“Personal information” is defined to mean 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 EMERITUS INDIA, is capable of identifying such person.

Examples of personal information are your name, address, NRIC/FIN/Passport number, photograph or video image, telephone numbers and email addresses.

“Sensitive personal information” is defined to mean such personal information which consists of information relating to passwords, financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health conditions, sexual orientation, medical records and history, biometric information, any detail relating to the above as provided to a body corporate for providing service; and any information received which falls under the abovementioned categories by a body corporate for processing, stored or processed under lawful contract or otherwise. Any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force is not regarded as sensitive personal information.

We collect personal information, sensitive personal information (personal information and sensitive personal information is hereinafter collectively referred to as “Personal Data”), and other data from the Site. We may also collect information about you when you respond to advertisements through social media such as Facebook Leads Ads.

The personal information we collect from you may include:

(i) your name;
(ii) your photo identification card (eg. Aadhaar card, Passport, Voter ID or Driving License);
(iii) your contact particulars including telephone number, fax, address and email id;
(iv) your educational qualification, your educational achievement and your year of graduation;
(v) your professional experience, the companies you have worked at and the specific start and end dates of your working in these companies and your job roles and designations at these companies;
(vi) your nationality; and
(vii) your date of birth.

The sensitive personal information we collect from you may include:

(i) passwords;
(ii) financial information such as your bank account or credit card or debit card or other payment instrument details;
(iii) medical records and history;
(iv) any detail relating to the above; and
(v) any information received which falls under the abovementioned categories.

Information we collect apart from your personal data may include the following:

Cookies and Usage Data

We may also collect information how the services on the Site (the “Services”) are accessed and used and technical, navigational and other related non-personal information (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), operating system, geo-location, browser type, operating systems and software, types of devices used, browser version, the pages of our Site that you visit, URLs visited prior to the use of the Site or URLs visited after use or access to the Site, the time and date of your visit, the time spent on those pages, usage patterns, unique device identifiers and other diagnostic data. Please refer to our cookie policy for more details.

How we use your Personal Data

We collect, use and disclose your Personal Data for the following purposes in connection with the products or services which you have applied for, to the extent applicable:

(a) General administration of your application and/or registration and/or enquiry, including those Personal Data collected by our marketing service providers, for any program offered by us or our university partners;

(b) Improvement of our offerings, both individually (e.g., by program staff when working with a participant) and in aggregate, and to individualize the experience and to evaluate the access and use of the Site;

(c) Scientific research;

(d) The purpose for which you specifically provided the information, for example, to respond to a specific inquiry or provide you with access to the specific program content and/or services you select or any other reason stated by you or by the teleoperator for which we received or made a call;

(e) tracking of both individual and aggregate attendance, progress and completion of a program, and analysis of statistics on participant performance and the manner in which participants learn;

(f) Monitoring and detection of violations as well as other misuses and potential misuses of the Site;

(g) Sending you/ providing you on a call, updates about programs offered by ERUDITUS-INDIA or other events or promotional materials, sending you communications about products or services of ERUDITUS-INDIA , ERUDITUS-INDIA affiliates, or selected business partners that may be of interest to you, or sending you email messages about Site maintenance or updates;

(h) Authentication of your identity when needed;

(i) Process of refunds, as applicable;

(j) Conducting checks under the National Customer Preference Register (“NCPR”) maintained by Telecom Regulatory Authority of India (TRAI) or its appointed agency or the telephone service provider as the case may be;

(k) Compliance with internal policies and procedures and any applicable laws, rules, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation);

(l) To conduct the regular business of Eruditus and pursue all legitimate business interests in marketing our programs, services and products, including:

• Conduct of direct marketing; we may process your Personal Data to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law;
• We may use your email address or other contact information to identify groups of individuals with similar interests or characteristics on social media, which we would target for advertisement. Your data would not be used for any other purpose by the social media. This would be based on our legitimate interest to increase the audience of persons likely to be interested in our services. You have a right to object to this use of your information that can be exercised by informing us through email at privacy@eruditus.com
• We may be targeting advertising on social media through services offered by third-party Service Providers, such as Facebook Custom Audiences or other similar business tools to groups of individuals identified by such social media as having similar interests or characteristics than our existing contacts. This processing activity is based on our legitimate interest to increase the audience of person likely to be interested in our services. In such case, we will be acting as joint controller with the social media (which contact details can be found on the social media’s platform). Such targeted audience will be provided with the possibility to object to the display of targeted advertising by the social media. We will not have any personal data on this audience, except to the extent it decides to click on the advertisement and/or access our website;
• Facilitating data analysis and business planning purposes, marketing, advertising, and sales efforts.

(m) Creating a database of members and other participants or users of ERUDITUS-INDIA or the Site, or database of the persons attending events and functions of ERUDITUS-INDIA;

(n) The purposes described elsewhere in this Policy (for example in the section entitled “Use and Disclosure to Third Parties”); and

(o) Any other purpose as disclosed to you at the point of collection or pursuant to your consent. By providing us your Personal Data and any third party’s personal data such as the Personal Data of your parents regardless of the manner in which you have provided such data, you represent and warrant to us that consent, including that of the third party, has been obtained for collection, use and disclosure of the Personal Data for the abovementioned purposes.

ERUDITUS-INDIA ensures that the Personal Data held by us shall be kept confidential. When transferring Personal Data to our third-party service providers, agents and/or our affiliates or related corporations whether in India or elsewhere in order to carry out one or more of the purposes listed above, we will require them to ensure that Personal Data disclosed to them is kept confidential and secure.

We employ other companies and individuals to perform functions on our behalf. They will need access to the Personal Data needed to perform their functions for EMERITUS INDIA but may not use it for purposes other than for collection and handling of data for the purposes set out herein above. Subject to the exclusion stated under the heading “exclusion” below, we will share Personal Data we collect with the following third parties or purposes:

(i) With service providers, or contractors that perform certain functions on our Site, including managing our learning management system, hosting our videos and program kit, processing information that you provide to us on the Site, processing purchases via third party providers, and other transactions through the Site, operating the Site or portions of it, providing or administering programs, or in connection with other aspects of EMERITUS INDIA services;

(ii) With the service providers or contractors that assist with our telemarketing activities including software providers of tele-calling, CRM, learning management system and marketing service providers such as Google, Facebook, LinkedIn and other marketing Affiliates;

(iii) With other visitors to the Site, program platform or our mobile learning app, to the extent that you submit comments, program work, or other information or content (collectively, “Postings”) to a portion of the Site, program platform or mobile learning app designed for public communications; and with other members of an EMERITUS INDIA class of which you are a member, to the extent you submit Postings to a portion of the Site, program platform or mobile learning app designed for viewing by those class members. We may provide your Postings to participants who later enrol in the same classes as you, within the context of the forums, the program kit, or otherwise. If we do re-post your Postings originally made to non-public portions of the Site, program platform or mobile learning application or learning management system we will post them without your real name and e-mail (except with your express permission), but we may use your username without your consent;

(iv) For scientific research, for example, in the areas of cognitive science and education. However, we will only share Personal Data about you for this purpose to the extent doing so complies with applicable law and is limited to the Personal Data required to fulfill the purposes stated at the time of collection;

(v) To provide opportunities for you to communicate with other users of the Site who may have similar interests or educational goals. For instance, we may recommend specific study groups or connect potential participant and coaches. In such cases, we may use all information collected about you to determine who might be interested in communicating with you;

(vi) To third parties whose practices are not covered by this Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers);

(vii) We may also share Personal Data about you with the University collaborating on a program for which you are enrolled, and this University may use your Personal Data in accordance with their own privacy policies;

(viii) We may, however, disclose your private information when required by law to do so pursuant to judicial or other government orders, warrants, instructions, to respond to court orders, or other legal process; to investigate, or prevent, or take action regarding illegal activities, suspected fraud, or security or technical issues, or to enforce our terms and conditions, or this Policy; as otherwise may be required by applicable law; or to protect our rights, property, or safety or those of others. However, we are not responsible for the manner in which such government agencies use such information, including any disclosures/publication of such information by such Government agencies;

(ix) With affiliates of EMERITUS INDIA or with successors in the event of a merger, acquisition or reorganization, for their use consistent with this Policy;

(x) As otherwise described to you at the point of collection of Personal Data or pursuant to your consent; and for integration with third party services including third parties who provide administrative, telecommunication, computer, financial intermediary, payment or other services to EMERITUS INDIA. In addition, we may share aggregated information that does not personally identify you with the public and with third parties, including but not limited to researchers and business partners. Please keep in mind that whenever you voluntarily disclose personal data online – for example on message boards, through e-mails, or in chat areas – that information can be collected and used by others. By posting personal data online that is publicly accessible, you may receive unsolicited messages from other parties in return;

(xi) Any lawyer or other professionals for the preparation of any document or professional advice in respect of any matter relating to the Policy or the TOS;

(xii) Any other person to whom EMERITUS INDIA believes it is necessary to share the information with, provided that such person is under a duty of confidentiality to EMERITUS INDIA with an obligation to keep such information confidential; and

(xiii) Any person to whom EMERITUS INDIA is under a legal obligation to make a disclosure under and for the purposes of compliance with guidelines / regulations issued by regulatory or other authorities which EMERITUS INDIA is bound to comply with.

Exclusion:

EMERITUS INDIA will endeavor to ensure that in respect of sensitive personal information, it shall not publish, and that the person / entity receiving any personal information from EMERITUS INDIA as above, does not publish and/or disclose such information onwards to any third party.

The Site contains links to websites published by third parties, including other content providers as well as certain service providers, such as those who process payments on behalf of EMERITUS INDIA. These other websites are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by such websites, unless we have otherwise indicated in this Policy. They may place independent cookies on your computer or independently contact you, for which the EMERITUS INDIA shall not be held responsible or liable in any manner whatsoever. We encourage you to be aware when you are being redirected to a third-party website and review the privacy policies and terms of use of each website you visit and use.

The uploading, dealing, handling and/ or using of any personal information for any lawful purpose by the Site, including for the purposes and in the manner outlined above shall not constitute ‘publication’ in any manner.

In the event you do not wish to receive calls or messages from EMERITUS INDIA , we request you to either choose to unsubscribe on any emails we have sent you or write to privacy@eruditus.org.

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain Personal Data in a non-human readable format to provide protection.

EMERITUS INDIA will not be responsible for the accuracy or authenticity of the Personal Data that is provided by you. It is the responsibility your responsibility to notify EMERITUS INDIA of any changes to your Personal Data or if you would like your data to be deleted. To this end, you may request EMERITUS INDIA for reasonable access to, and correction of, or deletion of your Personal Data by emailing your request/clarification at privacy@eruditus.com. We take every reasonable step to ensure that Personal Data that we process is accurate and, where necessary, kept up to date, and any of your User Information that we process that you inform us is inaccurate (having regard to the purposes for which they are processed) is erased or rectified.

EMERITUS INDIA may however before processing such requests, ask the user to identify themselves. EMERITUS INDIA shall not be responsible for any delay in updating such information.

We will retain Personal Data only for as long as is necessary for the purposes set out in this Policy. In addition, we will retain and use Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain certain data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. You have full rights to stop processing and/or request removal of your data by emailing us at privacy@eruditus.com (by stating “Retention of Data” as the subject matter of the enquiry in the subject matter line.)

Your Newsletter and Email Subscriptions.

You can opt-out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. For some Services, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

Cookies and Pixel Tags

You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Site. We have also provided another measure of disabling the cookies, you will see a pop up on the Site that can enable you to control the cookies tracking.

Our website uses Facebook Pixel service. This tool allows us to follow your activities on the Site after you are redirected to the Site by clicking on a Facebook advertisement. This will enable us to understand the efficacy of Facebook advertisements for analytical purposes, and in the process improve our advertising campaigns for a better users’ experience. We may use the analysis to retarget you with further advertising on Facebook and the use of Custom Audiences. Facebook website provides information about Custom Audiences and how to opt-out from being targeted.

Please note that we review and may make changes to this Policy from time to time. When changes are made, the Policy link will include a notation “Revised (date).” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in this Policy link for at least seven (7) days after the update has been made. By accessing the Site after any changes have been made, you signify your agreement on a prospective basis to the modified Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.