1.1. Purpose
Privacy Policy - Myaspirations.biz
This online training website is dedicated to all the human beings of this beautiful world. The aspirations could be in any aspect of personal or professional life like understanding of self, personality development, soft skills, education in terms of language / technical, entertainment, health, wealth, relationships, jobs, economy, politics, science and technology, innovation, environment, animal kingdom, beyond earth and the like...with only condition being use it only for positive and progressive purposes. We wish each user of this platform to achieve sustainable success and happiness in life by enabling better clarity, focus and action also engaging others in your progress. The overall principle is TOGETHER WE WIN. This is the reason why we have also included the feature of TRAINERS / ENABLERS so that your personal and professional aspirations can be stated in a structured manner with deeper clarity, understanding, focus, confidence and commitment to realize in reality. Lets commence the journey of achieving our aspirations in a structured manner.
1. Background
1.1 This document is an electronic record in terms of (i) Information Technology Act, 2000; (ii) the rules framed there under as applicable; and (iii) the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
1.2 This Privacy Policy (“Privacy Policy”) is published in accordance with: (i) Section 43A of the Information Technology Act, 2000; (ii) Regulation 4 of the Information Technology (Reasonable security practices and procedures and sensitive personal information) Rules, 2011 (“SPI Rules”); and (iii) Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011, that require publishing the privacy policy that is applicable in relation to the access or usage of Myaspirations.biz (“Website”).
1.3 This Privacy Policy covers: (i) the type of information collected from the users of the Website including sensitive personal data or information; (ii) the purpose, means and modes of usage of such information; and (iii) how and to whom such information which has been collected will be disclosed.
1.4 For the purpose of this Privacy Policy, wherever the context so requires "You", “Your” or “User” shall mean any natural or legal person who uses the Website for availing the Services, which includes the parent or adult who is paying for the service, as well as the student who is using the service. The terms “We”, “Us”, “Our” shall mean Ladder Consultancy Services Pvt. Ltd. (“LCS”).
1.5 We reserve the right to make changes to this Privacy Policy at any time. We will provide notice of any significant changes through the Website, or by other means so that you may review the changes before you continue to use the Website. Any such modifications will become effective immediately upon posting to the Website and your continued use of the Website, and/or the Services constitutes your agreement to such modifications. If you object to any changes, you may close your account. You agree to periodically review the current version of the Privacy Policy as posted on the Website.
2. Type of Information collected from users of the Website
2.1 For the purpose of this Privacy Policy, “personal information” as defined under Section 2(i) of the SPI Rules means, any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
2.2 “Sensitive personal information” as defined under Section 3 of the SPI Rules means such personal information which consists of information relating to:
(i) password;
(ii) financial information such as Bank account or credit card or debit card or other payment instrument details ;
(iii) physical, physiological and mental health condition;
(iv) sexual orientation;
(v) medical records and history;
(vi) Biometric information;
(vii) any detail relating to the above clauses as provided to body corporate for
providing service; and
(viii) any of the information received under above clauses by body corporate for
processing, stored or processed under lawful contract or otherwise.
2.3 We require Users who register to use the services offered on our Website to give the following type of information:
(i) Name of Parent, for individual / student less than 18 years of age;
(ii) Name of Student;
(iii) E-mail Address;
(iv) Address;
(v) Date of birth and Age of Student;
(vi) Class/grade in which the Student is currently studying;
(vii) Preferred time for the training session(s);
(viii) The subject(s) for which they require the training session(s); and
(ix) Credit card information which is required for payment of services which they are availing of, through the Website.
2.4 After You create an account on the Website, you may choose to provide additional information on Your personal profile on the Website, such as descriptions of your skills, professional experience, and educational background. You can list honors, awards, professional affiliations, networking objectives, companies or individuals that you follow, and other information including content. Providing additional information enables You to derive more benefit from the Website by helping you express your professional identity; find other professionals, opportunities, and information; and help recruiters and business opportunities find you. It also enables us to serve you ads and other relevant content on and off the Website.
3. How the collected information will be used
3.1 Sensitive Personal Information and other Personal Information collected under Clause 2.3 will be used in the manner described below:
(i) Name: The user name is used to personalize all communications that are sent to the user by us. In the context of training sessions offered by LCS, the user name is used to customize the training session for each individual user. Similarly, wherever relevant, the parents name is used to personalize any correspondence that LCS might have with them.
(ii) E-mail Address and Residential Address: Your email address will serve as the login ID, to access the various services provided on the Website, including but not limited to the training sessions offered by LCS. The E-mail address and/ or the residential address will also be used to communicate new features/ programs/ services that we may provide, the training schedules, information relating to payment for the services to be availed by you, communication of expiry of your subscription period and date of renewal of subscription and progress reports on the training sessions.
(iii) Phone Number: The phone number will be an alternative method to contact the user/student and/or the parent or any other adult who has registered on behalf of the student, should there be any cancellation/interruption of a training session, or for any other matter related to the services to be availed by you.
(iv) Credit Card information: Credit card information is used for charging the user/the parent/any other adult registering on behalf of the student for availing of the training sessions, and also for subsequent renewals of the training sessions.
(v) Other Personal Information: The website also serves all the features of a regular social media in terms of FORUM, Sharing the individual’s dreams and wishes with their select individuals / groups or with general public. They may also wish to take help from service providers in the areas of their dreams and wishes wherein, their personal contact details and basic details of their wish will be shared by us with the potential provider of products / services.
3.2 The personal information You provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name may reveal your gender). By providing personal information to us when You create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of the Terms of Use of the Website and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part. You have the right to withdraw or modify your consent to LCS’ collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the Terms of Use, by changing your account settings on your profile, or by closing your account.
3.3 In order to improve the quality of our services we may ask you to provide us with information regarding your experiences with our services, and more detailed contact preferences. Users have the option of choosing not to provide us with this information.
3.4 Personal information including personal sensitive information as described in Clause 2.1 will not be sold to any third parties. Except as explicitly stated at the time of requesting such information, we do not disclose such information that you may have provided to us, at the time of registration and upon request subsequently. Details of information that may be disclosed to third parties is discussed in Clause 4 below.
4. Disclosure of Personal Information
4.1 All financial information that is collect through the Website is used solely to bill for the services availed of by the user, and is not used for marketing or promotional purposes. Towards this end, we disclose such information to a third-party intermediary, for the sole purpose of for credit card processing, which is used to make payments to avail of the services on our Website.
4.2 We may also disclose certain information to third parties solely to help diagnose technical problems, to administer the Website, and improve the quality of the Services provided by us. Information that you share through the Website may be used by other Users to help you obtain information and support that advances probability of your dreams and wishes to be realized or.
4.3 We reserve the right to disclose any personal information as required by law and when we believe, at our sole discretion that disclosure is necessary to protect our rights, protect someone from injury and/or to comply with a judicial proceeding, court order, or legal process served on our Website.
5. Cookies
5.1 As further described in Paragraph 5.2 below, the Website uses cookies and similar technologies like pixels and tags to ensure that we give you the best possible experience on our website. A cookie is a small file placed onto your device. Cookies enable us to identify your device, and enable the functioning of many features on our Website, including your ability to log into your account. If you don’t want to receive cookies, you can change your browser settings. If you use the Website without changing your browser settings, we'll assume that you’re happy to receive all cookies on the Website. Please note that the Website will not work properly without cookies.
Trusted partners and analytics companies like Google Analytics may also place cookies on your machine. Please read their privacy policies to ensure that you’re comfortable with the manner in which they use cookies.
• Google Analytics
5.2 The Website uses two types of cookies, persistent and session. A persistent cookie is set once you’ve logged in to your account on the Website. The next time you visit the Website using the same device, the persistent cookie will enable us to recognize you as an existing user, so you may not need to log in before using our services.
A session cookie is used to identify a particular visit to the Website. Session cookies expire after a short time, or when you close your web browser. Other technology, such as Adobe Flash, can be used to place the functional equivalent of a cookie on your computer. These cookies are intended to be automatically cleared or deleted when the User quits the browser application. You are encouraged to use the “clear cookies” functionality of you browser to ensure such clearing / deletion, since it is impossible for us to guarantee, predict or provide for the behaviour of your computer
5.3 The information collected through these cookies is used by us for the technical administration of the Website, and for research and development purposes. We may use third party cookies to track visitor behavior and to improve the quality of our Services. However, such cookies will not store any kind of personal information, nor will such information be disclosed to any third party.
5.4 Specifically, the Website uses cookies for a number of purposes, including:
(a) Authentication: The Website uses cookies to recognize you if you are logged in to the Website, so that we can show you the right information and personalize your experience.
(b) Security: The Website uses cookies to support or enable security features we have deployed, and to help us detect malicious activity and violations of our Terms of Use.
(c) Preferences, features and services: The Website uses cookies to know which language you prefer, what your communications preferences are, and they help you fill out forms on the Website. In addition, they provide you with features, insights, and customized content through our plugins.
(d) Advertising: The Website may use cookies to show you relevant advertising both on and off the Website. We may also use a cookie to learn whether members who saw an ad on the Website later visited the advertiser’s site. Similarly, our partners may use a cookie to determine whether we’ve shown an ad and how it performed, or provide us with information about how you interact with them. We may also work with a partner to show you an ad on or off the Website, such as after you’ve visited a partner’s site or application. Cookies and ad technology such as web beacons, pixels, and anonymous ad network tags help the Website more effectively serve ads to you, as well as to collect aggregated auditing, research, and reporting for advertisers. Note: Because your web browser may request advertisements and web beacons directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their site.
(e) Performance, Analytics and Research: The Website uses cookies to help us learn how well our site and plugins perform across the globe. We also use cookies to understand, improve, and research products, features, and services, including when you access the Website from other websites, applications, or devices such as your work computer or your mobile device.
Most browsers allow you to control cookies through their settings preferences. Limiting the ability of websites to set cookies, however, may worsen your overall user experience.
5.5 The information we collect with cookies is not sold, rented, or shared with any third parties. Provided however that LCS does generate periodical reports on HR analytics using the Google Analytics tool. Such analytics reports may even be sold by LCS. However, in all such situations, LCS ensures that it does not part with any individual User’s personal information unless it has obtained the prior written approval from such User.
6. Third Party Links
We may provide links to websites for the convenience and information of users. These websites may not be owned, controlled, or operated by us. In those cases, we cannot control how information collected by those websites will be used, shared, or secured. If the user visits linked sites, we strongly recommend that the user reviews the privacy notices or policies posted at those sites. We are not responsible for the content of linked sites, the user’s use of them, or the information practices of their operators.
7. Security Procedures
We have implemented industry standard security policies, rules and technical measures as required under Section 8 of the SPI rules, to protect any kind of personal sensitive information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.
Access to your data on the Website is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and the Services offered through the Website. To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to LCS through the Website. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Members are not encrypted, and we strongly advise you not to communicate any confidential information through these means. Please help keep your account safe by using a strong password.
Section 8 of the SPI Rules reads as follows:
(1) The appropriate Government may cause an audit to be conducted of the affairs of the service providers and authorised agents in the State at such intervals as deemed necessary by nominating such audit agencies.
(2) The audit may cover aspects such as the security, confidentiality and the privacy of information, the functionality and performance of any software application used in the electronic service delivery and the accuracy of accounts kept by the service providers and authorised agents.
(3) The service providers and the authorised agents shall provide such information and assistance to the audit agencies nominated by the appropriate authority, to comply with the directions given by the audit agencies and to rectify the defects and deficiencies pointed out by the audit agencies within the time limit specified by the audit agency.
(4) All service providers and the authorised agents shall submit a due declaration for protecting the data of every individual transaction and citizen and any unauthorised disclosure to anyone without the written consent of either the individual or the appropriate Government shall be debarred from providing such a service any further and the provisions of section 45 of the Act shall be applicable in such cases.
The provisions stated above is to ensure compliance with Rule 8 of the SPI Rules.
8. Retention of Information
We retain any personal information that you may have provided to us, for as long as you are registered subscribers of our Services. LCS may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Privacy Policy and the Terms of Use. LCS may retain information for as long as is necessary to provide support-related reporting and trend analysis only, OR if requested by law enforcement agencies who have the jurisdiction to make such requests to LCS but we generally delete or de-personalize closed account data consistent with Paragraph 9 below, except in the case of our plugin impression data, which we will try to de-personalize at the time of collection, but in any event, we will de-personalize within 7 days.
9. Rights to Access, Correct, or Delete Your Information, and Closing Your Account
You have a right to (1) access, modify, correct, or delete your personal information controlled by LCS regarding your profile, (2) change or remove your content, and (3) close your account. You can also contact us for any account information which is not on your profile or readily accessible to you. If you close your account(s), your information will generally be removed from the Website within 24 hours. We generally delete closed account information and will de-personalize any logs or other backup information within 30 days of account closure, except as noted in Paragraph 8 above.
10. Obligations of Users towards other Users
As a User, you have certain obligations to other Users. Some of these obligations are imposed by applicable law and regulations and others have become commonplace in communities of like-minded Users, such as the Website:
You must, at all times, abide by the terms and conditions of the current Privacy Policy, User Agreement, and other policies of LCS. This includes respecting all intellectual property rights that may belong to third parties, such as trademarks or copyrights.
You must not upload or otherwise disseminate any information that may infringe on the rights of others or which may be deemed to be injurious, violent, offensive, racist, or xenophobic, or which may otherwise violate applicable law OR the purpose and spirit of the Website and its community of Users.
You must keep your username and password confidential and not share it with others. Any violation of these guidelines or those detailed in our Terms of Use or elsewhere may lead to the restriction, suspension, or termination of your account at the sole discretion of LCS.
11. Grievances
If you have any grievances as to the usage of any of your personal information or any other privacy concerns, you can contact the Grievance Officer whose details are provided in the Terms of Use, who will redress any such grievance that you might have within a period of 30 (Thirty) days.
12. Governing Law and Jurisdiction
This Privacy Policy shall be governed by and constructed in accordance with the applicable laws of India without reference to conflict of laws principles. Courts in Bangalore, India shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, this Privacy Policy.
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