1. LEGAL BASIS OF PROCESSING PERSONAL INFORMATIONWe process your Personal Information on the following legitimate basis as also mandated under certain applicable laws:
1.1 Consent: Processing based on your consent
1.2 Legitimate interests: Processing in furtherance of our legitimate interests to provide and personalize our services to you including our interests to conduct legitimate business activities (such as improving our products and services, communicating with you, to secure our systems, among other legitimate interests like processing of a payment, fraud detection, for the establishment, exercise, or defense of legal claims; or you have made the data manifestly public.
1.3 Compliance with legal obligations: We may process your personal data if necessary for us to comply with a legal obligation arising under an applicable law to which we are subject.
2. TYPE OF INFORMATION WE COLLECTPersonal Information as defined above is collected by us when you browse or use our website and when you register as a user to subscribe to our services. We collect, process, and store your Personal Information, to provide a safe, efficient, and customized experience to our Users accessing the Website. You can browse through the Website without giving any Personal Information about yourself or by creating an account to avail of our services on the Website. These services shall include but not be limited to providing the Users with online pathways, participating in public forums, sign-up for email, calling and SMS, WhatsApp updates, purchase our services. To register and create an account (“Account”), you may be required to provide us with your contact and identity information and other Personal Information as indicated on the Website and complete the registration process. Where possible, we indicate which fields are mandatorily required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature on the Website unless we require it so. Your Account Personal Information is protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your mobile phone and browser by signing off after you have finished accessing your Account. We advise you to not share login credentials/Account information with anyone to avoid unauthorized access.
2.2 Information Automatically Collected/ Acquired Information
2.2.1. Location Information and IP Address: When you access the Website, your IP (“Internet Protocol”) address is recorded by us. This method ensures smooth operations and protection against attacks and requires the user’s IP address to be saved for the duration of the session. We may be able to determine from an IP address a User’s Internet Service Provider and the geographic location of his or her point of connectivity.
2.2.2. Device Information: We collect information about the apps, browsers, and devices you use to access our website, which helps us provide features like automatic service updates. The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, and mobile network information including the carrier name and phone number, and application version number.
2.2.3. Behavioural Information: We may automatically track, collect, and aggregate certain information about you based on your behavior on our Website or while accessing our services. We may use such information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve our Users. This information is compiled and analyzed on an aggregated basis.
2.4 User Generated Content: Content added, created, uploaded, submitted, distributed, and posted by Users including but not limited to feedback, queries, chats, and discussions is collectively referred to as, “User Content”. The user is the sole owner and responsible for the authenticity, and correctness of all the UGC.We may use your User Content, in a number of different ways in connection with the Services and Bluetick’s business as we may determine at our sole discretion. By submitting User Content through the Website, you hereby do and shall grant Bluetick a worldwide, non-exclusive, royalty-free, fully paid, sub-licensable (through multiple tiers) and transferable license to use, copy, reproduce, distribute, prepare derivative works of, display, perform, and otherwise fully utilize the User Content in connection with the Services and Bluetick’s (and its successors and assigns’) business, including without limitation for promoting and redistributing part or all of the Website (and derivative works thereof), publicly displaying it, reformatting it, incorporating it into marketing materials, advertisements and other works, creating derivative works from it, promoting it, distributing it, and allowing other users to do the same in connection with their own websites, media platforms, and applications (“Third Party Media”),For clarity, the foregoing license grant to Bluetick does not affect your other ownership or license rights in your User Content(s), including the right to grant additional licenses to the material in your User Content(s), unless otherwise agreed in writing with Bluetick.When you delete your User Content, it will be removed from the Website. However, you understand that any removed User Content may persist in backup copies for a reasonable period of time (but following removal will not be shared with others) or may remain with users who have previously accessed or downloaded your User Content or may be retained by Bluetick for such period as stipulated under the law. If you have questions or concerns about the legal basis upon which we collect and use your personal data, you can contact us at firstname.lastname@example.org.
3.2. Improve our Services :Information collected from your feedback, reviews, ratings you provide, poll questions, and surveys including phone interviews you take may be aggregated and analyzed by us in order to improve and enhance our services, our website, etc. Participation in these surveys is purely optional. The identity of the survey participants is anonymous unless otherwise stated in the survey.
3.3. Participation in Online courses, Micro Experiences Public Forums, and Signing Up for UpdatesWe use the Personal Information as provided by you for processing purposes, including but not limited to that of following attendance, progress, utilization, and completion of your online subscription. We may also share details regarding your performance in a given online pathway with the instructor/instructors or other designated individuals who assisted you in such content. This will help us modify, alter, and operate the online pathway conveniently. We may also collect student-generated content in the form of various assignments, peer-grading feedback, and responses related to the pathway data in the form of exams, surveys, etc. We may collect or/and store such information as provided by you.Bluetick may offer public forums. We may require your Personal information if you wish to participate and share your thoughts on these forums. Please keep in mind that such posts as shared by you will be available on our website and/or any related application or platform. We may collect and/or store such information as provided by you on these forums. We may also provide you with updates by either posting such updates on the Website or through letters, emails, calls, SMS, WhatsApp, etc.
3.5. Advertisements:We may also aggregate (gather up data across all Accounts) information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for other marketing and promotional purposes. We don’t share Personal Information that personally identifies you with advertisers, such as your name or contact information unless you ask us to.
3.7. Posting to Public Forums:Please remember that if you post any of your Personal Information in public forums of the Website, such information may be collected and used by others over whom we have no control. You are to please note that these posts may be made available in the public domain.
4. INTERNATIONAL DATA TRANSFEROur website is primarily operated and managed on servers located and operated within India. However, your Personal Data may also be stored in third-party data servers located in other countries where Bluetick provides its products and services.Bluetick engages sub-contractors, service providers and other third parties for facilitating our products, service offerings and to offer support services to you, and your Personal Data may be transferred to servers of such sub-contractors, service providers and other third parties. Depending upon the location of our service providers, your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Where required under applicable law we will seek your express consent for such transfers. In all other cases, by consenting to this policy, you also provide consent to Bluetick to transfer your Personal Data to Bluetick-affiliated companies, service providers, or any third-party entity in locations around the world. We take steps to ensure that a degree of data protection that is similar to this policy is afforded to such Personal Data transferred. Bluetick will always ensure the transfer of your personal information internationally and will be in accordance with the applicable legal requirements.
5. PROCESSING AND STORAGEUser Data is processed and stored on Bluetick’s internal servers. All User data is either stored manually or electronically. Any data stored electronically will be stored in secure servers, and any data stored manually will be stored on our premises.Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our websites and any transmission is at your own risk.
6. WITH WHOM YOUR PERSONAL INFORMATION IS SHARED
7. HOW LONG DO WE KEEP YOUR DATA?
We may retain Personal Information for as long as it is necessary. It may be archived as long as we believe that the purpose for which it was used still exists or as necessary for our legitimate business interests or for complying with legal obligations or for a period as mentioned in the applicable Laws.There will be some residual information in an anonymized form that shall remain with us within our logs, database, and other records. Such residual information may or may not include Personal Information. Please also note that we shall retain your Personal Information if we require the same for complying with a legal obligation.
8. DATA SECURITYWe endeavor to safeguard the User’s Personal Information by adhering to strict security guidelines and protecting it against unauthorized access. The website has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. All Personal Information you provide is transmitted using the minimum AES-128 encryption system. All your activity on our website from the time you log on until you log off is encrypted with an SSL certificate to ensure it remains private. We neither capture nor store your credit/debit card information. However, this cannot be guaranteed.
9. CHILDREN’S PRIVACYBluetick does not engage in the collection, processing, storage, use, dissemination, and transfer of Personal Data of children. We do not knowingly collect personal information online from children under the legal age which can vary from jurisdiction. If a child, the age of 13 has provided us with personal information online such processing shall be lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility over the child. In the event, Bluetick becomes aware that the User is a minor or below the legal age to consent in the jurisdiction concerned, Bluetick reserves its right to terminate all services to such User/ Account without any prior notice.
10. RIGHTS AVAILABLE TO THE USERYou have a right to access and rectify the record of your personal data maintained by Bluetick if it is inaccurate.You may request that Bluetick erase that data, subject to certain exceptions.You have the right to object, at any time to processing if you have concerns that Bluetick is using your data for direct marketing purposes.You have a right to restrict processing. If the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead.When technically feasible, the Bluetick will, at your request, provide your personal data to you or transmit it directly to another controller.You may also request additional information about the purpose of the processing; the categories of personal data concerned; who else outside Bluetick might have received the data from Bluetick; what the source of information was; and how long it will be stored.If access cannot be provided within a reasonable time frame, Bluetick will provide you with a date when the information will be provided.In the event you wish to exercise any of the above, you may send your written request to email@example.com
12. THE OPT-OUT PRACTICEIf you are no longer interested in receiving email announcements and other marketing information from us, or you want us to remove any personal information that we have collected about you, you can opt out anytime by sending an e-mail about your request to firstname.lastname@example.org
Grievance Officer and DPO: Mr. Mohit Malani
Email Id: email@example.com
Address: Langston Apartments, Kharadi, Pune, Maharashtra, India – 411014
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