For the purposes of this Policy, “Personal Information” shall mean any personally identifiable information relating to an identified or identifiable individual, including data that identifies an individual or that could be used to identify, locate, track, or contact an individual. Personal Information includes both directly identifiable information, and indirectly identifiable information such as date of birth, unique mobile or wearable device identifier, information that could be used to identify a household, telephone number, key-coded data, or online identifiers, such as IP addresses, and includes any data that constitutes “personal data” under the Data Protection Law (as defined hereinafter). It shall also include information including, but not limited to:
- first and last name, postal address and an email address or other contact information,
- educational qualification,
- a username and password you will use to access the Website; and
- financial information such as bank account or credit card or debit card or other payment instrument details (if provided)
- all information gathered during any correspondence or interaction between you and us via emails, chats, telephone calls, SMSs, WhatsApp messages posts on public forums etc.
- any detail relating to the above clauses as provided to us for providing service; and (viii) any of the information received under above clauses by us for processing, stored or processed under lawful contract or otherwise.
All the Personal Information as mentioned above is collected, stored, and processed as per the Indian Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 or any other applicable data protection, data security or privacy law (“Data Protection Law”). Personal Information of the Users residing outside India is collected stored and processed as per the data protection laws in their respective jurisdictions such as EU General Data Protection Regulation 2016/679 (the “GDPR”) to the extent possible in consonance with the Indian Data Protection Laws as mentioned above.
- LEGAL BASIS OF PROCESSING PERSONAL INFOMRATION
We process your Personal Information on the following legitimate basis as also mandated under certain applicable laws:
- Consent: Processing based on your consent
1.2 Legitimate interests: Processing in furtherance of our legitimate interests to provide and personalise our services to you including our interests to conduct legitimate business activities (such as improving our products and services, to communicate with you, to secure our systems, among other legitimate interests like processing of payment, fraud detection, for the establishment, exercise, or defence of legal claims; or you have made the data manifestly public.
1.3 Compliance with legal obligations: We may process your personal data if necessary for us to comply with a legal obligation arising under an applicable law to which we are subject.
- TYPE OF INFOMRATION WE COLLECT
2.1 Information You Provide Us
Personal Information as defined above is collected by us when you browse or use our website and when you register as a user to subscribe to our services. We collect, process, and store your Personal Information, to provide a safe, efficient, and customized experience to our Users accessing the Website. You can browse through the Website without giving any Personal Information about yourself or by creating an account to avail of our services on the Website. These services shall include but not be limited to providing the Users with online courses, participate in public forums, sign-up for email, calls and SMS, WhatsApp updates, purchase our services. To register and create an account (“Account”), you may be required to provide us with your contact and identity information and other Personal Information as indicated on the Website and complete the registration process. Where possible, we indicate which fields are mandatorily required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature on the Website unless we require it so. Your Account Personal Information is protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your mobile phone and browser by signing off after you have finished accessing your Account. We advise you to not share login credentials/Account information with anyone to avoid unauthorized access.
2.2 Information Automatically Collected/ Acquired Information
2.2.1. Location Information and IP Address: When you access the Website, your IP (“Internet Protocol”) address is recorded by us. This method ensures smooth operations and protection against attacks and requires the user’s IP address to be saved for the duration of the session. We may be able to determine from an IP address a User’s Internet Service Provider and the geographic location of his or her point of connectivity.
2.2.2. Device Information: We collect information about the apps, browsers, and devices you use to access our website, which helps us provide features like automatic service updates. The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number.
2.2.3. Behavioural Information: We may automatically track, collect, and aggregate certain information about you based upon your behaviour on our Website or while accessing our services. We may use such information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve our Users. This information is compiled and analysed on an aggregated basis.
You agree, if you send us personal correspondence, such as emails, calls, SMSs (including WhatsApp messages) or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we may collect and/or store such information.
2.3 Third-Party Tools
2.4 User Generated Content: Content added, created, uploaded, submitted, distributed, posted by Users including but not limited to feedback, queries, chats, discussions is collectively referred to as, “User Content”. User is sole owner and responsible for the authenticity, correctness of all the UGC.
We may use your User Content, in a number of different ways in connection with the Services and Harappa’s business as we may determine in our sole discretion. By submitting User Content through the Website, you hereby do and shall grant Harappa a worldwide, non-exclusive, royalty-free, fully paid, sub-licensable (through multiple tiers) and transferable license to use, copy, reproduce, distribute, prepare derivative works of, display, perform, and otherwise fully utilise the User Content in connection with the Services and Harappa’s (and its successors and assigns’) business, including without limitation for promoting and redistributing part or all of the Website (and derivative works thereof), publicly displaying it, reformatting it, incorporating it into marketing materials, advertisements and other works, creating derivative works from it, promoting it, distributing it, and allowing other users to do the same in connection with their own websites, media platforms, and applications (“Third Party Media”),
For clarity, the foregoing license grant to Harappa does not affect your other ownership or license rights in your User Content(s), including the right to grant additional licenses to the material in your User Content(s), unless otherwise agreed in writing with Harappa.
When you delete your User Content, they will be removed from the Website. However, you understand that any removed User Content may persist in backup copies for a reasonable period of time (but following removal will not be shared with others) or may remain with users who have previously accessed or downloaded your User Content or maybe retained by Harappa for such period as stipulated under law.
If you have questions or concerns about the legal basis upon which we collect and use your personal data, you can contact us at email@example.com.
- HOW WE USE YOUR PERSONAL INFORMATION
3.1 Provide, Customize, Maintain and Improve our Services
3.2 Participation in Online Courses, Public Forums and Signing Up for Updates
We use the Personal Information as provided by you for processing purposes, including but not limited to that of following attendance, progress, and completion of your online course. We may also share details regarding your performance in a given online course with the instructor/instructors or other designated individuals who assisted you in such course. This will help us modify, alter, and operate the online course conveniently. We may also collect student generated content in the form of various assignments, peer-grading feedback, responses related to the course data in the form of exams, surveys etc. We may collect or/and store such information as provided by you.
Harappa may offer public forums. We may require your Personal information if you wish to participate and share your thoughts on these forums. Please keep in mind that such posts as shared by you will be available on our website and/or any related application, platform. We may collect and/or store such information as provided by you on these forums. We may also provide you with updates by either posting such updates on the Website or through letters, emails, calls, SMS, WhatsApp etc.
3.3 Communicate with You
We may also aggregate (gather up data across all Accounts) information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for other marketing and promotional purposes. We don’t share Personal Information that personally identifies you with advertisers, such as your name or contact information, unless you ask us to.
3.5 Services Offered on the Website by Third Parties:
3.6 Posting to Public Forums:
Please remember that if you post any of your Personal Information in public forums of the Website, such information may be collected and used by others over whom we have no control. You are to please note that these posts may be made available in the public domain.
- INTERNATIONAL DATA TRANSFER
Our website is primarily operated and managed on servers located and operated within India. However, your Personal Data may also be stored in third party data servers located in other countries where HARAPPA provides its products and services.
HARAPPA 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. 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 HARAPPA to transfer your Personal Data to HARAPPA 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. HARAPPA will always ensure transfer of your personal information internationally, will be in accordance with the applicable legal requirements.
- PROCESSING AND STORAGE
User Data is processed and stored on Harappa’s internal servers. All User data is either stored manually or electronically. Any data stored electronically will be stored in secure servers, and any data stored manually will be stored in our premises.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our websites and any transmission is at your own risk.
- WITH WHOM YOUR PERSONAL INFOMRATION IS SHARED
6.1 We do not rent, sell, or share your Personal Information with other people (save with your consent) or non-affiliated companies except to provide our products or services, or under the following circumstances:
- We will share your Personal Information with our members, employees and directors who need it to deliver the services, complete your request or carry out your instructions.
- To provide the Personal Information to trusted partners who work on behalf of or with us under confidentiality agreements. These entities may use your Personal Information to assist us in providing our services to you and help us communicate with you about offers from us and our marketing partners.
- To respond to summons, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
- From time to time, to reveal general statistical information about our website and visitors, such as number of visitors, number and type of products and services purchased, etc.
In addition to the circumstances described above, HARAPPA may disclose User’s Personal Information if required to do so:
- by law, required by any enforcement authority for investigation, by court order or in reference to any legal process.
- to conduct our business.
- for regulatory, internal compliance and audit exercise(s)
- to secure our systems; or
- to enforce or protect our rights or properties of HARAPPA or any or all its affiliates, associates, employees, directors, or officers or when we have reason to believe that disclosing Personal Information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
- Such disclosure and storage may take place without your knowledge. In that case, we shall not be liable to you or any third party for any damages howsoever arising from such disclosure and storage.
- HOW LONG DO WE KEEP YOUR DATA?
We may retain Personal Information for as long as it is necessary. It may be archived as long as we believe that the purpose for which it was used still exists or as necessary for our legitimate business interests or for complying with legal obligations or for a period as mentioned in the applicable Laws.
There will be some residual information in anonymised form that shall remain with us within our logs, database, and other records. Such residual information may or may not include Personal Information. Please also note that we shall retain your Personal Information if we require the same for complying with a legal obligation.
- DATA SECURITY
We endeavour to safeguard the User’s Personal Information by adhering to strict security guidelines and protect it against unauthorized access. Website has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. All Personal Information you provide is transmitted using minimum AES-128 encryption system. All your activity on our website from the time you logon until you logoff is encrypted with an SSL certificate to ensure it remains private. We neither capture nor store your credit/debit card information. However, we cannot guarantee.
- CHILDREN’S PRIVACY
Harappa does not engage in the collection, processing, storage, use, dissemination, and transfer of Personal Data of children. We do not knowingly collect personal information online from children under legal age which can vary from jurisdictions. If a child, the age of 13 has provided us with the personal information online such processing shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child. In the event HARAPPA becomes aware that the User is a minor or below the legal age to consent in the jurisdiction concerned, HARAPPA reserves its right to terminate all services to such User/ Account without any prior notice.
- RIGHTS AVAILABLE TO THE USER
- You have a right to access and rectify the record of your personal data maintained by the Harappa if it is inaccurate.
- You may request that the Harappa erase that data, subject to certain exceptions.
- You have the right to object, at any time to processing if you have concerns that Harappa is using your data for direct marketing purposes.
- You have a right to restrict processing. If the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead.
- When technically feasible, the Harappa will, at your request provide your personal data to you or transmit it directly to another controller.
- You may also request additional information about the purpose of the processing; the categories of personal data concerned; who else outside the Harappa might have received the data from Harappa; what the source of information was; and how long it will be stored.
- If access cannot be provided within a reasonable time frame, the Harappa will provide you with a date when the information will be provided.
In the event you wish to exercise any of the above, you may send your written request to firstname.lastname@example.org.
12. THE OPT-OUT PRACTICE
Grievance Officer: Mr. Rahul Singh
Email Id: email@example.com
Address: N-154, Panchsheel Park, New Delhi – 110017, India
DPO: Arnab Makur
Email Id: firstname.lastname@example.org
Address: 266, Okhla Phase -3 New Delhi – 110020, India