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Privacy Policy

Privacy Policy

1. Introduction

SETU (together with its subsidiaries, and international affiliates, hereinafter "SETU," "us," "we," or "our" or “the Company”) is committed to security and management of personal data, to function effectively and successfully for the benefit of our stakeholders, customers and for the community. In doing so, it is essential that people’s privacy is protected through the lawful and appropriate means for handling the personal data. Therefore, we have implemented this privacy policy (hereinafter referred to as ‘‘policy’’).

2. Aim

This policy aims to protect personal data of the various stakeholders connected to our organization. This policy is aimed at providing individuals notice of the basic principles by which the company processes the personal data of individuals (“Personal Data”) who visits, uses, deals with and/or transacts through the website and includes a guest user and browser (hereinafter ‘you’, ‘user’).

3. Purpose and Scope

The purpose of this policy is to describe how SETU collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to https://www.SETU.com/ (hereinafter the "website"). This policy is also designed to provide information on how SETU ensures data security, conducts data transfers and process requests from data subjects.

This policy control applies to all systems, 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 SETU.

The company is also committed to ensure that its employees conduct themselves in line with this, and other related, policies. Where third parties process data on behalf of SETU, the Company endeavors to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.

SETU offers curated and specially designed higher education and industry-relevant certification programs online (“hereinafter individually or collectively referred to as Program”). This Privacy Policy applies to all our services unless specified otherwise.

4. Types of Personal Data collected

4.1 Data you provide to us:

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 or other countries) of SETU. The following types of Personal Data may be held by the Company, as appropriate, on relevant individuals:

Registration

To create an account, you need to provide data including your name, email address and/or mobile number, and a password. For payment, you will need to provide payment (e.g., credit card) and billing information.

Profile

You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. You do not have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and business opportunities find you. It is your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

Posting and Uploading

We collect personal data from you when you provide, post, or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or salary), respond to a survey, or submit a resume or fill out a job application on our Services. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, e.g., times, places, attendees and contacts.

You do not have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

4.2Data we collect about you from your use of our Site:

We will automatically collect information from you each time you visit our Site whether or not you enter the Site as a registered user. This includes technical information, information about your visit, and information about your activity on our Site such as courses searched and viewed, page response times, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods to browse to and away from a page, and methods used to contact our sales and support teams. Technical information may also include the internet protocol (IP) address used to connect your device to the internet, unique device identifiers, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating systems, and device platform.

4.3 Data we receive from other sources:

This is information we receive about you from third parties that we work closely with to provide, promote, and improve our services. These third parties include business partners, vendors who assist in technical and payment services, advertising networks, analytics providers, and search information providers.

5. Sources of data collection

The data collected by the company is derived directly from the data provided by the user or by use of our sites.

Data Collected when You:

  • • Register for various seminars, webinars or any other outreach initiatives made available by us or Educational Partner’s offline activities
  • • Request a quote for the various products and services offered by us
  • • Place feedback, complete any customer 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

Data Collected from third parties We receive Personal Data such as access or login details, profile picture or any other text / image in relation to your Personal Data which may be available with such third parties. We also receive information about your visits to this platform and to other websites using pixel tags.

Third parties from whom we receive your Personal Data include, our service providers, other networks connected to our service, our advertising partners, our marketing and advertising affiliates, our educational partners, scholarship providers, analytics providers, recruiters and such other third-party sources.

6. Cookies

Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behavior information by Us. When You visit the Website(s), We may collect Personal Data automatically from You through cookies or similar technology. We also set cookies to collect information that is used either in aggregate form to help Us understand how Our Website(s) is being used or how effective Our marketing campaigns are, to help customize the Website(s) for You or to make advertising messages more relevant to You.

Essential Cookies: We set essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing Your browser settings, but this may affect how the Website(s) functions.

Analytics, Customization and Advertising Cookies: We set these cookies to help Us improve Our Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.

When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt out of non-essential cookies as required by applicable laws.

7. Data protection principles

Where third parties process data on behalf of SETU, we endeavor to obtain assurances from such third parties that your Personal Data will be safeguarded consistently. We understand that it will be accountable for the processing, management and regulation, and storage and retention of all Personal Data held in the form of manual records and on computers.

All Personal Data obtained and held by the Company will:

  • • be processed fairly, lawfully and in a transparent manner
  • • be 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 unauthorized or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organization measures
  • • comply with the relevant laws and procedures for international transferring of Personal Data applicable to us.

8. Legal basis for processing your Personal Data

Certain jurisdictions require that we have a lawful basis to justify our processing of your Personal Data.

Where applicable, the lawful basis that SETU relies upon to justify a particular processing activity may differ from the lawful basis used to justify a different processing activity.

SETU relies on the following lawful basis to process Personal Data, as permitted under applicable law:

  • • Processing necessary for the negotiation, execution, or performance of contracts
  • • Processing to comply with legal and regulatory obligations
  • • Processing in furtherance of our legitimate interests, including our interests to conduct legitimate business activities (such as improving our products and services, to communicate with you, to secure our systems, among other legitimate interests)
  • • Processing necessary to protect vital interest of a user or any other natural person
  • • Processing necessary for public interest
  • • Processing based on your consent

9. 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, SETU 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 use 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 client, customer, member does not opt-out.

Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), individuals can withhold or withdraw their consent for SETU to use their personal information in certain ways.

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 and our Terms of Service.

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.

10. Purpose of collecting Personal Data

We collect your Personal Data for the following purposes

Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.

Functional: These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behaviour of the Services (like your preferred language or volume level for video playback).

Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of SETU to see which features or content users prefer and determine which email messages are opened.

Advertising: These Data Collection Tools are used to deliver relevant ads (on the site and/or other sites) based on things we know about you like your Usage and System Data, and things that the ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.

Social Media: These Data Collection Tools enable social media functionality, like sharing content with friends and networks. These cookies may track a user or device across other sites and build a profile of user interests for targeted advertising purposes.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional.

11. Disclosure of Personal Data

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

  • • With Your Instructors: : We share data that we have about you (except your email address) with instructors or teaching assistants for educational content you access or request information about, so they can improve their content for you and other students. This data may include things like your country, browser language, operating system, device settings, the site that brought you to SETU, and certain activities on SETU, like enrolled courses and course review. We will not share your email address with instructors or teaching assistants. (Account Data; System Data; Usage Data; Approximate Geographic Data)
  • • With Other Students and Instructors: Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and instructors. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable. Note that all chat rooms, message boards, news groups, or other public forums available to participants are publicly visible to other participants, so you shouldn’t post any confidential or proprietary information through those features. (Account Data; Profile Data; Shared Content)
  • • With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing, and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. (All data categories)
  • • With SETU Affiliates: We may share your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services. (All data categories)
  • • With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to SETU. Depending on your location, we may share your data with these trusted partners. (Account Data; Learning Data; Communications and Support; System Data)
  • • With Credit-Granting Organizations for Continuing Education: If you take a course to fulfil a continuing professional education requirement, we may share that information upon request of the organization granting the continuing education credit. (Account Data; Learning Data)
  • • With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like ZoomInfo, we share certain contact information or de-identified data. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner. (Account Data; System Data; Usage Data; Cookie Data)
  • • To Power Social Media Features: The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy. (System Data; Usage Data; Cookie Data)
  • • To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey. (Account Data; Sweepstakes, Promotions, and Surveys)
  • • For Advertising: If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools, to use this data to offer you targeted ad delivery to personalize your user experience (through behavioural advertising) and to undertake web analytics. Advertisers may also share with us the data they collect about you. Note that if you opt out, you’ll continue to be served generic ads. (System Data)
  • • For Security and Legal Compliance: We may disclose your data (all data categories) to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
    • o Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
    • o Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
    • o Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
    • o Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
    • o Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of SETU, our users, employees, members of the public, or our Services;
    • o We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or
    • o Required or permitted by law.
  • • During a Change in Control: If SETU undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence). (All data categories)
  • • After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.
  • • With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy. (All data categories)

12. Our Policy on Children’s Data

Children’s data privacy is important to us. Our Sites are not intended for children Age to constitute a user as children is different for different jurisdictions. The age (for valid consent) of children varies across jurisdictions. For example, under GDPR child is a person aged 16 years or below, and in United Kingdom, children is someone who is aged 13, in case of Singapore and Qatar the valid age for providing consent is 18 years.

As a general policy, our company does not engage in the collection, processing, storage, use, dissemination, and transfer of Personal Data of children.

In case such a collection becomes necessary for the performance of our contractual obligations, or when required under the concerned law, we shall notify you in a time-bound and appropriate manner, informing the purposes and reasons for such collection and seek your explicit consent, and where applicable, parental authorization, prior to the processing of such data.

We will take appropriate steps to delete any Personal Data of children’s that has been collected on our website without verified parental consent upon learning of the existence of such Personal Data, subject to conditions stipulated in the laws of applicable jurisdiction.

Data Security

SETU takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and SETU, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact our Support Team with any concerns.

International data transfers

We mainly Process Personal Data in India. However, we may transfer Personal Data outside India for the purposes referred to in Section 11. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.

If You are a resident of the European Economic Area and when Your Personal Data is Processed outside EEA, we will ensure that the recipient of Your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

15. Records management

Records management refers to a set of activities required for systematically controlling the creation, distribution, use, maintenance, and disposition of recorded information maintained as evidence of business activities and transactions. It is impossible to be compliant with information law without robust records management policies and practises. Good records management practices ensure not only record quality, but that Personal Data is only kept for as long as necessary for its original purpose and help support data minimization.

16. Organization and Responsibilities

SETU will maintain records of data processing as required by the laws.

The ‘Data Protection Officer’ (DPO) has the specific responsibility of overseeing data protection and ensuring that we comply with the data protection principles and relevant legislation. The DPO will ensure that the Data Processing Register is kept up to date and demonstrates how the data protection principles are adhered to by our activities. Individual members of staff have a duty to contribute to ensure that the measures outlined in the Register are accurately reflected in our practice.

Our compliance with relevant policies and regulatory requirements in respect of data protection as part of our Data Management Strategy will be periodically monitored internally by a designated governance group. All employees, volunteers, consultants, partners, or other parties who will be handling Personal Data on behalf of SETU will be appropriately trained and supervised where necessary.

The collection, storage, use and sharing of Personal Data will be regularly reviewed by the Data Protection Officer, the Governance Group, and any relevant business area. We will adhere to relevant codes of conduct where they have been identified and discussed as appropriate.

Where there is likely to be a high risk to individuals rights and freedoms due to a processing activity, we will first undertake a Data Protection Impact Assessment (DPIA) and consult with the relevant supervisory authority prior to processing, if necessary.

17. 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.

18. Retention of Personal Data

We retain your Personal Data, not longer than necessary for the purposes for which it was collected. The length of time to retain Personal Data depends on the purposes for which we collect and use it and/or as may be required to comply with applicable laws, to establish, exercise, or defend our legal rights.

The users can exercise their rights enumerated herein. Also, if in case required to extend the period of retention of such data, we shall obtain your consent for the same. Further, we may also dispose the data prior to completion of the period of retention, if the purpose for which it was collected is exhausted.

19. Procedures

The Company has taken the following steps to protect the Personal Data of relevant stakeholders, which it holds or to which it has access:

  • • it appoints or employs employees with specific responsibilities for: o the processing and controlling of data
    • the comprehensive reviewing and auditing of its data protection systems and procedures
    • overviewing the effectiveness and integrity of all the data that must be protected.
    • There are clear lines of responsibility and accountability for these different roles.
  • • it provides its employees with information and training to make them aware of the importance of protecting Personal Data, to teach them how to do this, and to understand how to treat information confidentially
  • • it can account for all Personal Data it holds, where it comes from, who it is shared with and also who it might be shared with
  • • it carries out risk assessments as part of its reviewing activities to identify any vulnerabilities in its Personal Data handling and processing, and to take measures to reduce the risks of mishandling and potential breaches of data security. The procedure includes an assessment of the impact of both use and potential misuse of Personal Data in and by the Company
  • • it recognizes the importance of seeking individuals’ consent for obtaining, recording, using, sharing, storing and retaining their Personal Data, and regularly reviews its procedures for doing so, including the audit trails that are needed and are followed for all consent decisions. The Company understands that consent must be freely given, specific, informed, and unambiguous. The Company will seek consent on a specific and individual basis where appropriate. Full information will be given regarding the activities about which consent is sought. Relevant individuals have the absolute and unimpeded right to withdraw that consent at any time
  • • it has the appropriate mechanisms for detecting, reporting, and investigating suspected or actual Personal Data breaches, including security breaches. It is aware of its duty to report significant breaches that cause significant harm to the affected individuals to the relevant supervisory authority, and is aware of the possible consequences
  • • it is aware of the implications international transfer of Personal Data internationally.

20. Breach notification

Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the relevant supervisory authority within 72 hours of the Company becoming aware of it and may be reported in more than one instalment. Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual. If the breach is sufficient to warrant notification to the public, the Company will do so without undue delay.

21. External Links on our website

For your convenience we may provide links to sites operated by organizations other than SETU ("Third Party Sites") that we believe may be of interest to you. We do not disclose your Personal Data to these Third-Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third-Party Sites. If you choose to click on a link to one of these Third-Party Sites, you should review the privacy policy posted on the other websites to understand how that Third-Party website collects and uses your Personal Data.

SETU uses YouTube API Services to play YouTube videos. When a YouTube video is played, the app communicates directly with the content provider (YouTube) and not with SETU. Users of the app should be aware of the Google Privacy Policy available at https://policies.google.com/privacy, which states how YouTube treats user data. SETU does not have any record of the videos watched or any other user related YouTube API data. We take no responsibility for the content or practices of any third-party services in the Third Party Sites.

We encourage you to carefully review the terms of services/use of any third-party services or Third Party Sites you access.

22. Use of this website and our Terms of Service

This website is the property of the SETU. Our Terms of Use and this Privacy Policy collectively govern the use of the Platform and the Programs offered by SETU. This Privacy Policy shall form a part of the Terms by way of reference. By using this website and the information offered herein, you indicate your acceptance of these Terms of Use.

23. Updates to this policy

We may update our Privacy Policy from time to time. We will take reasonable steps to inform all SETU entities, Customers, Business Partners, and other data subjects affected by the revisions by posting the new Privacy Policy on this page and/or via email.

24. Data Controller/ Company Details

The "Data Controller" (i.e., SETU) means the entity that will make the decisions about how your data is used and that is responsible for deciding how it holds personal information about you. Since SETU is made up of different legal entities, the entity that will be the controller for your data is dependent on the situation where your Personal Data is collected.

25. Data Protection Officer

The company, in accordance with the applicable laws, and all applicable rules made thereunder, has appointed a Data Protection Officer; who can be reached at the details below:

Name: Mr. Shiva

Email: shiva@setuschool.com