INTRODUCTION
Welcome to Shodhgrants’s “Privacy
Policy”.
Shodhgrants
respects your privacy and is committed to protecting your personal data. This
Privacy Notice will inform you as to how we look after your personal data when
you visit our website (regardless of where you visit it from) and tell you
about your privacy rights and how the law protects you.
This Privacy
Notice applies to all/any user accessing or availing the services on the
Platform. Please also use the Glossary to understand the meaning of some of the
terms used in this privacy notice.
- WHO WE ARE
a. THE PURPOSE
OF THIS PRIVACY NOTICE
This Privacy Notice aims to give you information
on how Shodhgrants collects and processes your personal data through your use
of the Shodhgrants website and connected services (the website and connected
services are collectively referred to as “Platform” in this Privacy Notice).
The Platform is not intended for children and
we do not knowingly collect data relating to children.
It is important that you read this Privacy
Notice together with any other privacy notice or fair processing notice we may
provide on specific occasions when we are collecting or processing personal
data about you so that you are fully aware of how and why we are using your
data. This Privacy Notice supplements the other notices and is not intended to
override them.
b. CONTROLLERS
The Mintbotics Group is made up of different
legal entities. This Privacy Notice is issued on behalf of the Mintbotics
Edutech Private Limited Group so when we mention “Shodhgrants”, “Mintdemy”,
“Mintbotics”, “we”, “us” or “our” in this Privacy Notice, we are
referring to the relevant division in the Mintbotics Edutech Private Limited
responsible for processing your data. Mintbotics Edutech Private Limited is the
controller and responsible for this website.
We have appointed a data privacy manager who
is responsible for overseeing questions in relation to this Privacy Notice. If
you have any questions about this Privacy Notice, please contact the date
privacy manager using the details set out below.
Contact Details:
Mintbotics Edutech Private Limited
Name of Data Privacy Manager: Dr. Sushama Vaishnav
Email address: shodhgrants@gmail.com
Address: Mintbotics Edutech Private Limited, 18, Vishwakarma Society, N8,
Sector E, CIDCO, Aurangabad 431003, Maharashtra, India
Phone: +91 8830364711
CHANGES TO THE
PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version of the Privacy Notice was last
updated on 27th October 2021 and previous versions can be obtained by
contacting us.
It is important that the personal data we hold
about you is accurate and current. Please keep us informed if your personal
data changes during your relationship with us.
c. THIRD-PARTY
LINKS
The Platform may include links to third-party
websites, plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their
privacy statements. When you leave our Platform, we encourage you to read the
privacy notice of every website you visit.
- THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means
any information about an individual from which that person can be identified.
It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer
different kinds of personal data about you which we have grouped together as
follows:
- Identity
Data includes first name, maiden name, last name, username or
similar identifier, date of birth, the language you use, and gender.
- Contact
Data includes your email address.
- Financial
Data includes your payment card details.
- Transaction
Data includes details about payments to and from you and other
details of services you may have purchased from us.
- Technical
Data includes your geo location, your login data, browser type and
version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices you use
to access the Platform.
- Profile
Data includes your username and password, purchases or orders made
by you, your interests, preferences, feedback and survey responses.
- Usage Data includes
information about how you use the Platform.
- Marketing
and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication
preferences.
We also collect, use and share Aggregated
Data such as statistical or demographic data for any purpose. Aggregated
Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly reveal your
identity. For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific website feature. However, if we
combine or connect Aggregated Data with your personal data so that it can
directly or indirectly identify you, we treat the combined data as personal
data which will be used in accordance with this Privacy Notice.
We do not collect any Special Categories
of Personal Data about you (this includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your health and
genetic and biometric data), nor do we collect any information about criminal
convictions and offences.
IF YOU FAIL TO
PROVIDE PERSONAL DATA
Where we need to collect personal data by law,
or under the terms of a contract we have with you and you fail to provide that
data when requested, we may not be able to offer the services that we aim to.
In this case, we may have to cancel the service you have with us but we will
notify you if this is the case at the time.
- HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from
and about you including through:
. DIRECT
INTERACTIONS
You may give us your identity and contact
information by using our Platform. This includes personal data you provide when
you:
· create an account on the Platform;
· subscribe to our publications,
newsletters;
· request marketing material to be sent
to you;
· enter a competition, promotion or
survey; or
· give us some feedback.
a. AUTOMATED
TECHNOLOGIES OR INTERACTIONS
As you interact with our Platform, we may
automatically collect technical data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies, server logs and other
similar technologies. The session timeout duration on Shodhgrants is 14 days.
b. THIRD PARTIES
OR PUBLICLY AVAILABLE SOURCES
We may receive personal data about you from
various third parties and public sources as set out below:
- Technical
Data from the following parties:
- analytics providers such as Google;
- advertising networks such as Facebook, Taboola, Outbrain,
CTN, Google, Adgebra and
- search information providers such as Google, Yahoo and
Bing.
- Contact,
Financial and Transaction Data from providers of technical, payment and
delivery services such as Stripe, Razorpay, PayU, Citrus, Billdesk.
- Identity
and Contact Data from publicly availably sources such as Facebook and
Google.
- HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the
law allows us to. Most commonly, we will use your personal data in the
following circumstances:
- Where we
need to perform the services we offer.
- Where it is
necessary for our legitimate interests (or those of a third party) and
your interests and fundamental rights do not override those interests.
- Where we
need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal
basis for processing your personal data other than in relation to sending third
party direct marketing communications to you via email or text message. You
have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE
WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a
description of all the ways we plan to use your personal data, and which of the
legal bases we rely on to do so. We have also identified what our legitimate
interests are wherever appropriate.
Note that we may process your personal data
for more than one lawful ground depending on the specific purpose for which we
are using your data. Please contact us if you need details about the specific
legal ground we are relying on to process your personal data where more than
one ground has been set out in the table below.
PURPOSE / ACTIVITY |
TYPE OF DATA |
LAWFUL BASIS FOR PROCESSING
INCLUDING BASIS OF LEGITIMATE INTEREST |
To register you as a new user |
c.
Identity d.
Contact |
·
Performance
of a contract with you |
To process and deliver your order
including: f.
Manage
payments, fees and charges g.
Collect
and recover money owed to us |
h.
Identity i.
Contact j.
Financial k.
Transaction l.
Marketing
and Communications |
m.
Performance
of a contract with you n.
Necessary
for our legitimate interests (to recover debts due to us) |
To manage our relationship with you
which will include: o.
Notifying
you about changes to our terms or Privacy Notice p.
Asking
you to leave a review or take a survey |
q.
Identity r.
Contact s.
Profile t.
Marketing
and Communications |
u.
Performance
of a contract with you v.
Necessary
to comply with a legal obligation w.
Necessary
for our legitimate interests (to keep our records updated and to study how
customers use our products/services) |
To enable you to partake in a prize
draw, competition or complete a survey |
x.
Identity y.
Contact z.
Profile aa.
Usage bb.
Marketing
and Communications |
cc.
Performance
of a contract with you dd.
Necessary
for our legitimate interests (to study how customers use our
products/services, to develop them and grow our business) |
To administer and protect our
business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data) |
ee.
Identity ff.
Contact gg.
Technical |
hh.
Necessary
for our legitimate interests (for running our business, provision of
administration and IT services, network security, to prevent fraud and in the
context of a business reorganisation or group restructuring exercise) ii.
Necessary
to comply with a legal obligation |
To deliver relevant website content
and advertisements to you and measure or understand the effectiveness of the
advertising we serve to you |
jj.
Identity kk.
Contact ll.
Profile mm. Usage nn.
Marketing
and Communications oo.
Technical |
·
Necessary
for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform our
marketing strategy) |
To use data analytics to improve our
website, products/services, marketing, customer relationships and experiences |
qq.
Technical rr.
Usage |
·
Necessary
for our legitimate interests (to define types of customers for our products
and services, to keep our website updated and relevant, to develop our
business and to inform our marketing strategy) |
USE OF THIRD-PARTY
ANALYTICS
We may use third-party web analytics services
on our Services, such as those of Google Analytics. These service providers use
the sort of technology previously described in the “Cookies and other
electronic technologies” section to help us analyze how users use the Services,
including by noting the third-party website from which you arrive, and provide
certain features to you. The information (including your IP address) collected
by the technology will be disclosed to or collected directly by these service providers,
who use the information to evaluate your use of the Services. This information
may be used to place interest-based advertisements on the Platform. This may
result in you seeing Shodhgrants’s advertisement when you visit other websites.
To prevent Google Analytics from using your information for analytics, you may
install the Google Analytics Opt-out Browser Add-on by clicking here.
COOKIES AND OTHER
ELECTRONIC TECHNOLOGIES
When you interact with the Services, we try to
make that experience simple and meaningful. When you visit our Platform, our
web server sends a cookie to your computer or mobile device. Cookies are small
pieces of information that are issued to your computer or mobile device when
you visit a website or access or use a mobile application, and that stores and
sometimes tracks information about your use of the platform. A number of
cookies we use last only for the duration of your web or application session
and expire when you close your browser or exit the application. Other cookies
are used to remember you when you return to the Platform and will last longer.
Some of the cookies used by the Platform are
set by us, and some are set by third parties who are delivering services on our
behalf.
We may use cookies, and similar technologies
to cookies, to collect information about your access and use of the Platform.
For example, we may use cookies or other technologies that: (1) allow you to
navigate and use all the features provided by our Platform; (2) customize
elements of the layout and/or content within the Platform and remember that you
have visited us before; (3) identify the number of unique visitors we receive;
(4) allow us to provide you with a customized experience; and (5) inform us how
you use the Platform (including how long you spend on the Platform) and where
you have come to the Platform from, so that we can improve the Platform and
learn which functions of the Platform are most popular with users. As we adopt
additional technologies, we may also gather additional information through
other methods.
Most web and mobile device browsers
automatically accept cookies but, if you prefer, you can change your browser to
prevent that or to notify you each time a cookie is set. You can also learn
more about cookies by visiting www.allaboutcookies.org,
which includes additional useful information on cookies and how to block
cookies using different types of browsers or mobile devices.
You may also consult the “Help”
section of your browser for more information (e.g., Internet
Explorer, Google Chrome, Mozilla Firefox,
or Apple Safari). You can
also manage the use of Flash technologies, including cookies and local storage
objects with the Flash management tools available at Adobe’s
website. Please note that by blocking any or all cookies, you may
not have access to certain features or offerings of the Services.
If you are accessing our Services through a
mobile device, you can also update your privacy settings on your device by
setting the “Limit Ad Tracking” and Diagnostics and Usage setting property
located in the settings screen of your Apple iPhone or iPad, or by resetting
your Android ID through apps that are available in the Play Store. You can also
limit information collection by uninstalling the App on your device and you can
use the standard uninstall process available as part of your device for this
purpose.
ADVERTISING POLICIES
We may use third-party advertising
technologies that allow for the delivery of relevant content and advertising on
our Platform, as well as on other websites you visit. The ads may be based on
various factors such as the content of the page you are visiting, information
you enter such as your age and gender, your searches, demographic data,
user-generated content, and other information we collect from you. These ads
may be based on your current activity or your activity over time and across
other websites and online services and may be tailored to your interests.
Also, third parties whose products or services
are accessible or advertised on our Platform may place cookies or other
tracking technologies on your computer, mobile phone, or other device to
collect information about your use of the website as discussed above. We also
allow other third parties (e.g., ad networks and ad servers such as Google
Analytics, AdWords and others) to serve tailored ads to you on our website,
other sites, and in other applications, and to access their own cookies or
other tracking technologies on your computer, mobile phone, or other device you
use to access the website. We may provide our customer information (such as a
hashed version of your email addresses) to service providers, who may “match”
this information in de-identified form to cookies (or mobile ad identifiers)
and other proprietary IDs, in order to target or “retarget” you with ads when
you visit other websites and mobile applications. (You may opt out of these
many of these service providers as described in the next paragraph.)
We neither have access to, nor does this
Privacy Policy govern the use of cookies or other tracking technologies that may
be placed on your computer, mobile phone, or other device you use to access our
website by non-affiliated, third-party ad technology, ad servers, ad networks
or any other non-affiliated third parties. Those parties that use these
technologies may offer you a way to opt out of ad targeting as described below.
If you receive tailored advertising on your
computer through a web browser, you can learn more about such tailored browser
advertising and how you can generally control cookies from being put on your computer
to deliver tailored advertising, by visiting the European Interactive Digital
Advertising Alliance Consumer Ad Choices
link for EU based advertising or for US based advertising either:
(i) the Network Advertising Initiative’s Consumer Opt-Out link or (ii)
the Digital Advertising Alliance’s Consumer Opt-Out link to
opt-out of receiving tailored advertising from companies that participate in
those programs. To opt out of Google Analytics for display advertising or
customize Google display network ads, you can visit the Google Ads Settings page.
Please note that to the extent advertising
technology is integrated into our website or other websites that you visit, you
may still receive advertisements even if you opt-out. In that case, the
advertising will not be tailored to your interests. Also, we do not control any
of the above opt-out links or whether any particular company chooses to
participate in these opt-out programs. We are not responsible for any choices
you make using these mechanisms or the continued availability or accuracy of
these mechanisms.
USERS IN EUROPE
- Access.
You have the right to request a copy of the information we are processing
about you.
- Rectification.
You have the right to have incomplete or inaccurate information that we
process about you rectified.
- Deletion.
You have the right to request that we delete information that we process
about you, except we are not obliged to do so if we need to retain such
data in order to comply with a legal obligation or to establish, exercise
or defend legal claims.
- Restriction.
You have the right to restrict our processing of your information where
you believe such data to be inaccurate; our processing is unlawful; or
that we no longer need to process such data for a particular purpose
unless we are not able to delete the data due to a legal or other
obligation or because you do not wish for us to delete it.
- Portability.
You have the right to obtain information we hold about you in a
structured, electronic format, and to transmit such data to another data
controller, where this is (a) information that you have provided to us,
and (b) if we are processing that data solely on the basis of your
consent or to perform a contract with you.
- Objection.
Where the legal basis for processing your information is our legitimate
interest, you have the right to object to such processing on grounds
relating to your particular situation. We will abide by your request
unless we have compelling legitimate grounds for the processing which
override your interests, or if we need to continue to process the data
for the establishment, exercise or defense of a legal claim.
- Withdrawing
consent. If you have consented to our processing of your information, you
have the right to withdraw your consent at any time, free of charge. This
includes where you wish to opt out from marketing messages.
You can make a request to exercise any of
these rights in relation to your information by sending the request to us
at shodhgrants@gmail.com or mailing address set forth under
“Contact Us” in the end of this page. For your own privacy and security,
at our discretion, we may require you to provide your identity before providing
the requested information. Please note that Shodhgrants may take up to 30 days
to fulfill such requests.
You also have the right to lodge a complaint
with the local data protection authority if you believe that we have not
complied with applicable data protection laws. A list of local data protection
authorities in European countries is available here.
CHANGES TO SHODHGRANTS’S
PRIVACY POLICY
The Services and our business may change from
time to time. As a result, at times it may be necessary for Shodhgrants to make
changes to this Privacy Policy. Shodhgrants reserves the right to update or
modify this Privacy Policy at any time and from time to time. If you disagree
with our revisions to the Privacy Policy, you may de-activate your account or
discontinue the use of our Services. Please review this policy periodically,
and especially before you provide us with any information through the Services.
This Privacy Policy was last updated on the date indicated on top of this page.
Your continued use of the Services after any changes or revisions to this
Privacy Policy shall indicate your agreement with the terms of such revised
Privacy Policy.
If you are in Europe, you will not be required
to agree to changes to this Privacy Policy, unless we specifically seek your
consent.
CHANGE OF PURPOSE
We will only use your personal data for the
purposes for which we collected it, unless we reasonably consider that we need
to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an
unrelated purpose, we will notify you and we will explain the legal basis which
allows us to do so.
Please note that we may process your personal
data without your knowledge or consent, in compliance with the above rules,
where this is required or permitted by law.
- DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with
the parties set out below for the purposes set out in the table in paragraph 4
above.
- Internal
Third Parties as set out in the Glossary.
- External
Third Parties as set out in the Glossary.
- Third
parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business, then
the new owners may use your personal data in the same way as set out in
this privacy notice.
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.
- INTERNATIONAL TRANSFERS
As your personal data is shared with us, it
will involve transferring your data to Singapore.
Many of our external third parties are based
in India and United States so their processing of your personal data may
involve a transfer of data outside the country in which you are based.
Please contact us if you want further information
on the specific mechanism used by us when transferring your personal data out
of the country in which you are based.
- DATA SECURITY
We have put in place appropriate security
measures to prevent your personal data from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other
third parties who have a business need to know. They will only process your
personal data on our instructions and they are subject to a duty of
confidentiality.
We have put in place procedures to deal with
any suspected personal data breach and will notify you and any applicable
regulatory of a breach where we are legally required to do so.
- DATA RETENTION
. HOW LONG WILL
YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as
long as necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period
for personal data, we consider the amount, nature, and sensitivity of the
personal data, the potential risk of harm from unauthorised use or disclosure
of your personal data, the purposes for which we process your personal data and
whether we can achieve those purposes through other means, and the applicable
legal requirements.
In some circumstances we may anonymise your
personal data (so that it can no longer be associated with you) for research or
statistical purposes in which case we may use this information indefinitely
without further notice to you.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights
under data protection laws in relation to your personal data. Please click on
the links below to find out more about these rights:
If you wish to exercise any of the rights
above, please contact us.
NO FEE USUALLY
REQUIRED
You will not have to pay a fee to access your
personal data (or to exercise any of the other rights). However, we may charge
a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM
YOU
We may need to request specific information
from you to help us confirm your identity and ensure your right to access your
personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further information
in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests
within one month. Occasionally it may take us longer than a month if your
request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
- GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of
our business in conducting and managing our business to enable us to give you
the best service/product and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive and
negative) and your rights before we process your personal data for our
legitimate interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your consent or
are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us.
Performance of Contract means processing
your data where it is necessary for the performance of a contract to which you
are a party or to take steps at your request before entering into such a
contract.
Comply with a legal or regulatory obligation means
processing your personal data where it is necessary for compliance with a legal
or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties: Other companies
in the Mintbotics Edutech Private Limited Group [acting as joint controllers or
processors] and who are based in India and provide IT and system administration
services and undertake leadership reporting.
External Third Parties: Contact, Payments
and Transaction data service providers.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data
(commonly known as a “data subject access request”). This enables you to
receive a copy of the personal data we hold about you and to check that we are
lawfully processing it.
Request correction of the personal data
that we hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of
the new data you provide to us.
Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no
good reason for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully exercised
your right to object to processing (see below), where we may have processed
your information unlawfully or where we are required to erase your personal
data to comply with local law. Note, however, that we may not always be able to
comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
Object to processing of your personal
data where we are relying on a legitimate interest (or those of a third party)
and there is something about your particular situation which makes you want to
object to processing on this ground as you feel it impacts on your fundamental
rights and freedom. You also have the right to object where we are processing
your personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedom.
Request restriction of processing of your
personal data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios: (a) if you want us to establish the
data’s accuracy; (b) where our use of the data is unlawful but you do not want
us to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims; or (d)
you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
Request the transfer of your personal
data to you or to a third party. We will provide to you, or a third party you
have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated
information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
Withdraw consent at any time where we are
relying on consent to process your personal data. However, this will not affect
the lawfulness of any processing carried out before you withdraw your consent.
If you withdraw your consent, we may not be able to provide certain products or
services to you. We will advise you if this is the case at the time you
withdraw your consent.