PRIVACY POLICY
Virohan Private Limited (hereinafter referred to as "we", "our", "us" and "Virohan" and shall include any affiliates) understands the privileged position we are in while providing the services through our website, platforms and App(referred to as "App") and are committed to protecting the information and data shared by all of our users (hereinafter referred to as "you", "yourself" and "User").
In light of the same, we have created this privacy policy ("Privacy Policy") which is in compliance with the Information Technology Act, 2000 ("IT Act"), Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the "SPI Rules"). The privacy mechanism outlined in this Privacy Policy, as amended from time to time, identifies personally identifiable or personal information that may be collected, how such information is used, collected, stored, processed, disclosed, transferred and the choices you have regarding our use of this information.
Please read this Privacy Policy carefully as by providing your consent to it, you agree to the collection, storage, processing, disclosure, use and transfer of your personal information as set out in this Privacy Policy. Any information provided to us or collected by us is subject to this Privacy Policy. If you do not agree to any or all of these terms, please write to us on info@virohan.org. Should you continue to access and use the App and provide your personal information, such act would constitute your consent to the terms contained herein.
This Privacy Policy shall be read in conjunction with the Terms of Use as applicable to the App.
Your Consent
A prerequisite for usage of the App and the services provided on the App is the acceptance of this Privacy Policy. This Privacy Policy shall apply to all individuals and entities that use the App. After providing your consent to the Privacy Policy, you may:
If you are registered on the App, we may need to send routine communications to you, such as administrative messages through email and notifications posted on the App or through other means available, including text and other forms of messaging. Though we prefer to communicate with the users via email and SMS, as may be deemed necessary, you agree to receive our phone calls or any other mode of communication as may be deemed appropriate by us.
When you register on the App you also consent to allowing us to periodically send emails, SMS communications, WhatsApp messages or messages through any other means of communication available to Virohan based on the details provided by you and the nature of services opted for by you, now or in the future, for relaying information which you may find useful, interesting or in line with your interests. If you do not wish to receive promotional information from us, you can, at any time, choose to opt out of receiving such promotional communications by following the process mentioned in the promotional communication or by contacting us on info@virohan.org or clicking on the 'unsubscribe' button.
You must ensure to provide us with the correct or up-to-date information at the time of registration on the App. This will allow us to contact you for further correspondences with respect to the services provided on the App or otherwise. We are not responsible for any inaccurate information you provide to us, which may affect your experience when using the App and the services.
If, at any time, you want to access, update, modify or eliminate any information provided by you, you may do so by writing to us on info@virohan.org. You may also withdraw your consent for use of your personal information provided and stop using the services for which consent is required. Virohan reserves the right to stop providing any services to which consent has been withdrawn.
You may also write to us at info@virohan.org with a request for accessing, updating, modifying or deleting any information shared by you.
Personal Information and What Types Of Personal Information Do We Collect About You
"Personal information": means any information that relates to an individual, which directly or indirectly, in combination with other information available or likely to be available with us, is capable of identifying such individual or such other information that is considered as Personal Information under applicable laws.
"Sensitive Personal Information": means any Personal Information of an individual, which consists of information relating to financial information such as bank account, credit card, debit card or other payment instrument details; passwords; biometric information; sexual orientation; physical, physiological and mental health condition; and medical records and history or such other information that is considered as Sensitive Personal Information under applicable laws. Information freely available or accessible in public domain is not treated as Sensitive Personal Information.
Depending on who you are (e.g., a merchant, customer, cardholder, consumer, supplier or business partner) and how you interact with us (e.g., telephone, IVR, API, online or offline), we may collect, use, receive, store, analyse, combine, transfer or otherwise process different categories of your Personal Information (including Sensitive Personal Information).
Below is a table of the categories of Personal Information and Sensitive Personal Information which we may collect about you
| Category of Personal Information | Which includes information such as: |
|---|---|
| Identity and Account Log-In Information | Full name(s), title, age, user ID, gender and your date of birth. |
| Contact Information | Telephone/mobile number(s), permanent and current address(es), state/city of residence, country, pin code, email address(es), and chosen billing address(es), details of parents/guardian. |
| Financial Information | Personal bank account numbers and bank account data which may include e-nach, NEFT, IMPS and UPI ID details, credit or debit card information, including the credit or debit card number, card type, expiry date on the credit or debit card, card token. - Financial information is collected on a need basis and subject to provisions of applicable laws |
| Identification Information or other Sensitive Personal Information | Know Your Customer (KYC) documents including all proofs of identity and address, photograph, Permanent Account Number (PAN), GST Number, etc. Other identifiers such as cookie id, device id etc. or any other identifier from a third party. |
| Payment Information or Transactional Information | Payment gateway ID, name of issuing bank, mode of payment, the date, currency and amount of the payment was transaction(s), whether the transaction was successful, and other information provided by you directly or indirectly to us or provided to us by banks, payment gateway or other service providers or business partners. |
| Usage and Technical Information | IP addresses, application, device or browser type, versions and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, unique identifiers associated with your device(s) and pages that you access on the App and the dates and times that you visit the App and paths taken. During the use of the App via the internet, we may automatically receive technical information about your computer/device, including your IP address, your computer operating system, time-zone, browser type and browser plug-in details due to the communication protocol settings on the Internet. We may also collect information regarding the pages you viewed, the web addresses from which you arrive or click through to, time spent on certain pages, download errors and page response times. All these information help us analyze user's trends and preferences, and thus assist us in improving our services. |
| Credit related Information | Credit or affluence information or assessment provided by third parties such as financial institutions or account aggregators or similar third parties as permitted under applicable laws of India including our business partners, independent service providers and our business partners. |
| Marketing and Communications Information | Communications with customer service support, behavioural data (for example, data collected using cookies), information about promotions, surveys, promotional campaigns and records of your decision(s) to subscribe to or to withdraw from receiving marketing materials, if any. |
| Information in your device(s) | We may also access your location data in your devices to enable you to access our services after seeking necessary permissions as permitted under applicable laws. We may also collect, use, process and/or share non-Personal Information and/or anonymized and/or aggregated data such as statistical or demographic data in accordance with this Privacy Policy. |
Categories of Personal Information
Identity and Account Log-In Information
Full name(s), title, age, user ID, gender and your date of birth.
Contact Information
Telephone/mobile number(s), permanent and current address(es), state/city of residence, country, pin code, email address(es), and chosen billing address(es), details of parents/guardian.
Financial Information
Personal bank account numbers and bank account data which may include e-nach, NEFT, IMPS and UPI ID details, credit or debit card information, including the credit or debit card number, card type, expiry date on the credit or debit card, card token.
Identification Information or other Sensitive Personal Information
Know Your Customer (KYC) documents including all proofs of identity and address, photograph, Permanent Account Number (PAN), GST Number, etc. Other identifiers such as cookie id, device id etc. or any other identifier from a third party.
Payment Information or Transactional Information
Payment gateway ID, name of issuing bank, mode of payment, the date, currency and amount of the payment was transaction(s), whether the transaction was successful, and other information provided by you directly or indirectly to us or provided to us by banks, payment gateway or other service providers or business partners.
Usage and Technical Information
IP addresses, application, device or browser type, versions and configurations, operating systems, device brand and model, time zone setting, geo-location information, content, unique identifiers associated with your device(s) and pages that you access on the App and the dates and times that you visit the App and paths taken.
During the use of the App via the internet, we may automatically receive technical information about your computer/device, including your IP address, your computer operating system, time-zone, browser type and browser plug-in details due to the communication protocol settings on the Internet.
We may also collect information regarding the pages you viewed, the web addresses from which you arrive or click through to, time spent on certain pages, download errors and page response times. All these information help us analyze user's trends and preferences, and thus assist us in improving our services.
Credit related Information
Credit or affluence information or assessment provided by third parties such as financial institutions or account aggregators or similar third parties as permitted under applicable laws of India including our business partners, independent service providers and our business partners.
Marketing and Communications Information
Communications with customer service support, behavioural data (for example, data collected using cookies), information about promotions, surveys, promotional campaigns and records of your decision(s) to subscribe to or to withdraw from receiving marketing materials, if any.
Information in your device(s)
We may also access your location data in your devices to enable you to access our services after seeking necessary permissions as permitted under applicable laws. We may also collect, use, process and/or share non-Personal Information and/or anonymized and/or aggregated data such as statistical or demographic data in accordance with this Privacy Policy.
Virohan may also keep records of telephone calls received and made to their personnel for provision of the services or for making inquiries, orders, or other reasons for the purpose of administration of services.
Any data that is freely available to the public or made available to Virohan through public sources or by way of right to information will not be considered as personal information. We do not knowingly collect personal information from children, and all information uploaded by a user shall be deemed to be uploaded in compliance of all applicable laws and any children uploading personal information shall be deemed to be doing so with the consent of their parent or guardian.
In case we collect any Sensitive Personal Information in order to provide our services or products to you, such as some categories of Financial Information including bank account numbers, last 4 digits of credit/debit card and details. In such cases, we ensure that such Sensitive Personal Information is collected, used, processed, stored and/or disclosed in accordance with this Privacy Policy and in compliance with applicable laws of India.
Virohan may include other optional requests for information from the Users with a view to customize the App to deliver personalized information to the User and for other purposes as mentioned in this Privacy Policy. Any such additional personal information will also be processed in accordance with this Privacy Policy.
Virohan shall not be responsible in any manner for the authenticity of the information including the Personal Information or Sensitive Personal Information supplied by the User to Virohan. If a User provides any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or Virohan has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, Virohan has the right to suspend or terminate use of features or services on the App at its sole discretion.
Virohan has implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. While we try our best to provide security that is commensurate with the industry standards, because of the inherent vulnerabilities of the internet, we cannot ensure or warrant complete security of all information that is being transmitted to us by you. However, Virohan will take all reasonable measures to ensure that your information is not modified or used for any unauthorized purposes.
How do we collect your Personal Information?
How we collect Personal Information (including Sensitive Personal Information) will depend on the following broader situations:
If we receive or collect it directly from you
We collect Personal Information (including Sensitive Personal Information) directly from you in different ways on the App or through product or service offerings. For example, you give us your Personal Information (including Sensitive Personal Information) when you:
Collection from third parties, business partners or from publicly available sources
We obtain Personal Information (including Sensitive Personal Information) through third parties including our business partners, independent service providers or from publicly available sources, as permitted under applicable laws of India.
Use of Personal Information
Virohan will collect, process and retain your personally identifiable information to the extent that it is necessary to fulfill our services to you, as is permitted under applicable laws and for regulatory purposes. Any personal information submitted by you on the App or collected by us will be used only for the purposes mentioned below:
Disclosure of personal information
Virohan, in the course of performance of the services may need to disclose/ transfer certain personal information to third parties for the purposes mentioned in this Privacy Policy and the Terms & Conditions. The third parties to whom such information may be disclosed include:
How long will personal information be retained
Virohan may store your Personal Information (including Sensitive Personal Information) for as long as the same is required and is permissible as per the applicable laws in India for the fulfilment of purposes for which we collected it. The retention of Personal Information (including Sensitive Personal Information) by Virohan is determined by considering compliance with legal (that is, contractual or statutory or regulatory requirements), accounting and compliance reporting requirements.
Security Policy
We are committed to safeguarding your Personal Information and implement reasonable security practices and procedures to protect it from unauthorized access, alteration, disclosure, or destruction. In line with this, App takes necessary steps, within its limits of commercial viability and necessity, to ensure that the user's information is treated securely. We store and process your personal information on AWS cloud servers, Google Cloud Platform and other cloud service providers within and outside India. Some of the safeguards We use are firewalls and encryption using SSL, and information access authorization controls. We use reasonable safeguards to preserve the integrity and security of your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of your information. Subject to applicable laws, the information you provide to us may be stored on our secure servers located within or outside India.
Virohan takes careful precaution to protect our Users' information from unauthorized access, improper use or disclosure or unauthorized modification. To prevent unauthorized access, we have put in place the industry-standard security technology and procedures to safeguard the information we collect online including technical, operational and physical security controls. We store your personally identifiable information on the computer servers placed in a secure environment. Even though we have taken significant steps to protect your information and specifically your personally identifiable information, no company, including the App can fully eliminate security risks associated with personal information. We further disclaim any responsibility for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
However, it is important to note that no method of data transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security, and you are encouraged to take precautions to protect your information, such as using secure passwords and keeping your devices safe.
User Responsibilities
If any user gains access to our APIs, whether secured or unsecured, without explicit authorization, such use shall constitute a violation of our Privacy Policy and Terms and Conditions. Unauthorized access, use, or disclosure of our APIs is strictly prohibited, and we reserve the right to take appropriate legal action against any individual or entity found violating these terms.
Third Party Links
The links to third-party advertisements, third party Apps or any third-party electronic communication services (referred to as "Third Party Links") may be provided on the App which are operated by third parties and are not controlled by, or affiliated to, or associated with Virohan unless expressly specified on the App. If you access any such Third-Party Links, we request you review such App's privacy policy. Virohan does not have oversight of these third-party websites, plug-ins and applications and we are not responsible for their collection, processing, usage or transfer of your Personal Information or Sensitive Personal Information. Any information collected by a third party in this manner is subject to that third party's own data collection, use, processing and disclosure policies and you must make yourselves conversant with those.
Marketing
In relation to the products and services provided by us including our business partners or affiliates with whom we share your Personal Information (including Sensitive Personal Information) as per this Privacy Policy, you may receive marketing communications from Virohan or such other business partners or affiliates of Virohan by messages, SMS email, or through other digital modes, on the App or other platforms including social media platforms, if we have received or you have provided us your Personal Information (including Sensitive Personal Information) as per this Privacy Policy. Virohan's business partners or affiliates may market their own products or services including third party products and services using such communications. The provision of such marketing activities shall be in accordance with the applicable laws of India. For marketing activities done by Virohan, we will keep a record of marketing and communication information. You are entitled to opt out from receiving such marketing communications by either clicking on an opt-out link or un-subscribe the link, if any such link is provided, or write to us at info@virohan.org.
Virohan may also use Marketing and Communications Information in order to improve and customize the content of any ads, promotions and advertising that may be of interest to you.
Cookies
The App collects information about your use of our services, interactions with us, and details about the device you use to access our services. This includes your activity on our App, such as courses, study materials, and search queries; customer service interactions, IP address (which may indicate your general location), browser information, and data collected through cookies, web beacons, and other technologies. Such information may be stored in server logs in the form of data which will help us understand the use and number of Users visiting the App. The App uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by us for maintenance of the App and its features as well as research and development, and for provision of any services available on the App. In the course of serving advertisements or optimizing Services, we may allow authorized third parties to place or recognize a unique cookie on the Your browser which may enable them to collect information about your visits to our App. We do not store personally identifiable information in the cookies. Some or all data collected may be shared with the sponsors, investors, advertisers, developer, financing partners, strategic business partners of Virohan, in compliance with applicable laws.
Amendment of Privacy Policy
Virohan may update or amend this Privacy Policy at any time, with or without advance notice. Please revisit this page periodically to stay aware of any changes to this Privacy Policy.
Should you have any concern or reject the changes in the Privacy Policy you can refuse to accept the amendments and opt for withdrawing your Personal Information by writing to the Grievance Officer. By continuing to use the App after any changes to the Privacy Policy, you agree to accept and abide by those changes.
Governing Law and Jurisdiction
Any disputes arising under this Privacy Policy shall be governed by the laws of India. In the event of any dispute arising between the parties with respect to this Privacy Policy, the same shall be referred to a sole arbitrator and the arbitration shall be in accordance with the Arbitration and Conciliation Act of 1996. The language of arbitration proceedings shall be English. The seat and place of arbitration shall be Faridabad and the decision of the arbitrator shall be final and binding on the parties herein. Subject to the arbitration clause above, this Privacy Policy shall be subject to exclusive jurisdiction of courts in Faridabad.
Minor's Privacy
Our services do not address anyone under the age of eighteen (18) years ("Minor"). We do not knowingly collect personally identifiable information from Minors. If you are a parent or guardian and you are aware that your Minor has provided us with Personal Information, please contact us. If we discover that a Minor has provided us with Personal Information, we will delete such information from our servers immediately.
Grievance Officer
If you have any complaints or grievances or concerns with respect to the App or this Privacy Policy, please inform such matters to the designated Grievance Officer as mentioned below in writing or through electronic mail:
Name: Anshul Pandey
Contact Details: info@virohan.org
Designation: Manager, Legal
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