PRIVACY POLICY
Last updated: April 24, 2023
1. Introduction
Welcome to https://sibsagarcomcollege.myclasscampus.com/ (“Website”) and
Sibsagar Commerce College mobile application for android and iOS operating systems (“Application”),
a cloud based ERP product available for educational organizations on a
subscription basis and can be accessed through the web and the mobile
applications (Website and Mobile App are hereinafter collectively referred to
as “Platform”) owned and managed by Teachmint Technologies
Private Limited and its affiliates (“Company”).
Your visit and use of the Platform for accessing and
managing the ERP products (“Services”) are subject to this privacy,
security and cookies policy (“Privacy Policy”) and other terms and
conditions of the Platform. This Privacy Policy ensures our firm commitment to
your privacy vis-à-vis the protection of your information.
If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.
In this Privacy Policy "we", "our" and
"us" refers to the Company and "you", "your"
and/or “Users” refers to the user of the Platform. Our Platform is for
teachers and students.
You must be 18 years of age or older to visit or use the
Website and/or Application in any manner. If you are under the age of 18, you
should review this Privacy Policy with your parent or legal guardian to make
sure that you and your parent or legal guardian understands and agrees to it
and further, if required, you shall perform or undertake such activities which
will entitle you to enter into a legally binding agreement with the Company. If
you are availing the Services on behalf of a legal entity as admin user (“Admin
User”), you represent and warrant that you have the actual authority to
agree to the terms and conditions of this agreement on behalf of such legal entity.
By visiting this Website and/or Application or accepting this Privacy Policy,
you represent and warrant to the Company that you are 18 years of age or older,
and that you have the right, authority and capacity to use the Website and/or
Application and agree to and abide by this Privacy Policy. You also represent
and warrant to the Company that you will use this Privacy Policy in a manner
consistent with any and all applicable laws and regulations.
This document is published and shall be construed in
accordance with the provisions of the Information
Technology (Reasonable Security Practices and Procedures and Sensitive Personal
Data or Information) Rules, 2011 (“Data Protection Rules”) under
the Information Technology Act, 2000; that require publishing of the Privacy
Policy for collection, use, storage and transfer of information. The
information collected from you could be categorized as “Personal Information”,
“Sensitive Personal Information” and “Associated Information”.
Personal Information, Sensitive Personal Information and Associated Information
(each as individually defined under the Data Protection Rules) shall
collectively be referred to as “Information” or “Personal Information”
or “Personal Data” in this Policy
This Privacy Policy is an electronic record in the form of
an electronic contract formed under the Information Technology Act, 2000, rules
made thereunder, and any other applicable statutes, as amended from time to
time. This Privacy Policy does not require any physical, electronic or digital
signature.
Please read this Privacy Policy carefully. By using the
Platform, you indicate, agree and acknowledge that you understand, agree and
consent to this Privacy Policy and to the collection and use of information in
accordance with this Privacy Policy.
Our Privacy Policy governs your use of the Services on the
Platform, and explains how we collect, safeguard and disclose information that
results from your use of the Service. We reserve the right to amend and
supplement to complete this Privacy Policy at any time. Whenever there is a
change to our Privacy Policy, we post updates on our Website and/or
Application. We encourage you to regularly review this Privacy Policy to get
the latest updates to ensure you know and exercise the right to manage your
Personal Information.
Our Terms and Conditions (“Terms”) govern all use of
our Service and together with the Privacy Policy constitutes your agreement
with us (“Agreement”).
2. Definitions
Unless otherwise defined elsewhere in this Privacy Policy,
the following terms shall have the meanings assigned to them as herein below
for the purposes of this Privacy Policy:
“USAGE DATA” means information and data collected and
captured as a result of the use of Service.
“COOKIES” mean small data files stored on your device
(computer or mobile device).
“DATA CONTROLLER” means a natural or legal person who
(either alone or jointly or in common with other persons) determines the
purposes for which and the manner in which any Personal Data are, or are to be,
processed. For the purpose of this Privacy Policy, we are a Data Controller of
your data.
“DATA PROCESSORS” OR “SERVICE PROVIDERS” means
any natural or legal person who processes the data on behalf of the Data
Controller. We may use the services of various Service Providers in order to
process your data more effectively.
3. Information Collection and Use
3.1 Collection of Data
In order to avail the Services on
the Platform, account registration by the User is mandatory. You are required
to provide various Personal Information at the time of registration. You are
fully responsible for all activities that occur under your account. You
specifically agree that the Company shall not be responsible for unauthorized
access to or alteration of your transmissions or data, any material or data
sent or received or not sent or received through the Platform. By registering,
you consent to provide information including Personal Data.
The Company respects the privacy
of the Users of the Services and is committed to reasonably protect it in all
respects. The information about the user as collected by the Company are:
·
Information supplied by Users
·
Information automatically tracked while navigation
·
Inferred information through usage and log data
·
Information collected from any other sources (like third party
providers or social media platforms)
In order to provide Services and
to maintain and improve the Platform, we require certain information (including
Personal Data), and when you express an interest in obtaining information about
us or our products and Services, when you participate in activities on our
Platform or otherwise contact us. Such Personal Data may be collected in
various ways including during the course of your:
·
Registration as a User on the Platform, and/or registering for an
event, promotion or a campaign and/or otherwise interact with us;
·
Availing Services offered on the Platform. Instances of such
Services include but are not limited to, communicating with the Company
customer service by phone, email or otherwise or posting user reviews in
relation to Services/products available on the Platform;
·
Granting permission to share credentials of your online accounts
maintain with third parties. We may receive Personal information about you from
such third parties, including commercially available sources and business
partners. If you access the Platform through a connect a service on the
Platform, the information we collect may include your information available
through such connected service.
In order to provide Services and
to maintain and improve the Platform, we require you to grant certain access
right to your phone or other system including but not limited to microphone,
camera, location, storage, calendar etc.
For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to Image, Video, all documents, mp3, mp4, etc. The information that we request will be retained by us and used as described in this privacy policy.
3.2 Types of Data Collected
We collect different types of
information, including Personal Data, for various purposes to provide and
improve our Service for you.
(1)
Personal Data
While using our Service, we may
ask you to provide us with certain Personal Data i.e. personally identifiable
information that can be used to contact or identify you. Personal Data may
include, but is not limited to:
·
Email address
·
First name and last name
·
Phone number
·
Address, Country, State, Province, ZIP/Postal/Pin code, City
·
Other contact information
·
Gender and other demographics
·
Date of birth and age
·
Location Data
·
Cookies and Usage Data
·
Profile Image
We may use your Personal Data to
contact you with newsletters, marketing or promotional materials and other
information that may be of interest to you. You may opt out of receiving any,
or all, of these communications from us by following the unsubscribe link.
(2)
Usage Data
We may also collect information
that your browser sends whenever you visit our Platform and/or use the Service
or when you access the Platform by or through any device (“Usage Data”).
This Usage Data may include
information such as server log, your computer’s Internet Protocol address (e.g.
IP address), browser type, browser version, the pages of our Service that you
visit, referring site/webpage, the time and date of your visit, the time spent
on those pages, unique device identifiers and other diagnostic data.
When you access the Platform with
a device, this Usage Data may include information such as the type of device
you use, your device unique ID, the IP address of your device, your device
operating system, the type of Internet browser you use, unique device
identifiers and other diagnostic data.
(3)
Location Data
We may use and store information
about your location if you give us permission to do so (“Location Data”).
We use this data to provide features of our Service, to improve and customize
our Service.
(4)
Tracking Cookies Data
We may use cookies , web beacons and similar tracking technologies to
track the activity on our Platform and we may hold certain information. We may use a web beacon (electronic images or also known as
clear gifs) to recognize certain types of information on users computer such as
time and date of page view, users cookie number, page description.
Cookies are files with a small
amount of data which may include an anonymous unique identifier. Cookies are
sent to your browser from a website and stored on your device. Other tracking
technologies are also used such as beacons, tags and scripts to collect and
track information and to improve and analyze our Service.
You can instruct your browser to
refuse all cookies or to indicate when a cookie is being sent. However, if you
do not accept cookies, you may not be able to use some portions of our Service
(5)
Other Data
We may also collect the following
information and data: place of birth, passport details, citizenship,
registration at place of residence and actual address, telephone number (work,
mobile), details of documents on education, qualification, professional
training, employment agreements, non-disclosure agreements, information on
bonuses and compensation, information on marital status, family members, social
security (or other taxpayer identification) number, office location,
photograph, information regarding your transactions on the Platform, (including
purchase history), your financial information such as bank account information
or credit card or debit card or other payment instrument details and other
data.
3.3 Purpose for Collection and Use of Data
All required information is
Service dependent and the Company may use the above said user Information to,
maintain, protect, and improve the Services (including advertising) and for
developing new services. Any Personal Data provided by you will not be
considered as sensitive if it is freely available and / or accessible in the
public domain like any comments, messages, blogs, scribbles available on social
platforms like Facebook, twitter etc
The Company uses the collected
data for various purposes including as follows:
·
To create and maintain an online account with the Platform;
·
to maintain our Platform and enable you to avail the Services;
·
to notify you about changes to our Service
and to execute your request for the products and the services;
·
to allow you to participate in interactive features of our
Service when you choose to do so;
·
to enable the viewing of content in your interest;
·
to provide customer support;
·
to analyse information so that we can improve our Platform and
Services;
·
To notify the necessary information related to the Platform and
Services and your online account on the Platform from time to time, and to contact you to provide the relevant information
regarding any events, promotions;
·
to monitor your usage of our Platform and Services;
·
To maintain records and provide you with an efficient, safe and
customized experience while using the Platform;
·
to detect, prevent and address technical issues;
·
To furnish your information to Service Providers to the extent
necessary for delivering the relevant Services;
·
Aggregated and individual, anonymized and non-anonymized data may
periodically be transmitted to Service Providers to help us improve the
Platform and our Services;
·
to fulfil any other purpose for which you provide it;
·
to verify your identity and prevent fraud or other unauthorized
or illegal activity;
·
to carry out our obligations and enforce our rights arising from
any contracts entered into between you and us, including for billing and
collection;
·
to provide you with notices about your account and/or
subscription, including expiration and renewal notices, email-instructions,
etc.;
·
To dispatch transaction-related communications such as welcome
letters, billing reminders, and purchase confirmations;
·
For general management and reporting purposes, such as invoicing
and account management;
·
to provide you with news, special offers and general information
about other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about;
·
in any other way we may describe when you provide the
information;
·
To provide aggregate statistics about Users, traffic patterns,
and other related information to reputable third parties, however this
information when disclosed will be in an aggregate form and does not contain
any of personally identifiable information;
·
to comply with applicable laws, rules, and regulations; and
·
for any other purpose with your consent.
You agree that we may use
Personal Information about you or share the same with third party service
provider to improve our marketing and promotional efforts, to analyse site
usage, improve the Platform's content and Service offerings, and customise the
Platform's content, layout, and Services. These uses improve the Platform and
better tailor it to meet your needs, so as to provide you with an efficient,
safe and customized experience while using the Platform. It is clarified that
the third-party service provider shall not have right with respect to Personal
Information and shall use the Personal Information for the limited purpose for
which it has been provided or retain the same for purposes of compliance of
applicable law or in complete anonymize form for analytical purposes. Such
third-party service provider may store the Personal Information in the servers
located in India or outside India.
You authorize us to contact you
via email or phone call or sms and offer you our Services, imparting product
knowledge, offer promotional offers running on Application, for which reasons,
Personal Information collected may be used. Further, irrespective of the fact
that you may have registered yourself under DND or DNC or NCPR service, you
still authorize us to give you a call for the above mentioned purposes for a
total period of 365 days from the date of your registration with us.
3.4 Retention of Data
We will retain your Personal Data
only for as long as is necessary for the purposes set out in this Privacy
Policy. We will retain and use your Personal Data to the extent necessary to
comply with our legal obligations (for example, if we are required to retain
your data to comply with applicable laws), resolve disputes, and enforce our
legal agreements and policies.
We will also retain Usage Data
for internal analysis purposes. Usage Data is generally retained for a shorter
period, except when this data is used to strengthen the security or to improve
the functionality of our Service, or we are legally obligated to retain this
data for longer time periods.
Mailing list information,
discussion posts and email are kept for only the period of time considered
reasonable to facilitate the User's requests.
We reserve the right to retain
the aggregated and anonymized data derived from the Personal Data collected
from the users of the Platform including your Personal Data, for any purposes
(commercial and non-commercial) as the Company deem fit and proper.
3.5 Withdrawal of Consent
To the extent possible, we
provide you with the option of not divulging any specific information that you
wish for us not to collect, store or use. You may also choose not to use a
particular service or feature on the Platform and opt-out of any non-essential
communications from the Platform.
You may withdraw your consent
given for collecting any Information and Personal Data under this Privacy
Policy and pursuant to use of the Services, at any time by sending an email to [email protected].
In such an event, the Company reserves the right to not allow you further usage
of the Website and the Application or provide/use any Services thereunder,
without any obligations or liability, whatsoever, whether in contract, tort,
law, equity or otherwise, in this regard.
4. Disclosure of Data
We may disclose the information including Personal Data that
we collect, or you provided on our Platform as follows:
4.1 Disclosure for Law Enforcement and other legal necessity.
We reserve the right to use or
disclose your Personal Data in response to any statutory or legal requirements.
We will use and disclose your Personal Data if we believe you will harm the
property or our rights or right of the other Users of our Platform. Finally, we
will use or disclose your Personal Data if we believe it is necessary to share
information in order to investigate, prevent, or take action regarding illegal
activities, suspected fraud, situations involving potential threats to the
physical safety of any person or property, violations of the Platform’s other
policies, or as otherwise required by law when responding to subpoenas, court
orders and other legal processes.
We reserve the right to use or
disclose your Personal Data and other information if we believe that disclosure
is necessary or appropriate to protect rights, property and safety of the
Company, its users, customers, Service Providers, officers and shareholders. We
may also in good faith share information with other organizations and entities
for the purposes of fraud protection and credit risk reduction.
4.2 Business Transaction
If we or our group entities are
involved in a merger, acquisition or asset sale, and/or in the event the
ownership or control of our Platform changes, we may transfer your information
to the new owner.
4.3 Disclosure by the User
When you use certain features on
the Platform like the discussion forums and you post or share your Personal
Information as comments, messages, files, photos on such discussion forums on
the Platform, which is freely accessible to group of other users and/or the
public, the same will be available to all such users and/or public. All such
sharing of information will be done at your own risk. Please keep in mind that
if you disclose Personal Information in posting as comments, messages, files,
photos on the discussion forums on the Platform, such information may become
publicly available.
4.4 Other Disclosures
We may also disclose your
Personal Data as follows:
·
to our subsidiaries and affiliates;
·
to contractors, Service Providers, and other third parties we use
to support our business in compliance with the provisions of this Privacy
Policy;
·
to fulfil the purpose for which you provide it;
·
for the purpose of including your institution / company’s logo on
our website;
·
for any other purpose disclosed by us when you provide the
information; and
·
with your consent in any other cases.
4.5
Data Processing by the Service Providers
We may engage and employ third
party companies and individuals to perform certain processing activities and to
perform Service (“Service Providers”), to provide Service on our behalf,
perform Service-related activities or assist us in analysing how our Service is
used. Towards that objective, we may share your Personal Information with such
Service Providers.
The Service Providers may be
engaged and employed for various purposes including following:
·
Analytics: We may use Service Providers to monitor and analyze
the use of our Service and the Usage Data.
·
CI/CD tools: We may use Service Providers to update and automate
the development process of our Platform.
·
Behavioural Remarketing
We may use remarketing services
to advertise on third party websites to you after you visited our Platform. We
and our Service Provider use cookies to inform, optimise and serve ads based on
your past visits to our Platform.
4.6 Google Analytics
We use Google Analytics to help
us to understand how you make use of our content and work out how we can make
things better. These cookies follow your progress through us, collecting
anonymous data on where you have come from, which pages you visit, and how long
you spend on the Platform. This data is then stored by Google to create
reports. These cookies do not store your Personal Data.
The information generated by the
cookie about your use of the Platform, including your IP address, may be
transmitted to and stored by Google on servers in the United States. Google may
use this information for the purpose of evaluating your use of the website,
compiling reports on website activity for us and providing other services
relating to website activity and internet usage.
Google may also transfer this
information to third parties where required to do so by law, or where such
third parties process the information on Google's behalf. Google will not
associate your IP address with any other data held by Google. By using this
Platform, you consent to the processing of data about you by Google in the
manner and for the purposes set out above. The Google website contains further
information about Analytics and a copy of Google's privacy policy pages.
4.7 Google Ad Sense
Google Ad Sense is a tool that
allows website publishers to deliver advertisements to site visitors in
exchange for revenue calculated on a per-click or per-impression basis. To do
this, Google uses cookies and tracking technology to deliver ads personalized
to a website user/visitor. In this regard the following terms are specified to
the Users:
·
Third-party vendors, including Google, use cookies to serve ads
based on your prior visits to our website or other websites.
·
Google's use of advertising cookies enables us and our partners
to serve advertisements to you based on their visit to our Platform and/or
other websites on the Internet.
·
You may opt-out of personalized advertising by visiting Ads
Settings.
·
All advertisements of third parties on our Platform are for
informative purposes only and neither the Platform nor the Company guarantees
or bears liability for the authenticity of the advertisements.
·
At no point will the Company permit its competitors to advertise
on the Platform
·
You may visit the links in the advertisements at your own risk or
choose to not accept the cookies permitting third parties to display their
advertisements.
5. Data Security Practice and Procedure
The security of your data is important to us, but remember
that, no method of transmission over the Internet or method of electronic
storage is 100% secure. While we strive to use commercially acceptable means to
protect your Personal Data, we cannot guarantee its absolute security.
5.1 Security of Data
We maintain strong security
safeguards to ensure the security and confidentiality of the User’s data,
protect against any anticipated threats to the security of your Personal
Information, protect against unauthorized access to your information, and ensure
the proper disposal of your Personal Information. We have adopted a
comprehensive security policy that complies with laws and regulations and
reflects industry standards. We have in place appropriate safeguards and
security measures to protect the personal data you provide on this Platform
against accidental or any other unlawful forms of processing. We use third
party Service Providers for the purposes of payment collections and information
shared by you in relation to payments, shall be governed by privacy policy
adopted by such Service Providers.
Our security policy requires us
to consistently monitor the risk of any threats to the administrative,
technical, and physical safeguards we have put in place to protect your
information. The safeguards include, at a minimum, firewalls and data
encryption and restricting access to your Personal Information only to those
employees who have a need to know such information to carry on our operations.
These safeguards are reviewed and adjusted periodically based on ongoing risk
assessments.
5.2 Grievance Officer
In accordance with Information
Technology Act 2000 and the Information Technology (Reasonable Security
Practices and Procedures and Sensitive Personal Data or Information) Rules,
2011 made there under, the name and contact details of the Grievance Officer
are provided below:
The Grievance Officer
Mr. Rahul Singh
Teachmint Technologies Private
Limited,
Address: #1685, 4th Floor, 27th
Main Rd, Sector 2, HSR Layout, Bengaluru, Karnataka 560102
Email: [email protected]
5.3 Transfer of Data
The information, including
Personal Data, we obtain from or about you may be maintained, processed and
stored by us on the systems situated in the territory of Republic of India.
However, subject to applicable
laws, your information, including Personal Data, may be transferred to – and
maintained on – computers located in the countries other than India where the
data protection laws may differ from those of the Data Protection Rules
applicable in India.
If you are located outside India
and choose to provide information to us, please note that we transfer the data,
including Personal Data, to India and process it there.
Your consent to this Privacy
Policy followed by your submission of such information represents your
agreement to that transfer.
The Company will take all the
steps reasonably necessary to ensure that your data is treated securely and in
accordance with this Privacy Policy and no transfer of your Personal Data will
take place to an organisation or a country unless there are adequate controls
in place including the security of your data and other Personal Information.
We comply with generally accepted
industry standard regulations regarding the collection, use, and retention of
data under the Information Technology Act, 2000 and Data Protection Rules. By
using the Platform and/or Services, you consent to the collection, transfer,
use, storage and disclosure of your information as described in this Privacy
Policy, including to the transfer of your information outside of your country
of residence.
6. Children’s Privacy
These Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from children under 18 years of age. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do the necessary actions.
7. Links to Other Sites
Our Platform may contain links to third party websites and
mobile applications that are not operated by us. If you click such link, you
may be directed to such third party’s websites and mobile applications. We
strongly advise you to review the Privacy Policy of every site you visit.
We also use APIs, tools and other services of third party
for offering our services to the Users.
We have no control over and assume no responsibility for the
content, privacy policies or practices of any third party websites and mobile
applications or any services offered by such third parties. You agree that we
shall not be liable for any breach of your privacy of Personal Information or
loss incurred by your use of such websites or services.
We may host surveys for survey creators for our Platform who
are the owners and users of your survey responses. We do not own or sell your
responses. Anything you expressly disclose in your responses will be disclosed
to survey creators. Please contact the survey creator directly to better
understand how they might share your survey responses.
8. Changes to this Privacy Policy
This Privacy Policy will remain in effect except with
respect to any changes in its provisions in the future. We may update our
Privacy Policy from time to time. We will notify you of any changes by posting
the new Privacy Policy on this page, which will be in effect immediately after
being posted on this page.
We reserve the right to update or change our Privacy Policy
at any time and you are advised to review this Privacy Policy periodically for
any changes. Your continued use of the Platform and our Service after we post
any modifications to the Privacy Policy on this page will constitute your
acknowledgment of the modifications and your consent to abide and be bound by
the modified Privacy Policy.
We may let you know via email and/or a prominent notice on
our Platform, prior to the material change becoming effective and update
“effective date” at the top of this Privacy Policy.
9. Copyright, Trademark, and other Intellectual Property Protection
All wordmarks and logos of Sibsagar Commerce College are intellectual
property of the Company, all materials on the Platform are protected by copyright
laws, trademark laws, and other intellectual property laws. Any unauthorized
use of any such information or materials may violate copyright laws, trademarks
laws, intellectual property laws, and other laws and regulations.
10. Contact Us
If you have any questions about this Privacy Policy, please
contact us by email: [email protected]
