our behalf across the internet, social networking sites and blogs. These third parties may collect Personal Data about your visits to our platform and your interactions with our products and use this information to target advertisements for goods and services.

Where electronic direct marketing communications are being sent, you have the option to opt-out in each communication sent, and this choice will be recognised and adhered to by us.

13. Disclosure of Personal Data

NumberOne Academy is a registered company and may share the personal information collected or provide such access to other companies within the NumberOne Academy group.

Examples of third parties with whom NumberOne Academy may share Personal Data includes:

  • With government bodies, including tax and social security authorities, to comply with applicable laws (including employment and tax laws), to obtain licenses or approvals, and upon request during an audit or assessment;
  • With Instructors/Teachers to improve their educational content or improve the teaching techniques, we will not share your email address, contact number or personal address with the Instructors or Teachers;
  • With suppliers, subcontractors and service providers, to maintain an efficient and commercially viable business, including technology, telecom, internet providers;
  • With professional advisers, consultants, and employment and recruitment agencies, to conduct background verification and reference checks, deal with disciplinary and grievance issues and maintain emergency contact details;
  • With our legal advisors and external auditors for legal advice and to conduct business audits;
  • With service providers for business continuity management and contingency planning in the event of business disruptions.
  • With certain companies in order to establish a membership to participate in digital wallets, payment services or rewards programme.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

14. Our Policy on Children's Data

Children's data privacy is important to us. Our Sites are not intended for children who is aged below 18 years. As a general policy, the Company does not engage in the collection, processing, storage, use, dissemination, and transfer of Personal Data of children.

In case such a collection becomes necessary for the performance of our contractual obligations, or when required under the concerned law, we shall notify you in a time-bound and appropriate manner, informing the purposes and reasons for such collection and seek your explicit consent, and where applicable, parental authorization, prior to the processing of such data.

We will take appropriate steps to delete any Personal Data of children's that has been collected on our website without verified parental consent upon learning of the existence of such Personal Data, subject to conditions stipulated in the applicable laws.

15. Data Security

NumberOne Academy will ensure that appropriate technical and organizational measures are in place, supported by privacy impact and risk assessments, to ensure a high level of security for Personal Data, and secure environment for information held both manually and electronically.

NumberOne Academy implements appropriate security measures designed to prevent unlawful or unauthorized processing of personal information and accidental loss of or damage to personal information. NumberOne Academy maintains written security management policies and procedures designed to prevent, detect, contain, and correct violations of measures taken to protect the confidentiality, integrity, availability, or security of your Personal Information. These policies and procedures assign specific data security responsibilities and accountabilities to specific individuals, include a risk management program that includes periodic risk assessment and provide an adequate framework of controls that safeguard your personal information.

In addition, as part of its organizational security measures, employees at NumberOne Academy must:

  • ensure that all files or written information of a confidential nature are stored in a secure manner and are only accessed by people who have a need and a right to access them
  • ensure that all files or written information of a confidential nature are not left where they can be read by unauthorised people
  • check regularly on the accuracy of data being entered into computers
  • always use the passwords provided to access the computer system cautiously and such access should not be circulated, unless absolutely necessary
  • use computer screen blanking to ensure that Personal Data is not left on screen when not in use.

Personal Data should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised by management of the Company. Where Personal Data is recorded on any such device it should be protected by:

  • ensuring that data is recorded on such devices only where absolutely necessary
  • using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted
  • ensuring that laptops or USB drives are not left lying around where they can be stolen.

Failure to follow the Company's rules on data security may be dealt with via the Company's disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.

We also take steps to ensure that our service providers, contractors and other third parties maintain similar level of data protection measures when processing your Personal Data. While we strive to secure your Personal Data, please note that 100% security of Personal Data cannot be guaranteed and that NumberOne Academy shall not be liable for any misuse or loss of Personal Data carried out by third party cloud service provider.

16. Data transfers

Our website is primarily operated and managed on servers located and operated within India.

NumberOne Academy engages sub-contractors, service providers and other third parties for facilitating our products, service offerings and to offer support services to you, and your Personal Data may be transferred to servers of such sub-contractors, service providers and other third parties. Depending upon the location of our service providers, your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Further, your Personal Data may be transferred may be shared, disclosed, and transferred between various NumberOne Academy group companies where such transfers are required for legitimate business reasons.

Where required under applicable law we will seek your express consent for such transfers. In all other cases, by consenting to this policy, you also provide consent to NumberOne Academy to transfer your Personal Data to NumberOne Academy affiliated companies, service providers or any third-party entity in locations around the world. We take steps to ensure that a degree of data protection which is similar to this policy is afforded to such Personal Data transferred.

We are committed to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with our data privacy and security standards.

17. Records management

Records management refers to a set of activities required for systematically controlling the creation, distribution, use, maintenance, and disposition of recorded information maintained as evidence of business activities and transactions. It is impossible to be compliant with information law without robust records management policies and practises. Good records management practices ensure not only record quality, but that Personal Data is only kept for as long as necessary for its original purpose and help support data minimization.

18. Conflicts of Law

This Policy is intended to comply with the laws and regulations in the place of establishment and of the countries in which company operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.

19. Retention of Personal Data

We retain your Personal Data, not longer than necessary for the purposes for which it was collected. The length of time to retain Personal Data depends on the purposes for which we collect and use it and/or as may be required to comply with applicable laws, to establish, exercise, or defend our legal rights.

The users can exercise their rights enumerated herein. Also, if in case required to extend the period of retention of such data, we shall obtain your consent for the same. Further, we may also dispose the data prior to completion of the period of retention, if the purpose for which it was collected is exhausted.

20. Procedures

The Company has taken the following steps to protect the Personal Data of relevant stakeholders, which it holds or to which it has access:

  • it appoints or employs employees with specific responsibilities for the processing and controlling of data
  • the comprehensive reviewing and auditing of its data protection systems and procedures
  • overviewing the effectiveness and integrity of all the data that must be protected.
  • There are clear lines of responsibility and accountability for these different roles.
  • it provides its employees with information and training to make them aware of the importance of protecting Personal Data, to teach them how to do this, and to understand how to treat information confidentially
  • it can account for all Personal Data it holds, where it comes from, who it is shared with and also who it might be shared with
  • it carries out risk assessments as part of its reviewing activities to identify any vulnerabilities in its Personal Data handling and processing, and to take measures to reduce the risks of mishandling and potential breaches of data security. The procedure includes an assessment of the impact of both use and potential misuse of Personal Data in and by the Company
  • it recognises the importance of seeking individuals' consent for obtaining, recording, using, sharing, storing and retaining their Personal Data, and regularly reviews its procedures for doing so, including the audit trails that are needed and are followed for all consent decisions. The Company understands that consent must be freely given, specific, informed and unambiguous. The Company will seek consent on a specific and individual basis where appropriate. Full information will be given regarding the activities about which consent is sought. Relevant individuals have the absolute and unimpeded right to withdraw that consent at any time
  • it has the appropriate mechanisms for detecting, reporting and investigating suspected or actual Personal Data breaches, including security breaches. It is aware of its duty to report significant breaches that cause significant harm to the affected individuals to the relevant supervisory authority, and is aware of the possible consequences
  • it is aware of the implications international transfer of Personal Data internationally.

21. Breach notification

Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the relevant supervisory authority within 72 hours of the Company becoming aware of it and may be reported in more than one instalment. Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual. If the breach is sufficient to warrant notification to the public, the Company will do so without undue delay.

22. External Links on our website

For your convenience we may provide links to sites operated by organizations other than NumberOne Academy ("Third Party Sites") that we believe may be of interest to you. We do not disclose your Personal Data to these Third-Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third-Party Sites. If you choose to click on a link to one of these Third-Party Sites, you should review the privacy policy posted on the other websites to understand how that Third-Party website collects and uses your Personal Data.

We take no responsibility for the content or practices of any third-party services in the Third Party Sites.

We encourage you to carefully review the terms of services/use of any third-party services or Third Party Sites you access.

23. Use of this website and our Terms of Service

This website is the property of the NumberOne Academy. Our Terms of Use and this Privacy Policy collectively govern the use of the Platform and the Programs offered by NumberOne Academy. This Privacy Policy shall form a part of the Terms by way of reference. By using this website and the information offered herein, you indicate your acceptance of these Terms of Use.

24. Updates to this policy

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Platform, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the Platform after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

25. Complaints about our privacy policy or use of your data

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 hello@numberone.academy with any such complaints.

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