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Legal
Privacy Policy
This Privacy Policy governs how Virtued Academy International collects, uses, maintains, and discloses information of its users. By using the Platform, you consent to the practices described herein.
⚠️ Important — Please Read Before Using the Platform
By accessing and using the Platform, providing Your Personal Information, or by otherwise signalling Your agreement when the option is presented to You,
You expressly and irrevocably consent to the collection, use, and disclosure of information described in this Policy and Terms of Use. We disclaim all liabilities arising therefrom. If You do not agree, You must leave the Platform immediately. If any information You provide violates the terms of this Policy, we reserve the right to delete such information and revoke Your access without any liability to You.
📋 Table of Contents
11
Grievances
1
Personal Information
"Personal Information" shall mean the information which identifies a Learner i.e., first and last name, identification number, email address, age, gender, location, photograph and/or phone number provided at the time of registration or at any time thereafter on the Platform.
"Sensitive Personal Information" shall include (i) passwords and financial data (except the truncated last four digits of credit/debit card), (ii) health data, (iii) official identifiers (such as biometric data, Aadhaar number, social security number, driver's license, passport, etc.), (iv) information about sexual life, sexual identifier, race, ethnicity, political or religious belief or affiliation, (v) account details and passwords, or (vi) other data/information categorised as 'sensitive personal data' or 'special categories of data' under applicable Data Protection Laws including the IT (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, GDPR, and/or CCPA ("Data Protection Laws").
Usage of the term 'Personal Information' shall include 'Sensitive Personal Information' as may be applicable to the context of its usage.
ℹ️ Our Commitment
We do not ask You for Personal Information unless we truly need it. We do not share Your Personal Information with anyone except with our certification/training partners, and to comply with applicable laws, develop our products and services, or protect our rights.
2
Information We Collect
We may collect both personal and non-personal identifiable information from You in a variety of ways, including when You visit our Platform, register on the Platform, and in connection with other activities, services, features, or resources we make available.
a. Personal Identifiable Information
We may collect personal identifiable information such as Your name and email address to enable Your access to the Platform and services/products offered therein. We will collect personal identifiable information from You only if such information is voluntarily submitted by You. You can always refuse; however, it may prevent You from accessing services or products on the Platform.
b. Non-Personal Identifiable Information
When You interact with our Platform, we may collect non-personal identifiable information such as the browser name, language preference, referring site, date and time of each user request, operating system, internet service providers utilised, and other similar information.
c. Cookies
To enhance User experience, our Platform may use cookies. A cookie is a string of information that a website stores on a visitor's computer for record-keeping purposes. You may choose to refuse cookies; however, some parts of the Platform may not function properly if you do so.
3
How We Use and Share the Information Collected
We may collect and use Your Personal Information for the following purposes:
a. To Provide Access to the Platform
We use Your information to allow You to access the Platform and the services/products offered therein, including to provide customer service, fulfil purchases, verify User information, and resolve glitches. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between You and us.
b. To Improve Our Platform and Maintain Safety
We use Your information to improve and customise the Platform and to prevent, detect, investigate, and take measures against criminal activity, fraud, misuse of or damage to our Platform or network, and other threats and violations to our rights and property, or the safety of our Users or others.
c. To Communicate With You or Market Our Services
We and our training and certification partners may use the email address submitted by You to communicate about Your orders, our offers, new products, services or to receive feedback. If You wish to unsubscribe from receiving future emails, please write to us at the contact information provided below.
🔒 No Sale of Data
We do not use Personal Information for making any automated decisions affecting or creating profiles other than what is described in this Policy. We do not sell, trade, or otherwise exploit Your personal identifiable information to others. We may share generic aggregated demographic information not linked to any personal identifiable information with our business partners and trusted affiliates.
4
Your Choices
Limit the Information You Provide: You always have the option to choose the information You provide to us, including the option to update or delete Your information. However, lack of certain information may prevent You from accessing the Platform or any of its features, in part or in full.
Limit Communications from Us: You will have the option to choose what kind of communication You would like to receive from us. However, certain communications required for legal or security purposes may not be able to be limited.
Reject Cookies: You may reject or remove cookies from Your web browser. However, some services/products offered on the Platform may not function or be available to You when cookies are rejected, removed, or disabled.
5
Your Rights
In general, all Learners have the rights specified herein. However, depending on where you are situated, you may have certain specific rights accorded by the laws of the country you are situated in. Please refer to the Country Specific Additional Rights below.
You may exercise any of these rights by using the options provided within the Platform upon your login, or by writing to us at the address noted in the 'Grievances' section below.
Right to Confirmation and Access: You have the right to get confirmation and access to your Personal Information that is with us along with other supporting information.
Right to Correction: You have the right to ask us to rectify your Personal Information that you think is inaccurate, incomplete, or out-of-date.
Right to be Forgotten: You have the right to restrict or prevent the continuing disclosure of your Personal Information under certain circumstances.
Right to Erasure: You have the right to request erasure of your Personal Information from our Platform. Please note that such erasure will remove all your Personal Information (except as specifically stated in this Policy) and may result in permanent deletion of your account, which is not retrievable.
You are entitled to exercise these rights only with respect to your own information, and not that of other Learners. We may request additional information to verify your identity before fulfilling any such requests, as required by applicable Data Protection Laws.
6
Protection of Your Information
We take all measures reasonably necessary to protect against the unauthorised access, use, alteration, or destruction of Personal Information or such other data on the Platform. Our disclosure of any such information is limited to:
a. Internal Disclosure
Our employees, contractors, and affiliated organisations that (i) need to know that information in order to process it on our behalf or to provide services available on our Platform, and (ii) that have agreed not to disclose it to others.
b. Legal Disclosure
In response to a court order or other governmental request. We reserve the right to disclose such information where we believe in good faith that such disclosure is necessary to: (i) comply with applicable laws, regulations, court orders, and law enforcement agencies' requests; (ii) protect and defend a third party's or our rights and property, or the safety of our users, employees, or others; or (iii) prevent, detect, investigate, and take measures against criminal activity, fraud, and misuse or unauthorised use of our Platform and/or to enforce our Terms of Use or other agreements or policies. To the extent permitted by law, we will attempt to give You prior notice before disclosing Your information in response to such a request.
7
Third Party Websites
You may find links to the websites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. The content or links that appear on these sites are not controlled by us in any manner and we are not responsible for the practices employed by such websites.
⚠️ No Liability for Third-Party Sites
These websites/links, including their content, may be constantly changing and may have their own terms of use and privacy policies. Browsing and interaction on any other website, including websites which have a link to our Platform, is subject to that website's own terms and policies. We expressly disclaim any and all liability arising from your use of any third-party website.
8
Cross-Border Data Transfer
Your information including any Personal Information is stored, processed, and transferred in and to the Amazon Web Service (AWS) servers and databases located in India. We may also store, process, and transfer information in and to servers in other countries depending on the location of our affiliates and service providers.
Please note that these countries may have differing (and potentially less stringent) privacy laws. If you use our Platform from outside India, including in the USA, EU, EEA, and UK, your information may be transferred to, stored, and processed in India. By accessing our Platform or otherwise giving us information, you expressly and irrevocably consent to the transfer of information to India and other countries outside your country of residence.
9
Duration for Which Your Information is Stored
We will retain Your information for as long as it is required for us to retain for the purposes stated hereinabove, including for the purpose of complying with legal obligations or business compliances.
We may not be able to delete all communications or photos, files, or other documents publicly made available by you on the Platform (for example: comments, feedback, etc.); however, we shall anonymise your Personal Information in such a way that you can no longer be identified as an individual in association with such information. We will never disclose aggregated or de-identified information in a manner that could identify you as an individual.
If you wish to access, modify, or delete any or all information stored about you, you may do so by using the options provided within the Platform, or by writing to us at the email address specified in the 'Grievances' section below.
10
Modification to Privacy Policy
We may modify, revise, or change our Policy from time to time; when we do, we will revise the 'updated date' at the beginning of this page. We encourage You to check our Platform frequently to see recent changes.
Your continued use of the Platform following the posting of any changes to this Policy constitutes your acceptance of those changes. Unless stated otherwise, our current Policy applies to all information that we have about You. We reserve the right, at our sole discretion, to update this Policy at any time without prior notice to you, and the updated Policy shall take effect immediately upon posting.
11
Grievances
If you have any questions about this Policy, wish to exercise your rights, have concerns about privacy, or have any grievances, please write to us with a thorough description:
Virtued Academy International — Privacy Officer
Email: contact@virtued.in | Phone: +91 76519 39423
128 City Road, London EC1V 2NX | www.virtued.in
We will address your grievances to the extent required by applicable law.
🌍 Country Specific Additional Rights
Jurisdiction-Based Privacy Rights
Depending on your country of residence, you may have additional rights under local Data Protection Laws.
🇮🇳
Section A — Terms Applicable if You Are an Indian Resident
If you are located in India, you may have the following rights under the Personal Data Protection Bill (PDPB) and applicable Indian law. All requests can be made by using the option provided within the Platform upon your login, or by writing to us as stated in the "Grievances" section above.
Right to Confirmation and Access: You have the right to get confirmation and access to your Personal Information that is with us along with other supporting information.
Right to Correction: You have the right to ask us to rectify your Personal Information that you think is inaccurate, incomplete, or out-of-date.
Right to Data Portability: You have the right to ask that we transfer the Personal Information you gave us to another organisation, or to you, under certain circumstances.
Right to be Forgotten: You have the right to restrict or prevent the continuing disclosure of your Personal Information under certain circumstances.
Right to Erasure: You have the right to request erasure of your Personal Information from our Platform. Please note that such erasure will remove all your Personal Information (except as specifically stated in this Policy) and may result in permanent, non-retrievable deletion of your account.
🇬🇧 🇪🇺
Section B — Terms Applicable if You Are a UK / EU / EEA Resident (GDPR)
If you are located in the United Kingdom (UK) or European Union (EU) or European Economic Area (EEA), you have the following rights under the UK and EU General Data Protection Regulation (GDPR). All requests should be sent to the address noted in the "Grievances" section above.
Right to Access: You have the right to receive confirmation as to whether or not Personal Information concerning you is being processed, and where that is the case, access to the Personal Information.
Right to Rectification: You have the right to request that inaccurate or incomplete Personal Information be corrected or completed.
Right to Erasure: In some cases, you have a legal right to request that we erase your Personal Information.
Right to Object to Processing: You have the right to object to our processing of your Personal Information under certain conditions.
Right to Restrict Processing: You have the right to request that we restrict the processing of your Personal Information under certain conditions.
Right to Data Portability: You have the right to request that we transfer your data to another organisation or directly to you under certain conditions.
Right to Lodge a Complaint: If you believe we have not processed your Personal Information in accordance with the GDPR, you have the right to make a complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available at:
https://edpb.europa.eu/about-edpb/board/members_en.
Right Against Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.
We collect and process Personal Information about you only where we have a legal basis to do so. The specific legal rationale applied will depend on the type of Personal Information collected and the context in which it is processed.
🇺🇸
Section C — Terms Applicable if You Are a California State Resident (CCPA)
If you are a California state resident, then you have the following rights to the extent, and in the manner, set out in the CCPA:
The right to access the Personal Information that we hold on you.
The right to know what Personal Information we intend on collecting from you before the point of collection.
The right to opt in or out of marketing, analytics, and other similar activities.
The right to equal services without discrimination.
The right to request deletion of Personal Information.
CCPA Notice at Collection — Categories of Personal Information Collected:
a. Identifiers
We may collect your name, email address, mobile number, username, unique personal identifier, and Internet Protocol (IP) address.
b. California Customer Records Statute
We may collect your name, email address, username, unique personal identifier, and gender as described in the California Customer Records statute.
c. Internet or Electronic Network Activity
We collect cookies and automatically receive information from your browser and device, including date and time of visit, location, IP address, domain server, browser type, access time, and data about pages visited.
d. Geolocation Data
We may collect your IP address for geolocation purposes.
e. Audio, Electronic, and Visual Information
We may collect your profile picture or other audio or visual information uploaded as content to the Platform.
f. Inferences
We may make inferences based upon the Personal Information collected (such as likelihood of retention or attrition).
CCPA Data Practices During the Last 12 Months:
We have collected, used, and disclosed for business purposes the following categories: Identifiers; Characteristics of Personal Information described in the California Customer Records statute; Internet or other electronic network activity information; Geolocation data; Commercial information; Audio, electronic, visual, and similar information; and Inferences. We have not sold any categories of Personal Information during the preceding 12 months.
Consumer Rights and Requests Under the CCPA:
The CCPA gives consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, and sell, and (2) delete certain Personal Information that we have collected or maintained. You may submit requests by email to contact@virtued.in.
🔒 CCPA Non-Discrimination
You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against Users/consumers for exercising their rights under the CCPA.