We, at Grow Inn Steps (hereinafter “Platform”, “Us”, “Our” or “We”), value the trust that users (hereinafter “You”, “Your”) place upon Us and are fully committed to protect any Personal Information and Sensitive Personal Information, which We secure from You. We are an online educational marketplace providing a very wide range of educational and skill development courses for learners and students from all walks of life. The Personal Information and Sensitive Personal Information You choose to provide on the Platform helps us render Our services. Your privacy is critically important to Us and hence, We strive to maintain the best in the industry, robust and holistic data security practices and are committed to adhering to all Applicable Laws concerning data protection of users, at all times.
This Privacy Policy will provide all essential information pertaining to what Personal Information and Sensitive Personal Information We collect from You, how We treat the information that is collected, how the dissemination or sharing of the said information will be done, and how We will address any grievances, which You may have. We request You to read this Privacy Policy carefully to understand Our approach pertaining to the collection and treatment of Your information. In the event You do not agree with Our policies and practices, You can choose not to use Our Platform. By clicking on the “I Agree” button, You accept and agree to all the terms and practices described in this Privacy Policy.
Application:
This Privacy Policy applies to Our Platform, services and all functionalities hosted on the Platform, unless specified otherwise.
Definitions:
- “Account” shall refer to the user-generated account that is hosted on the Platform and can be created subject to the submission of Personal Information and Sensitive Personal Information by the user.
- “Act” shall refer to the Information Technology Act, 2000, as amended from time to time.
- Applicable Laws/ Law” shall mean any applicable statute, law, regulation, ordinance, rule, judgment, notification, rule of law, order, decree, bye-law, permits, licenses, clearance, approval, directive, guideline, consents, authorizations, policy, requirements, or other governmental restriction or any similar form of decision, or determination by, or any interpretation, or policy, having the force of law, whether in effect, as of the date of this Privacy Policy or thereafter, as amended from time to time;
- “Personal information” shall 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 a body corporate, is capable of identifying such person, such as name, email and physical addresses, phone numbers etc.
- “Non-Personal Information” shall include Your geographic location, details of Your telecom service provider or internet service provider, the type of browser (Internet Explorer, Firefox, Opera, Google Chrome etc.), Your operating system, device and the website You last visited before visiting the Platform, the duration of Your stay on the Platform along with the date, time of Your access etc.
- “Sensitive Personal Information” of a person means such personal information which relates to: (i) password(s); (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 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; provided that, 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 shall not be regarded as Sensitive Personal Data or Information;
- “Platform” shall mean the Grow In Steps website owned and hosted by RLN Education LLP and available at www.growinnsteps.com and/or the Grow In Steps mobile app.
Controller of Personal Information and Sensitive Personal Information
Any Personal Information or Sensitive Personal Information provided to or gathered by Us under this Privacy Policy will be stored and controlled by Amazon Web Services, at Region Name: India(Mumbai) Availability zone: ap-south-1a.
Objective for Collection of Information
Personal Information and/or Sensitive Personal Information is collected from users when the Platform is being accessed/ installed by You for the use of Our services, at the time of the creation of Your Account or onboarding at Our Platform or if at any time You make changes to Your profile, Account etc. The objectives for the collection of Personal Information and Sensitive Personal Information are the following:
- to enhance Your experience of use of the Platform or other services provided by Us;
- to respond to Your inquiries or fulfil Your requests for information about the various services offered by Us on the Platform;
- to provide You with information about services available on the Platform and to send You information, materials, and offers from Us;
- to update You with important information regarding the Platform, changes in terms and conditions, user agreements, and policies and/or other administrative information;
- to send You surveys and marketing communications that We believe may be of interest to You;
- to personalize Your experience on the Platform by presenting services and offers tailored to Your preferences;
- to analyze how Our services are used;
- to facilitate payments;
- to respond to legal, judicial, quasi-judicial process/requests and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by Applicable Law;
- to determine any security breaches, computer contaminant or computer virus and to investigate, prevent, or take action regarding illegal activities and suspected fraud;
- to resolve disputes, if any.
Information Accessibility
Please note that You may visit the Platform and access any information or data or part of the Platform which We authorise access to, without having to provide any Personal Information or Sensitive Personal Information. However, when You set up an Account on Our Platform, We collect and store Your Personal Information or Sensitive Personal Information which is provided by You from time to time. Our reason for the collection of such information is to enable You to have a hassle-free, efficient, safe and easy user experience. We may use Your Personal Information or Sensitive Personal Information to assist trainers in devising curriculum, scheduling classes or activities; processing payments; communicating with You regarding Our courses, activities, training, promotional offers, or recommendations that might be of interest to You or for other purposes mentioned in this Privacy Policy. The kinds of information We gather from You are listed below-
- Personal Information: We collect information through which an individual is identified, such as the name, contact details, email address or any other relevant material provided by a User when they register for an Account on the Platform; including but not limited to information gathered through a purchase of a Service, survey, e-mail updates. This includes information regarding the socio-economic profile of a student such as ascertaining which category the student falls into (General/OBC/SC/ST etc.). This also includes information pertaining to the racial or ethnic origin, political opinions, religion or other beliefs, health etc. of a User, either as provided by the User through the Platform or as otherwise provided. We may also collect Sensitive Personal Information such as physical, physiological and mental health condition of the Users, sexual orientation, medical records and history credit card/debit card / other payment instrument details; information provided by You to fulfil the Know Your Customer (“KYC”) requirements, etc. You may also add other information to Your Account, such as a profile name and profile picture.
- Integrated Service information: We collect any information obtained through access to any other social media platform (Facebook, Google, etc.) integrated with the Platform. The Company may collect this information already provided in your integrated service account.
- Information through use of our Platform: We may collect Non-Personal Information about Your Account includes information which is procured through the use of our Platform, including but not limited to the time spent responding to each question, behavioral patterns in answering questions, the amount of educational material viewed by you, and the number of questions attempted by You when You use our Services or interact with others using our Services.
- Information from your parents/guardian: We collect any information which is provided in a case where a child is less than 18 (eighteen) years of age and the data provided by their parent and/or guardian.
- Non-personal Information: We may collect any information which is gathered when a User visits the Platform, the interested course material of the User, and the pages which were visited and the pages which were “clicked” by the User.
- Transactional Information: If You undertake a transaction on Our Platform, We may receive information and confirmations, such as payment receipts, billing address, data from third party payment aggregators or gateways processing Your payment.
- Device and Connection Information: We collect device-specific Non-Personal Information such as e-mail address, Internet Protocol (IP), password, browser data, computer version, operating system, purchase history, the full Uniform Resource Locators (URL) clickstream to, through and from Our Platform (including date and time); cookie number; courses You viewed or searched for. We collect device location information if You use Our location features.
- Messages: If You use the chat facility available on the Platform, We will collect the communication exchanged between You and other users of the Platform, which may pertain to Your messages, documents, photos, videos, files etc. or any queries raised on the Platform. You should be aware that the Personal Information and any Sensitive Personal Information that you voluntarily disclose on the chat facility and that is accessible to other users, could be collected and disclosed by others. We cannot take any responsibility for such collection and disclosure.
- Cookies: We use cookies to operate and provide Our services, and improve Your experiences, understand how Our services are being used, and customize Our services. We may use cookies to know Your choices, such as Your language preferences, and customize Our services for You. You may refuse to accept browser cookies by activating the appropriate setting on Your browser.
Children Under the Age of 18
We have a policy of not collecting Personal Information and Sensitive Personal Information from Children under 18 without consent from parent or the legal guardian. Parents or legal guardians who believe that We may have collected Personal Information and/or Sensitive Personal Information from their child/ward under the age of 18, can submit a request to approve or remove their child/ward’s information with Us.
Sharing of Personal Information
Your Personal Information or Sensitive Personal Information is an important part of Our business and We share the same with other entities only as described below –
- Affiliated Services- We may share Your Personal Information or Sensitive Personal Information with Our affiliate service providers such as teachers, instructors, trainers etc. who perform functions for You on the Platform or in connection with processing credit card payments; providing transactional services (pertaining to the services available on Our Platform); or analysing Your data. These entities will only have access to Your Personal Information or Sensitive Personal Information that is needed to perform their functions, and they may not use the said information for any other purpose. Further, these entities will be required to process Your Personal Information or Sensitive Personal Information in accordance with this Privacy Policy and as permitted by the Applicable Law.
- Promotional offers/marketing/advertisement- We may share Your Personal Information with Our affiliates for the purposes of marketing outreach and advertisements. We display targeted advertisements based on Personal Information. Advertisers (including ad serving companies) may assume that people who interact with, view, or click on targeted ads meet the targeting criteria – for example, women ages 18-24 from a particular geographic area. We do not provide any Personal Information to the advertiser when You interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will make the assumption that You meet the targeting criteria used to display the ad. Our advertisers include financial service providers and non-financial companies. However, We will not disclose Your Sensitive Personal Information for marketing purposes without obtaining prior explicit consent from You via email or an alert in your Account. If you do not want to receive any such marketing/promotional communication, please adjust the preferences in Your Account.
- Business purpose- We may share Your Personal Information or Sensitive Personal Information with another business entity should We (or Our assets) plan to raise capital or seek investment, merge with, or be acquired by that business entity, or in case of re-organization, amalgamation, restructuring of Our business. Should such a transaction be undertaken, such business entity (or the new merged/restructured entity) will be required to follow this Policy with respect to Your Personal Information and Sensitive Personal Information.
- Legal compliance- We may share Your Personal Information or Sensitive Personal Information to comply with the Applicable Law, enforce Our Policies and Agreements or when directed by any court, tribunal, regulator or any government authority or legal process. We may also share Your Personal Information or Sensitive Personal Information with other entities and government authorities for detecting, mitigating, investigate fraudulent activities related to Our Platform.
- With your consent- Other than as set out above, You will receive prior written intimation/notice via email or alert in Your Account when information about You might be disclosed or transferred to third parties and You will have an opportunity to choose not to share/transfer such information.
- By using or continuing to use the Platform, You agree to Our use of Your Personal Information and Sensitive Personal Information in accordance with this Privacy Policy, as may be amended from time to time by Us in Our discretion. You also agree and consent to Us collecting, storing, processing, transferring and disclosing Your Personal Information and Sensitive Personal Information with third parties or affiliate service providers for the purposes set out in this Privacy Policy.
Managing Your Account and retention of Your Personal Information or Sensitive Personal Information
You may delete Your Account at any time or revoke Your consent to Our use of the information provided to Us, using Our Platform delete account feature.
We may retain some of Your Personal Information or Sensitive Personal Information after the deletion of Your Account or such data, only for legitimate business or legal purposes such as security, fraud prevention or financial record-keeping or as otherwise mandated under Applicable Laws. When You delete Your Account or such data, We follow a deletion process to make sure that Your data is safely and completely removed from Our servers or retained only in anonymized form.
Options available to You at any time while using the Platform
You will always have access to Your Account information and Your purchase transactions in Our Platform for the limited purpose of viewing and, in certain cases, updating that information. This list will change as Our Platform evolves. In addition, You may at any time while using the Platform:
- choose not to provide any information sought to be collected.
- request to review and correct, amend or update Your Personal Information or Sensitive Personal Information. When You update such information, We usually keep a copy of the previous version for Our records.
- You can, at any time while using the Platform withdraw Your consent given earlier to Our Platform to use Your Personal Information or Sensitive Personal Information. However, such withdrawal of consent must be provided to Us in writing at [email protected].
If you do not wish to receive any e-mails or advertisement/promotional offers, please adjust Your Account preferences.
Data Security
We have employed robust, reasonable and up to date physical and electronic procedural, technical and administrative security measures to protect Your Personal Information and Sensitive Personal Information from loss, theft, unauthorised and unlawful interception and dissemination.
We request You to undertake caution if You are providing Your Personal Information or Sensitive Personal Information over any publicly accessible part of the Platform. We urge You not to share Your Account details and password with anyone. It is Your responsibility to ensure Your Account details remain confidential and no unauthorised person gets access to these.
Conditions of Use
If You choose to avail Our services, such services and any dispute over privacy is subject to this Privacy Policy and Our terms of use, including limitation on damages, resolution of disputes and application of the laws of India.
Limitation on Damages
We shall be liable to pay damages only for such offences as are envisaged under the Act. Your right to claim damages on account of any non-compliances by Us with respect to the provisions of the Act shall be limited to the right to claim only statutory damages prescribed under the Act.
Disputes
Any disputes arising on account of or out of this Privacy Policy shall be governed by the laws of India and the courts at New Delhi shall have rightful jurisdiction to adjudicate upon all disputes arising out of this Privacy Policy.
Changes in Privacy Policy
Please note that this Privacy Policy is subject to changes which are necessitated from time to time on account of change in Applicable Laws, the evolution of technological standards, changes in safety and security standards etc. We request You to periodically check this Privacy Policy to be aware of any changes which may periodically be made to this Privacy Policy if any.
Contact Us
If You have questions or any grievances about Our Privacy Policy, please contact our Grievance Officer Mr. Sanjay Kumar at [email protected], 185, Pocket-3, Sector-24, Rohini, New Delhi