1. Introduction Clause:

CounselIndia Services Pvt. Ltd. hereinafter "CI, " "Counsel India, " " us, " " we, " or " our " or “the Company”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://www.counselindia.com/ and our mobile application, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”)

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site. We reserve the right to make changes to this Privacy Policy at any time and for any reason.

We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of any such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

The policy is compliant as per the Digital Personal Data Protection Act, 2023(DPDPA 2023) and CI shall abide by the provisions of the DPDPA 2023.

2. Scope:

The policy applies to everyone who visits our website systems, mobile application, people and processes that constitute the organization’s information systems, including board members, directors, employees and other third parties who have access to Personal Data available within CI. The company is also committed to ensure that its employees conduct themselves in line with this, and other related policies.

3. Information Collection and Use:

For a better experience while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to your name, phone number, and postal address. The information that we collect will be used to contact or identify you.

The Personal Data that we collect about you depends on the context of your interactions with us, the products, services and features that you use, your location, and the applicable laws.

Personal Data is stored in personnel files or within the electronic records (on servers in India) of CI. The following types of Personal Data may be held by CI, including but not limited to the points stated below:

Personal Identification Data & Characteristics
• First & Last name
• Contact Details – Mobile Number, Email ID, Address
• Job title & Company
• Signature
• Photographs
• Age & Gender
• Date of Birth
• Marital Status
• Nationality
• Educational qualification(s)

Identification Data
• Social security or tax identification numbers
• Aadhar number and PAN

Financial Data
• Bank Account information
• Salary Information
• Payment gateway account details
• E-wallet account details

Electronic Identification Data
• Login credentials (If you are a registered user)
• Visitors IP Data
• Date and time of website visit
• Pages visited and navigation on the website
• Browser being used
• County of accessing website
• Language of the browser being used
• Words searched for
• Pixel tags

Inquiries & Interactions
• Subject of Inquiry
• Personal details (Name on the card, billing address)
• Payment details (card numbers, card type)
• Recordings of calls with students and users showing interest in our Program.
• Information about your interactions with customer service and maintenance interactions with us.

User Generated Data
• Projects and Assignments submitted
• Peer feedback, assessment evaluation and grading
• Program performance data
• Response to quizzes, standalone quizzes, exams, and surveys
• Web Cam Recordings (during assessments related to online courses)
• Posts made to public forums through our platform
• Any other necessary information.

Marketing Data
• Your preferences in receiving marketing information from us
• Your communication preferences
• Data inferred or assumed information relating to your behaviour and interests based on your online activity on our sites

4. Sources of Data:

We want to inform you that whenever you visit our website or mobile application, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other statistics. The data will be collected by CI including, but not limited to the circumstances as mentioned below:

Register for various seminars, webinars, bootcamps or any other outreach initiatives made available by us

Request a quote for the various products and services offered by us

Place feedback, complete any surveys circulated or interact with our customer services online

View our services or visit our website pages on the internet

Browse our website

When you appear for assignments, exams or any other assessments in relation to online course

When you avail scholarships, refunds and referrals

We also receive information about your visits to this platform and to other websites using pixel tags.

5. Consent:

We may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law. Once consent is obtained from the individual to use his or her information for those purposes, CI has the individual' s implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new user is identified.

Consent may also be implied where a user is given notice and a reasonable opportunity to opt- out of his or her personal information being used for mail-outs, the marketing of new services or products, and the customer, member does not opt-out.

Further, by using this website/acknowledging this privacy policy/by voluntarily providing us with your Personal Data, you consent to collection, storage, and processing of your Personal Data in accordance with this privacy policy. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Data, we may not be able to provide you the services that can be offered on our Platform.

6. Purpose of Collecting Data:

Manage and process your information, including tracking attendance, progress, and completion of a Program.

Administer exams, projects, and other assessments for the Program.

To conduct internal trainings and quality checks.

Send updates about Programs, events, platform maintenance, or new services provided by CI, via WhatsApp, email, SMS, phone call, or any other medium.

Provide Chat Room services.

Enhance the quality of our content and product offerings.

Ensure compliance with security and other mandatory policies, including building access.

Provide information to relevant external authorities for legal purposes, such as tax and social security.

Conduct surveys to assess satisfaction with processes or policies.

Set up and maintain accounts and subscriptions with third parties for information, research, or communication services.

Make decisions about your continued engagement, employment, or membership.

Handle legal or regulatory disputes or investigations, including accidents at work, negligence claims, and professional discipline matters.

Monitor use of our information and communication systems to ensure compliance with IT and document management policies.

Ensure network and information security, including preventing unauthorized access and malicious software distribution.

Manage business operations, including accounting, auditing, and insuring.

Plan or review options related to operations or management.

Maintain registers required by law or regulation.

Communicate with you, including responding to inquiries.

Enhance the safety and security of services and prevent fraud, protecting our company’s and your rights or property.

Enforce applicable terms and conditions and other policies.

7. Disclosure of Personal Data:

We may disclose your Personal Data to third parties in the following circumstances:

Service Providers: We may share your Personal Data with third-party service providers who assist us in delivering our services, such as hosting providers, payment processors, and analytics providers. These service providers are contractually obligated to use your Personal Data only for the purpose of providing the services requested by us and in accordance with this Privacy Policy.

Business Partners: We may share your Personal Data with our business partners, affiliates, or educational institutions with whom we collaborate to offer joint programs or services. These partners may use your Personal Data for their own purposes in accordance with their privacy policies.

Legal Compliance: We may disclose your Personal Data to comply with applicable laws, regulations, legal processes, or governmental requests. We may also disclose your Personal Data to enforce our terms of service, protect our rights or property, or prevent fraud or harm to our users or others.

Corporate Transactions: In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your Personal Data may be transferred or disclosed as part of the transaction. We will take reasonable steps to ensure that any such transfer or disclosure complies with applicable data protection laws and regulations.

With Your Consent: We may disclose your Personal Data to third parties for other purposes not described in this Privacy Policy with your consent or at your discretion.

Please note that we are not responsible for the privacy practices of third-party websites or services to which we may link or integrate. We encourage you to review the privacy policies of those third parties before providing them with your Personal Data.

8. Assurance Clause:

All Personal Data obtained and held by the Company will:

Be processed fairly, lawfully and in a transparent manner

Collected for specific, explicit, and legitimate purposes

Be adequate, relevant and limited to what is necessary for the purposes of processing

Be kept accurate and up to date. Every reasonable effort will be made to ensure that inaccurate data is rectified or erased without delay

Not be kept for longer than is necessary for its given purpose

Be processed in a manner that ensures appropriate security of Personal Data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures

Comply with the relevant laws and procedures for international transferring of Personal Data applicable to us.

We may also share aggregated or anonymized data that does not directly identify you with third parties for research, analysis, or other purposes.

We do not sell, rent, or trade your Personal Data to third parties for their own marketing purposes without your explicit consent.

9. Cookies:

Cookies are files with small amount of data that is commonly used as an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive.

Our website uses these " cookies " to collect information and to improve our Service. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Service. When you visit our website, we may collect information from you automatically through cookies or similar technology.

10. Data Analytics:

We use Analytics tools and search information providers to measure how visitors interact with content on our website. We also use several applications to measure how you interact with the ads.

We may use data analytics tools and techniques to analyse aggregated and anonymized information collected through our Edtech services for the purpose of improving our platform, understanding user behaviour, and enhancing the learning experience. These analytics may involve processing usage data, patterns, trends, and interactions to identify areas for improvement, personalize content, and develop new features. We do not use personally identifiable information for data analytics without your explicit consent. Additionally, we take measures to ensure that individual users cannot be identified from the aggregated data used for analytics purposes. Our use of data analytics complies with applicable laws and regulations, and we are committed to protecting the privacy and confidentiality of your personal information throughout the analytics process.

11. Protection of Children's Data:

We do not knowingly collect personal information from Children under the age of 18 ("Children " or "Child") without verifiable parental consent. If you are a parent or guardian and believe that your Child has provided personal information to us without your consent, please contact us immediately, and we will take steps to remove that information from our systems.

In compliance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, we are committed to protecting the privacy and safety of Children online. We take reasonable steps to verify parental consent before collecting personal information from Children and provide parents or guardians with the option to review, modify, or delete their Child' s personal information.

Parents or guardians who wish to review, modify, or delete the personal information of their Child can contact us at wecare@counselindiaservices.in We encourage parents and guardians to actively monitor and supervise their Child' s online activities to ensure a safe and secure experience.

We adhere to all applicable laws and regulations governing the collection, use, and disclosure of Children ' s personal information in India, including the Information Technology Act, 2000, and the Protection of Children from Sexual Offences (POCSO) Act, 2012. If you have any questions or concerns about our handling of Children ' s personal information, please contact us.

12. Conflicts of Law:

This Policy is intended to comply with the laws and regulations in the place of establishment and of the countries in which company operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.

13. Data Protection System & Security:

CI has implemented the following measures to safeguard the Personal Data of relevant stakeholders, which it holds or accesses:

Comprehensive review and auditing of data protection systems and procedures

Oversight of the effectiveness and integrity of all protected data, with clear lines of

responsibility and accountability for these roles.

Provision of information and training to employees to:

Raise awareness about the importance of Personal Data protection

Educate on proper handling procedures

Emphasize the importance of confidentiality.

Conducting risk assessments to identify vulnerabilities in data handling and processing

Implement measures to mitigate risks of mishandling and breaches.

Implementation of mechanisms for:

Detecting, reporting, and investigating suspected or actual Personal Data breaches

Reporting significant breaches to relevant supervisory authorities.

In the event of a personal data breach, CI shall give the Board and each affected user intimation of such breach in such form as prescribed by the Digital Personal Data Protection Act, 2023.

We value your trust in providing us with your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

14. Links to Other Sites:

Our Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

15. Update of Privacy Policy:

As CI will continuously evolve and grow, our privacy policy will need to evolve so as to cover new situations. You are advised to review this Policy regularly for any changes, as continued use is deemed approval of all changes.

16. Contact Us:

If you have any questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact us at Data Protection Officer (DPO) named Rahul Sharma at rahul.sharma@counselindiaservices.in
This Privacy Policy was last updated on 27.03.2024.