Introduction

Grey Sim Learnings Foundation, together with affiliates (“GSLF”, “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you through our online platforms such as website and this mobile application. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data. This privacy policy is drafted in accordance with applicable data protection laws, including without limitation Digital Data Protection Act 2023.

Unless we link to a separate policy or state otherwise, this Privacy Policy applies when you visit or use the GSLF website, mobile applications.  GSLF, the entity that will make the decisions about how your data is used.

By using the Services, you agree to the terms of this Privacy Policy and the Terms of Use. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services. 

1. Legal Basis for Processing Data

We process your data based on the following:

• Your consent for processing your data as mentioned in the Section below and for the purposes mentioned in Section 4 below. It is hereby clarified that we may obtain your consent to collect and use certain types of personal data when we are required to do so by law. 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. Further, by using this app/ 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 Use. 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;

• Our legitimate interests, i.e. registering and administering accounts on our Services to provide you access to all content, updates, and to facilitate the efficient running and operation of our business;
• Processing to comply with legal and regulatory obligations;
• Processing necessary to protect vital interest of a user 

2.  Data Collected by Us

We collect certain data from you directly, like the information you enter yourself. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.

2.1 Data You Provide to Us
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.
When you create an account and/or use the Services, including through a third-party platform, we collect the following data:

The data listed above is stored by us and associated with your account.

• Account and Related Data – In order to use certain features you need to create a user account. When you create or update your account, or provide your information via any other forms or means, we collect and store the data you provide, like your name, email address, password, city, age, parents  name and occupation, residential and contact details, date of birth, educational qualification, resume, gender, socio-economic status, industry where you wish to work, job title, company name, phone number (“Account Data”). If you are a registered user, we may also have access to your login credentials. 

If you are logging in as an Employer we will need to have the detailed information of the company like PAN, GST number and other information as required to fill up your profile.

Other legal basis for our processing of may include, as permitted by law, , for employment, for reasons of substantial public interest, or as necessary for the establishment, exercise or defence of legal claims. If you voluntarily share with us you consent that we may use such data in accordance with applicable law and this policy.

• Other Identification Data – In order to provide our Services, we may request you to provide certain other identification details such as Permanent Account Number, Aadhar Card number, or such similar identification details.
• Profile Data – Your Profile Data will be viewable by other registered users  in the app.
• Program Data – When you register , we collect certain data including without limitation which assessment you have done, which LMS courses you have started and completed; 
• To clarify, GSLF and third-party service providers may also collect certain information from you in conjunction assessments related to the app. For example, as part of a exam for a course, GSLF may collect certain personally identifiable data from you in order to (a) verify or authenticate your identity a photograph or a recording of you (e.g., using a webcam) or information included on a photo identification card or document, or (b) monitor your performance during an exam to confirm that you are abiding by the applicable test rules or requirements (e.g., confirming that you are not using prohibited resources.

• Data About Your Accounts on Other Services -We may obtain certain information through your social media or other online accounts if they are connected to your GSLF account. If you log in to GSLF via LinkedIn or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, account ID number, login email address, etc.

Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.

• Communications and Support -If you contact us for support or to report a problem or concern, we collect and store your contact information, messages,. We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy. 
• Third Parties-We are also working closely with third parties (including, for example, assessment portal) and may receive information about you from such sources.The third-party using  your participation in the programs may use your email id and other data like contact details, aadhar card number etc. 
• Data Provided through Inquiries -While you inquire about our services, you may provide, or would be requested to provide personal data (stated in the inquiry form, or otherwise) such as name, address, phone number, country, subject of inquiry, personal details (name on the card, billing address, recordings of calls with students and users showing interest in our programs, information about your interactions with customer service and maintenance interactions with us. 
• Legal Requirements – Information needed in order to comply with any procedures, laws, and regulations .

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3. How We Get Data About You

We use tools like analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

3.1 Analytics
We use the 3rd-party browser and mobile analytics services like Google Analytics, YouTube and Drift on the Services. These services use Data Collection Tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data. We use this data to improve the Services, better understand how the Services perform on different devices and provide information that may be of interest to you.

3.2 Online Advertising
We may use third-party advertising services like Facebook, Google’s ad services, and other ad networks and ad servers to deliver advertising about our Services on other websites and applications you use. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.

Depending on the types of advertising services we may use, they may place cookies or other tracking technologies on your computer, phone, or other devices to collect data about your use of our Services, and may access those tracking technologies in order to serve these tailored advertisements to you. 

4. What We Use Your Data For, and How Long We Store it

4.1 How we use your data
We use your data to do things like communicate with you, troubleshoot issues, provide our Services, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, and as required by law or necessary for safety and integrity.

We use the data we collect through your use of the Services to:

• Provide and administer the Services, including to display customized content and facilitate communication with other registered users for interview scheduling , grievances etc.
• Communicate with you about your account by:
  • Sending you administrative messages and information including, notifications about changes to our Service, and updates to our agreements;
  • Sending you information and in-app messages about your progress in LMS , promotions, newsletters, and other available courses 
  • Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of the mobile app);
  • Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
  • Solicit feedback from users;
  • Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;
  • Identify unique users across devices;
  • Improve our Services and develop new products, services, and features;
  • Analyze trends and traffic, track purchases, and track usage data;
  • Advertise the Services on third-party websites and applications;
  • As required or permitted by law; or
  • As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.

It is hereby clarified that irrespective of the fact that you have registered yourself under DND or DNC or NCPR service, or any such similar service, you still authorize us to give you a call from us. GSLF may send email notices or contact you via SMS, phone call or any other medium to communicate about its Services. We may, from time to time, use business partners, operational service providers and subcontractors to operate and provide our services to you and to comply with legal and regulatory requirements. As necessary under this Privacy Policy, our service providers are required to protect the information we provide them in a manner that is consistent with this Privacy Policy. Although we exercise care in selecting our service providers and require them to protect information as mentioned above, they are independent third parties and we may not have control on their privacy practices.

4.2 Criterion For Determining Data Retention Period
It is for reference to say that we would be keeping your data for a minimum period of 3 years. However, we will not retain your data for longer than necessary, taking into account the following:

• The purpose(s) and use of your data in the future .
• Whether we have any legal obligation to continue processing your data (such as any record-keeping obligations imposed by any applicable law);
• Whether there is any relevant agreed industry practice on how long such data should be retained;
• The levels of risk and liability involved for us to continue holding the data;
• The amount of difficulty we may face to ensure the data can be kept updated and accurate; and

5. Who We Share Your Data With

We share certain data about you with our business partners(employers) , analytics and data enrichment providers and  advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring.

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

• With our Educational Partners: We may share the information that we collect from you with the particular Educational Partners (e.g., assessment portal) that developed assessment portal that  you are using. 
• Employers: We may share your data and grades, evaluations or progress in the program with your employer. This information may be shared at any time during the program or afterwards.
• With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, 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.
• To Power Social Media Features: The social media features in the Services (like the Facebook Share) 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.
• 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.
• For Security and Legal Compliance: We may disclose your data to third have a good faith that the disclosure is:
  • Permitted or required by law;
  • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
  • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
  • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
  • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
  • Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of GSLF, our users, employees, members of the public, or our Services.
  • 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.

• During a Change in Control: If GSLF 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).

6. Your Rights

You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data such as to restrict/object our processing of your data, to erase all data we have stored about you.

6.1 Accessing, Updating, Deleting Your Personal Data
You can access and update your personal data that GSLF collects and maintains as follows:

• To update data you provide directly, log into your account and update your account at any time.
• To terminate your account drop an email to admin@gslfoundation.org
• Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we post deletion, we may retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

6.2 Revocation of Consent

We recognise that the processing of your data may be based on your consent. In case you wish to withdraw such consent given to us for the processing of your data as identified above, please e-mail us at admin@gslfoundation.org. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and may need to verify your identity before implementing your request.
Further, please note that such revocation of consent shall be prospective in nature, and shall not affect the lawfulness of any data processed based on your consent given prior to revocation.

7. Security

We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.

We adhere to the best practices and standards for maintaining the confidentiality, integrity, and availability of your data. GSLF  takes appropriate security measures to transfer your data to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store in the cloud. These measures vary based on the type and sensitivity of the data. 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.

8. Jurisdiction-Specific Rules

GSLF in order to provide the Services to you, will hold  your data in India and process it there. By visiting or using our Services, you consent to the storage of your data on servers located in India. If you are using the Services from outside India, you consent to the transfer, storage, and processing of your data in and to India or other countries. 

9. Updates & Contact Info

When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email with any questions, concerns, or disputes.

9.1 Modifications to This Privacy Policy
From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.


9.2 Questions
If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact us at admin@gslfoundation.org.

10. Governing Law

This Privacy Policy forms part of our Terms of Use and is governed in accordance with the laws in India.