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Privacy Policy
This Privacy Policy applies to all websites and services operated by Pupilfirst Pvt. Ltd., a private limited company with its registered office at 1st Floor, C M Complex, Kalavath Road, Palarivattom, Kochi (Pupilfirst, we, us, or our), including but not limited to all subdomains under the following fully qualified domain names:
- pupilfirst.org
- pupilfirst.school
- gdc.network
By accessing any of our websites (collectively Websites) or using our services, you agree to the terms of this Privacy Policy and our Terms and Conditions and all applicable laws and regulations.
Pupilfirst is committed to respecting and protecting your privacy. This Privacy Policy will explain how Pupilfirst collects, uses and discloses the personal data shared, or communicated by you through our Websites.
You can browse our Websites 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 any of our Websites. You may need to provide us with some of your personal data while using some of the services provided on our Websites, or while registering with us.
What Data do we collect?
We collect personal data (Data) to provide and improve our services. This Data is likely to include:
- Personal Information: Name, Email Address, Address, Mobile Number, Gender, Date of Birth, Photographs, Blood Group, Aadhaar Details, ABC ID,Emergency Contact and social media profiles.
- Educational and Professional Information: Institute and University Details, Semester/Batch, Education Qualifications, Field of Employment, Work Experience, Languages Known.
- Sensitive Personal Data: We collect sensitive personal data only for the provision of specific optional services. This includes data such as your inclusion in the SC/ST/General category, Online Learning Disability, and other details as necessary per legal requirements or service provision.
- Identifiers on third-party user accounts: Discord user ID.
- Technical and Usage Data: IP Address, Cookie IDs, Device Information, Usage Metrics.
- Engagement Data: Interaction with our services, user preferences, feedback, and responses to surveys.
How do we collect your Data?
We collect data from you through various methods to ensure we have the information necessary to provide and improve our services:
-
Direct Interactions: You provide us with data
when you:
- Register for an account or sign up for a course.
- Fill out forms, submit information, or upload documents on our Websites.
- Enter personal and professional details, including your name, address, email, educational background, and employment details.
- Communicate with us directly via emails, phone calls, or other messaging services.
-
Automated Technologies: When you visit and
interact with our Websites, we collect certain data automatically
through:
- Cookies and similar tracking technologies that collect data about your browsing habits, your device, and your interactions with our Websites. For more information, please refer to our Cookie Notice
- IP address tracking and browser data collection to understand how you use our Websites and to enhance your user experience.
-
Third-Party Sources: Occasionally, we receive
data about you from:
- Educational institutions when you sign up for a course that Pupilfirst provides in partnership with these institutions.
- Other platforms and services you may use, which are integrated with our services, such as GitHub, for analysing your developer profile during a course application process.
-
Physical and Online Forms: Data is collected when
you:
- Complete application processes that may require detailed personal and educational information.
- Participate in surveys, feedback forms, and other interactive features of our Websites.
How will we use your Data?
We use the personal data we collect in various ways to deliver and enhance the services we provide:
- Identity Verification and Account Management: We use your information such as your name, email address, and photographs to verify your identity when you sign up for our services or courses, and when you log back into our Websites.
- Service Delivery: We use your data to administer and manage your learning/teaching experience, which includes sending you service messages about your account, responding to your queries, informing you of important course milestones or changes, facilitating internships & hiring, and notifying you of important events related to your students.
- Personalization: We provide personalized content and information to enhance your learning/teaching experience, based on the actions you take while using our services, and your preferences.
- Communication: We contact you about updates, and may send you course-related notifications via various communication means, including email and mobile phone. For some courses, particularly those in partnership with educational institutions, we may, after notifying you of the same, add your phone number to WhatsApp groups to facilitate communication with peers, students, coaches, and course administrators.
- Safety and Emergency Contact: Your contact details such as mobile numbers or emergency contact information are used to ensure your safety and to reach out in case of urgent course-related issues.
- Analysis and Feedback: We use data like your age, gender, employment field, and educational background for internal analysis to improve our courses and services. This also helps us in profiling and understanding our demographic spread.
- Compliance and Legal Obligations: We process your data to comply with legal obligations, respond to legal requests, and protect our rights in legal proceedings.
- Marketing and Promotions: After receiving specific consent, we may use your contact details to send you promotional messages and marketing communications, depending on your preferences and in compliance with applicable laws. Depending on whether you have given specific consent, we may also use your personal information to create these promotional campaigns.
- Technical Support and Development: We collect technical data such as your IP address and device information to troubleshoot issues, enhance system security, and improve overall website performance.
- Fraud Prevention: Information collected is also used to detect and prevent fraudulent activities and ensure the security of your account and our services.
By using our services, you acknowledge that we will process your data in these ways. We are committed to handling your personal information with care and in accordance with all applicable legal standards.
What is our legal basis for processing your Data?
- Consent, and the performance of a contract: When you sign up for a course, whether directly through our Websites, 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, to prevent future failures.
- Legal Obligations: We may disclose your information where we are legally required to do so 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).
Who will we share your Data with?
For course delivery
- If you are a student participating in a course launched by Pupilfirst, some of your personal information (name and email address) may be shared with coaches who administer the said course.
- Some of our courses are offered in partnership with educational institutions as an open-elective or as a minor degree. If you are a student in such a course, Data supplied during the application process and course-related artefacts will be shared with your home institution.
- Some of our courses are offered in partnership with The University of Trans-Disciplinary Health Sciences and Technology (TDU). If you are a student in such a course, Data supplied during the application process and course-related artefacts will be shared with TDU for the purpose of credit-issuance. Please go through TDU's privacy policy to learn more about their use of your data.
- If you have been referred to our course from a third-party organisation through the use of referral links, then Data related to your application and course-related artefacts may be shared with the referring organisation.
For facilitating internships & hiring
- If you give us additional consent, we may also share your course-related information, along with applicable personal information, with our hiring partners to facilitate internships & hiring.
For research & improvement of our services
- 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 to operate and improve our services. Data will be shared to only those organisations/persons who provide adequate safeguards to ensure your Data is stored and handled securely.
As part of a merger or acquisition
- We may transfer, sell or assign any of the information described in this Privacy Policy to third parties on a need to know basis as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.
To prevent fraud, and to comply with the law
- We reserve the right to disclose your personal information to comply with applicable laws and based on lawful requests for information from government or regulatory bodies'. 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 Websites; and to facilitate joint or co-branded services.
- We may disclose your Information to the extent such disclosure is reasonably necessary to enforce our Terms or Privacy Policy and to respond to claims of any other user or third-party. We will not transfer your personal data to third parties (other than as set out in this section of the Privacy Policy) unless we have your permission or are required by law to do so.
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 our Websites 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 our Websites, shall be stored in India.
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.
Regular student accounts
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.
Students of credit-linked courses
If your student account is part of a credit-linked course, then your data will be held for a period of 5 years to comply with local regulations regarding student data record-keeping. Once the credit-issuance process has begun, you will not be able to delete your account during this 5-year period.
Some Data may be preserved for long-term
Be aware that we may still preserve some content that you submitted to our Websites, 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.
What are your data protection rights?
- Right to Access Information: You have the right to access details about your Data that is being processed, with whom your Data has been shared, and other related information.
- Right to Correction and Erasure: You can request corrections, updates, or completion of your Data if it is inaccurate or incomplete. You also have the right to erase your personal data under certain conditions.
- Right of Grievance Redressal: You have the right to lodge complaints regarding the processing of your Data or the exercise of your rights.
- Right to Nominate: You can nominate individuals to exercise your data rights on your behalf, in the event of death or incapacity.
- Right to Withdraw Consent: You can withdraw your consent for data collection, processing and storage at any time.
The above rights are not absolute and certain exemptions will apply.
9. How to contact us
If you wish to exercise your data protection rights, or have doubts about this Privacy Policy, please contact us at support@pupilfirst.org.
In accordance with the 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: hari@pupilfirst.org
Disclaimer
We are committed to making sure your Data is secure. To prevent unauthorized access or disclosure, we have technical and organisational measures to safeguard and secure your Data. All our personnel and third parties that we engage to process your Data are obliged to respect your data's confidentiality. Due to the existing environment, we, however, cannot ensure that your Data will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we use industry standard practices to protect your privacy, no method of transmission over the internet, or method of electronic storage, is one hundred percent secure. If you believe your Data has been compromised, please contact us at the details set forth in the How to Contact Us section in this Privacy Policy. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
We use commercially reasonable safeguards to help keep the Data collected through the Websites 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 Websites or guarantee that Data on the Websites may not be accessed, disclosed, altered, or destroyed.
Privacy policies of other websites
Our Websites may contain links to other websites. Our Privacy Policy applies only to our Websites. If you click on a link to another website, you shall be bound by the privacy policy of that website.
Changes to our Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make substantial changes to this Policy that we at our sole discretion determine, which may affect your privacy, and you are a registered user of this Website, then we will endeavour to notify you of the same through email. Irrespective of whether we notify you via email or not, the updated Privacy Policy will always be made available to you on this Website.
Your continued use of our services and this Website shall be deemed your acceptance of the updated Privacy Policy.
This Privacy Policy was last updated on May 24, 2024.