Privacy Policy
PRIVACY POLICY
This privacy policy (Privacy Policy) will help you understand what information we collect at Lurnpro, why we collect it, how Lurnpro uses it, including if and how we share the information with third parties, and the choices you have.
When we talk about “Lurnpro”, “we”, “our”, or “us” in this Privacy Policy, we are referring to the Company. When we talk about “you” in this Privacy Policy, we are referring to the User. The purpose of this Privacy Policy is to inform you about the type of personal information which is collected, the manner in and the purpose for which such information is used and/or shared, and the various options and choices in this regard available to you.
You are advised to carefully read this Privacy Policy before using or availing any of our services and/or products. This Privacy Policy may be modified by the Company from time to time in its sole discretion, and any modifications shall be made effective and binding upon you through posting by the Company on the Application and the Website.
By use of our Application and/or Website, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. However, in the event you are under 18 years of age, you may use the Website and/or the Application only under the supervision of a parent or legal guardian who agrees to be bound by this Privacy Policy (please see our Terms of Use in this regard). Capitalized terms in this Privacy Policy would have their meaning as set out under the Terms of Use. This Privacy Policy is incorporated into and is subject to the Terms of Use.
A. INFORMATION WE COLLECT AND RECEIVE
1. Your Data
Your data may contain 'sensitive personal data or information' or 'personal information' as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (Data Protection Rules). The Company will collect, store, use, process, and transfer such information as prescribed under the Data Protection Rules. Where the Company collects or processes your data, it does so on your behalf. The data collected by the Company may include the following types of data, but is not restricted to: name, gender, age or date of birth, bank account details, home address, email address, phone-numbers and other contact information.
2. Other Information
● Account creation information: Users provide information such as an email address and password to create an account.
● Billing and other information: For sales and purchases enabled by the Website, our corporate affiliates and/or our third-party payment processors may collect and store billing address and credit card information on our behalf, or we may do this ourselves.
● Application and/or Website usage information: This is information about how you are accessing and using our Application and/or Website, which will include administrative and support communications with us and information about the purchases made through the Application and/or Website.
● Contact information: With your permission, any contact information you share is collected (such as an address book from a device) when using the Application and/or Website. We may also collect your phone number and email address to contact you. You may also receive SMSs, emails, phone calls, etc., in connection with the Application and/or Website.
● Log data: When you use the Website, our servers automatically record information, including information that your browser or mobile device sends whenever you visit or use a website. This log data may include your Internet protocol address, the address of the web page you visited before using the Website, your browser type and settings, the date and time of your use of the Website, information about your browser configuration and plug-ins, language preferences, and cookie data.
● Device information: We may collect information about the device you are using the Application and/or Website on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings.
● Geo-location information: Precise GPS location from devices is required for effective use of the Application and/or Website and will as such be collected with your permission. Such information will include geo-location data of your loading and unloading locations. Wi-Fi and IP addresses received from your browser or device may be used to determine approximate location.
● Third party data: The Company may also receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which pin codes, or it might be more specific information, such as about how well an online marketing or email campaign performed.
3. Retention
The information above would be collected and retained by Lurnpro which is registered under the following entity: Prominds Learning Pvt Ltd.
We will not retain any sensitive personal data or information for longer than is required for the purpose for which such data or information was collected or may lawfully be used or is otherwise required under any other law for the time being in force. We may retain anonymized data for as long as is required.
4. Our Cookie Policy
We use cookies and similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies. Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit the Website. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.
Some cookies are associated with your account and personal information in order to remember that you are logged in and which accounts you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things.
B. PURPOSE OF COLLECTION
The Company may process information including sensitive personal data or information concerning you both internally and externally (so far as reasonably necessary) for the purposes mentioned below (Purposes).
You have the option to refrain from disclosing your sensitive personal data or information to the Company. You will also have the option of withdrawing consent previously provided to the Company. However, exercising this option will hamper the Company's ability to provide you with any or all of the features of its Application and its Website.
1. Your data
The Company will access and use your data as reasonably necessary and in accordance with your instructions to (a) provide, maintain and improve the Application / Website; (b) to prevent or address service, security, technical issues, or at your request in connection with support matters; (c) as required by law, and (d) as expressly permitted in writing by you.
2. Other information
We use other information in connection with the Application / Website. Specifically:
● To understand and improve our services: We carry out research and analyze trends to better understand how Users are using the Application / Website and improve them.
● To communicate with you by:
o Responding to your requests: If you contact us with a problem or question, we will use your information to respond.
o Sending emails and notifications: By accepting the terms of this Privacy Policy you give us the permission to send you Application/Website notifications and administrative emails and messages including text messages. You hereby consent to receiving text messages from us, however you have the option to opt out later. We may also contact you to inform you about changes in the Application/Website, its offerings, and important Application/Website related notices, such as security and fraud notices. These emails and notifications are considered part of the Application/Website and you may not opt-out of them. In addition, we sometimes send emails about new product features or other news about the Company. You can opt out of these at any time.
● Billing and account management: We use account data to administer accounts and keep track of billing and payments.
● Communicating with you and marketing: We often need to contact you for invoicing, account management and similar reasons. We may also use your contact information (with us) for our own marketing or advertising purposes. You can opt out of these at any time.
● Investigating and preventing bad things from happening: We work hard to keep the Application/Website secure and to prevent abuse and fraud.
● Analysing and ensuring that great things do happen: We work hard to make our products intelligent; and any information from you, that we can use to make the Application/Website serve you better, we want to and will.
This Privacy Policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable User of the Application and/or the Website.
C. YOUR CHOICES
1. Your Data
You provide us with instructions on what to do with your data. You have many choices and control over your data. For example, you may enable or disable third party integrations, manage permissions, change retention and export settings and transfer or assign your data.
2. Access to Sensitive Personal Data or Information
You will have the right, upon reasonable request, to access and review the information provided by you and held by the Company. Upon discovering that the information provided is inaccurate or deficient in any manner, you will have the right to request suitable changes or amendments to such information, which may be provided by the Company, when feasible.
3. Right to Restrict Our Use of your Data
You have the right to request that we restrict our processing of your data in certain circumstances, for example if you dispute the accuracy of the data that we hold about you or you object to our processing of your data (including where we process your data for our legitimate interests, where permitted under applicable law).
4. Right to Withdraw Consent
Where we have obtained your consent to process your data for certain activities, you may withdraw this consent at any time and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose. Please note that exercising this option of withdrawing consent will hamper the Company's ability to provide you with any or all of the features of its Application and its Website.
5. Other Choices
In addition, the browser you use may provide you with the ability to control cookies or other types of local data storage. Your device may provide you with choices around how and whether location or other data is collected and shared. The Company does not control these choices, or default settings, which are offered by makers of your browser or the device’s operating system.
D. SHARING AND DISCLOSURE
The Company will not publish or disclose your personal information pertaining to you without your prior consent, unless it is required to do so in order to facilitate use of the Application and/or Website, or if mandated by law, or if you have previously provided your consent. The Company may disclose personal information with its employees, officers, agents, consultants, contractors, attorneys, etc., on a need to know basis for the Purposes.
The Company will disclose any sensitive personal data and information if there is a legal requirement or if it is ordered to do so by a court of competent jurisdiction or to any government agency if required by law for the purposes of verification of identity, or for prevention, detection, or investigation of crime (including cyber incidents), or for prosecution or punishment of offences.
E. TRANSFER
The Company may transfer personal information pertaining to you to third parties for the Purposes. You are expressly notified that the transfer may also be to foreign jurisdictions where your personal information may be processed by third-party service providers and vendors, or our group companies, in relation to the Purposes. ©©
F. SECURITY
The Company ensures the confidentiality and security of the personal information and sensitive personal data and information provided by you by implementing comprehensive information security practices and standards as mandated by the Data Protection Rules. We use sufficient technical and organisational measures to safeguard your data and we store your data on secure servers. [1] [KJ2] If you suspect any misuse or loss or unauthorised access to your data, please let us know immediately by contacting us by e-mail.
G. GRIEVANCE OFFICER
If you have any concerns or questions in relation to this Privacy Policy, you may address them to our grievance officer whose name and email address are as follows:
Name: Prominds Learning Pvt Ltd
Email: support@learning.com
You would have to suggest given the nature of our business. Am ok to go with whatever bare minimum is required for us to comply with given we are just starting and do not have a team to ensure compliance.
[KJ2]There is no requirement to specially mention the standard being used. However, as mention any entity in India collecting personal data is required to implement a comprehensive information security standard under applicable law. The IS/ISO/IEC 27001 security standard is one of the acceptable standards.