You can browse the Website without telling us who you are or revealing any personal data about yourself. If you give us your personal data, then, you are not anonymous to us. You always have the option to not provide information by choosing not to use a particular service or feature on the Website. You may need to provide us some of your personal data during the course of using some of the services provided on our Website or while registering with us.
1. What data do we collect?
The personal data (“Data”) we collect is likely to include:
- Your IP address
- Cookie IDs
- Email address
- Information about your course in your educational institution (degree, department & semester)
- Phone number
- Avatar (image)
Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation. We do not intentionally collect any sensitive personal data from you through the Website.
2. How do we collect your Data?
You directly provide our company the Data when you:
- Use or view our Website via your browser’s cookies; or
- Sign up for a Program/course (name and email address); or
- Add additional profile information (like your ‘avatar’).
Pupilfirst may also receive Data indirectly from the following sources:
- From the educational institution that you are enrolled with when you sign up for a course that Pupilfirst provides in partnership with your educational institution (name, email address, course name & semester).
- From applications that you fill in as part of your off-Website course enrolment process.
3. How will we use your Data?
We use the data we collect to:
- Verify your identity (for example, when you return to the Website, and have already logged in).
- Providing personalized content and information to you.
- Send you service messages regarding your account, for example, if you attempt to reset your password, we’ll need to send you an email at your email address provided.
- Respond to you about something you’ve posted on communities linked to the courses that you’re taking, or submissions on course targets.
- Contact you regarding important course milestones, or course-related notifications such as information about expert sessions, revised content, etc.
- When enrolled in a course implemented in partnership with your university, your phone number would be used to add you to WhatsApp groups created to facilitate communication between you, your peers, coaches, course administrators, and college faculty coordinators.
- Deal with any query or complaint you submit to our support team.
- To store and use information about any service errors or interruptions that you have experienced in order to help us create fixes and to make technical improvements to our Website.
- For complying with applicable laws.
4. What is our legal basis for processing your Data?
- Consent, and the performance of a contract: When you sign up for a course/Program, whether directly through our Website, or indirectly via your educational institution, we will need to process your details to provide you with our service.
- Legitimate interests: We may process your Data to ensure that your interactions with our Website or service are optimal. For example, if you encounter bugs or crashes on the Website, we may use your personal information to “debug” the instance, in order to prevent future failures.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
5. Who will we share your Data with?
- If you are a student participating in a course/Program launched by Pupilfirst, some of your personal information (name and email address) may be shared with coaches who administer the said course/Program.
- Your personal details may be shared with third-party organisations we have contracted to provide services to us which include processing Data. For example, to send you the emails you have signed up for. Similarly, we may share data with third parties such as researchers for analytics, research and to gather insights of our student learning outcomes in order to operate and improve our services. Data will be shared to only those organisations/persons who can provide adequate safeguards will be used to ensure your Data is stored and handled securely.
- We reserve the right to disclose your personal information to comply with applicable laws and government or regulatory bodies’ lawful requests for information. We may also have to release information because of a legal requirement on us or pursuant to a court order.
- We may share any information with our other affiliates to help detect and prevent identity theft, fraud and other potentially illegal acts; to prevent abuse of the Website; and to facilitate joint or co-branded services.
6. How do we store your Data, and will your Data be sent overseas?
As you are probably aware, services on the internet are accessible globally, so collection and transmission of personal data is not always confined to one country.
By using this Website or any website we link through to, your Data may be processed in or transferred to other countries, and you agree to your Data being transferred or processed in this way.
The Data collected, directly from you through the Website, shall be stored in the US.
7. How long do we keep your Data for?
We will keep your Data only for as long as it is relevant and useful for the purpose for which it was originally collected. Local data retention policies and applicable privacy laws will typically dictate the length of time Data is retained. Your personal data will be retained in compliance with privacy laws and regulations.
After the end of the data retention period, your Data will be deleted. If your account appears to have not been used for 5 years, we will try and contact you to check whether it is still in use. If we fail to contact you, and / or you do not sign in after our check-in email, we will delete your account and all personally identifiable information.
Be aware that we may still preserve some content that you submitted to the Website, in order to preserve the integrity of related information belonging to other users. For example, the content of your posts on a community forum will be preserved while your identity will be deleted. Please do not post personal information outside your profile page; this will ensure that no trace of your personal information is left behind after account deletion.
8. What are your data protection rights?
- Right to confirmation and access: you have the right to request a copy of the Data that we hold about you.
- Right to correction and erasure: you have a right to correct Data that we hold about you that is inaccurate or incomplete, and you have a right to request the erasure of personal data.
- Right to data portability: you have the right to have the Data we hold about you transferred to another organisation.
- Right to withdraw your consent: you have the right to withdraw your consent at any time
- Right to be forgotten: you have the right to prevent the continued disclosure of your Data
The above rights are not absolute and certain exemptions will apply.
9. How to contact us
In accordance with Information Technology Act, 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Name: Hari Gopal
E-mail address: firstname.lastname@example.org
We use commercially reasonable safeguards to help keep the Data collected through the Website secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, we cannot ensure the security of any Data you transmit on the Website or guarantee that Data on the Website may not be accessed, disclosed, altered, or destroyed.
11. Privacy policies of other websites
1. What are cookies?
A cookie (also known as browser cookie) is a small piece of data (essentially text files) sent from a website and stored on your browser. Cookies allow websites to remember information, such as recognizing you, even when you reload web pages.
When you visit our Website, we may collect information from you automatically through cookies or similar technology. You can learn more about cookies at this website.
We collect a number of cookies from our users for various reasons, including serving you content tailored to your own specifications for improving your overall experience of the Website. Amongst other things, the cookies we use allow users to register to enrol in our Public Courses.
3. What types of cookies do we use?
We use only strictly necessary cookies on our Website as follows:
- Pupilfirst cookies: These are cookies directly managed by our Website and are used for critical functionality like allowing you to sign in to the Website, submit application forms, or upload files.
- Cloudflare cookies: Cloudflare is a third-party service we use to improve Website security and performance. You can learn more about how Cloudflare uses these cookies in this article.
4. How to manage your cookies
You can set your browser not to accept cookies, and this website will instruct you on how to remove cookies from your browser. However, some of our Website features may be severely degraded as a result.