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:
- access the App;
-
register for programs offered on the App in the manner as provided
for in the Terms & Conditions;
-
submit any information to Virohan; and
-
use any features and services offered by Virohan on the App.
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:
-
give us your Contact Information so that we can contact you about
our services and products;
-
conclude a contract or verify to us who you are (whether by email,
phone or electronic verification);
-
provide your Personal Information (including Sensitive Personal
Information) on the Apps, or by connecting to us through other modes
of communication, both online or offline;
-
provide your Personal Information (including Sensitive Personal
Information) on the checkout pages in order for us to complete the
transaction(s);
-
provide your Personal Information (including Sensitive Personal
Information) when you send us a support request including filing a
complaint or for resolution of dispute with us or raise any
query;
-
apply for our products or services directly with us or through our
business partners (such as university websites, offline campuses,
resellers or business partners);
-
are prompted to give us your Identity and Account Log-In
Information, Contact Information, Financial Information,
Identification Information, and/or Payment Information on our web
checkout /payment pages or via other similar channels to complete a
transaction;
-
enter a competition, promotion or survey or you agree to receive
marketing materials to be sent by us; or
-
access, use and/or browse our App.
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:
-
For registration of the User on the App;
-
To carry out our obligations arising from your requests for
services on the App;
-
To improve the App's functionality, and to customize your future
experience with us;
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To make sure that our App's content is presented in the manner that
is most effective for you;
-
To deliver personalized information and target advertisements to
the user;
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For conducting research on efficient administrative practices on
the App;
-
To communicate with you about any changes to our services, special
offers;
-
Non-personally identifiable information, exclusively owned by
Virohan may be used in an aggregated or non-personally identifiable
form for internal research, statistical analysis and business
intelligence purposes including those for the purposes of
determining the number of visitors, and Virohan may sell or
otherwise transfer such research, statistical or intelligence data
in an aggregated or non-personally identifiable form to third
parties and affiliates;
-
Ensuring that the provisions of the Terms of Use and Privacy Policy
are complied with by all users;
-
To record, support and facilitate your participation in the
services you select, track your preferences;
-
To notify you of any updated information relating to the products
and services on the App;
-
To assist you with customer service or technical support
issues;
-
To follow up with you after your visit to any campus of
Virohan;
-
To otherwise support Your relationship with us and/or to prevent
fraud and unlawful use;
-
To comply with our legal, regulatory and contractual
obligations;
-
For our legitimate business interests (where permissible by law) or
those of a third party;
-
Where you have given us explicit consent to do so.
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:
-
Third party service providers to perform various services on our
behalf or assist us in delivering our services to you. These service
providers help with tasks such as marketing, advertising, customer
communications, infrastructure and IT services, personalizing and
optimizing your experience, processing payments, providing customer
support etc. for the purpose of ensuring services are available on
the App.
-
To our affiliates in India or in other countries who may use and
disclose your information for the same purposes as us.
-
To our employees for the purpose of ensuring provision of services
on the App, subject to the fact that our employees shall be bound by
obligations of confidentiality.
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To government institutions/ authorities to the extent required:
-
under the laws, rules, and regulations and/ or under orders of
any relevant judicial or quasi-judicial authority;
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for the purposes of prevention, investigation and prosecution of
cyber incidents;
-
for reporting any offenses committed by users;
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to protect and defend the rights or property of Virohan;
-
to enforce Virohan's Terms of Use (of which this Privacy Policy
is also a part);
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for verification of any information provided by Users; or
-
when Virohan, in its sole discretion, deems it necessary in
order to protect its rights or the rights of others.
-
To third party ad servers, ad agencies, technology vendors such as
Facebook, Google etc., and research firms to serve advertisements to
the user.
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Where substantially all our assets are acquired by a third party,
such information may be one of the assets that is transferred or
acquired by a third party. Under such circumstances, Virohan would
attempt to ensure that the third party acquiring Virohan follows the
provisions of this Privacy Policy and process your personal
information as set forth in this Privacy Policy.
-
Details like your name, testimonials, exam scores, and other
relevant information about exams/courses you have pursued or plan to
pursue, may be shared for promotional purposes. This may include
sharing across various media channels such as social media
platforms, television commercials, digital advertisements,
hoardings, interviews, live events, and on our mobile app or
websites. You consent to this sharing of Personal Information for
promotional activities that support Virohan's business
strategy.
-
We may disclose account information if we believe it is necessary
to identify, contact, or take legal action against individuals
violating our terms and conditions of service or causing harm to our
rights, property, or users.
-
When making purchases, your information will be transferred to
third-party payment processors. These payment gateways may also
access your purchase details and sensitive financial information
like your credit/debit-card details are transacted upon secure sites
of approved payment gateways which are digitally under
encryption.
-
If you express interest in availing an educational loan or other
financial services, we may share your personal information with
financial institutions and other third parties in compliance with
applicable laws and as necessary. This information will be used for
assessing your eligibility for loans, processing your loan
applications, and facilitating the loan approval process.
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