GlobalGrads (herein referred to as “GlobalGrads”, “we”. “us” or “Our”) owns, operates, and maintain the website https://www.GlobalGradsabroad.com (“Website”). GlobalGrads offers curated and specially designed higher education programs (“Programs”) through its website. This Website provides information about the Programs or the universities and assists students (“User”) by providing information on the admission process, details of the Program, university of their interest. This Website also acquaints the User with all the available learning options. In order to deliver the Programs in an efficient manner and to make available the information about the Programs, GlobalGrads collects certain information regarding the User. GlobalGrads values the trust placed by Users and therefore, we follow the highest standards to protect your Personal Information.

This Privacy Policy (“Privacy Policy”) describes how we collect, use, update, delete and share information about our users (hereinafter referred to as “User”, “you” or “your”) through our Website. Please review our Terms of Use and Privacy Policy (collectively referred to as the “Terms”) that govern the use of the Website and the Programs. This Privacy Policy shall form a part of the Terms by way of reference. All capitalised terms not defined in this Privacy Policy have their respective meanings set forth in the Terms of Use. This Privacy Policy applies only to the part of the Website provided by GlobalGrads, and we are not responsible for the practices of persons, companies, institutions or websites that GlobalGrads does not control, manage or employ.

User shall mean and include any person/persons, who visits, uses, deals with and/or transacts through the Website and includes a guest user and browser. In circumstances where the User is less than 18 years of age, consent from the legal guardian shall be required and it is advised that this policy be read in the presence of the legal guardian.

We take care and perform due diligence to ensure privacy aspects of each and every individual who interacts with our Website, by design and by default, in alignment with all applicable laws and regulations.

Please understand that submitting any Personally Identifiable Information (defined below) to us, you consent and agree that we may collect, use, update, disclose and retain your information (including but not limited to your Personally Identifiable Information) in accordance with this Privacy Policy and our Terms of Use, and as permitted or required by law. GlobalGrads reserves the right to share the information collected hereunder with its own affiliates. In the event of sale or transfer of all or a portion of our business assets, consumer information may be one of the business assets that are transferred as part of the transaction. If you do not agree with these Terms, then please do not provide any Personally Identifiable Information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personally Identifiable Information, we may not be able to provide you with the services that can be offered on our Website.

This Policy has been drafted in accordance with the applicable data protection laws, rules and regulations but not limited to General Data Protection Regulation, 2018 (“GDPR”), the Information Technology Act, 2000 (“IT Act”) and the Information Technology (Reasonable Security Practices and Procedures And Sensitive Personal Data or Information) Rules, 2011 (“IT Rules”), collectively referred to as “Data Protection Laws”

1. INFORMATION COVERED BY THIS PRIVACY POLICY

Some of our Website’s functionality may be used without revealing any personal information, though for features or services related to the Programs, personal information is required. If you do not use these specific features or services on the Website, then the only information we collect will be “Non-Personal Information” (i.e., information that cannot be used to identify you). Non-Personal Information includes information like the web pages that you have viewed. In order to access certain features and benefits on our Website, you may need to submit “Personally Identifiable Information” (i.e., information that can be used to identify you). Personally Identifiable Information can include, but not be limited to, information such as your name, email address, contact number (cellular and landline), educational qualification(s), and post-qualification or work experience among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to GlobalGrads. Inaccurate information may affect your ability to use the Website, the information you receive when using the Website, and our ability to contact you. For example, your email address and contact number should be kept valid because these are the primary channels through which we communicate with you.

2. INFORMATION COLLECTION

NON-PERSONAL INFORMATION

When you come to our Website, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages of our Website were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs through which you connected to our Website or with our Website. Collecting such information may involve logging the IP address, operating system and browser software used by each User of the Website. Although such information may not be considered Personally Identifiable Information, based on local laws, we may be able to determine a user’s Internet Service Provider and the geographic location of his or her point of connectivity from an IP address. We collect Non-Personally Identifiable Information from the Website visitors to track the total number of visitors on the Website in aggregate form and to identify the type of Internet web browser (e.g., Internet Explorer®) and operating system (e.g., Windows®) used by them. This information allows us to continuously improve our Website and services.

PERSONALLY IDENTIFIABLE INFORMATION

Personal Identifiable Information, you share with GlobalGrads shall have a meaning derived from the definition of ‘Personal Information’ or ‘Personal Data’ as per respective Data Protection Laws applicable to you.

The information provided by you is used only in accordance with purpose described in the Policy. We collect through our Website, or through third-party Websites being used by us, the information that you provide to us when you sign up for information updates or Programs, participate in our public forums, avail our chat room services, send us emails, call us, participate in online or offline events, and/or receive other services on or through our Website or through any of GlobalGrads’s or its Educational Partners’ offline activities. This information may include, among other things, your name, postal address, email address, contact number, social security or tax identification numbers, login credentials (in the case of registered users), educational qualification(s), salary information, working goals, post-qualification experience, and photographs. We collect demographic information such as your gender, socio-economic status, and other similar personal information. In the case of scholarships, refunds or referrals, we will collect your bank account information. Other than this, we do not collect any of your financial information, and all payments are processed by third-party payment gateway providers.

We collect this information in a number of ways, including when you enter it while using our Website, Website, interact with our customer support, or participate in our surveys, or marketing promotions.

Should you need any financial assistance, GlobalGrads may recommend certain third-party credit facility providers. Should you opt to sign up with such credit facility providers, any information you provide to them will be governed by their terms of use and policies, as you would be their direct customer. Please note, GlobalGrads does not control, manage, or regulate such third-party providers.

OTHER INFORMATION

Other forms of information that we may collect from you or about you are as follows:

• Information about your interactions with customer service and maintenance interactions with us.
• User-generated content you upload or post to public forums through the Website.
• Information needed in order to comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
• Recordings of calls with those of you who show interest in our programs.
• Any other information you choose to directly provide to us in connection with your use of the Website and Programs.
   

THIRD-PARTY SERVICE PROVIDERS

We may receive your information when you access or log in to a third-party site, e.g., LinkedIn, Facebook, WhatsApp from our Website or when you respond to our Ads on such third-party Websites. This may include the text and/or images of your Personally Identifiable Information available from the third-party site. Please be aware that the information we obtain from such third-party Websites is often dependent on their privacy policies and/or on your settings regarding what information you have consented to share with them.

We enter into arrangements with third parties to serve Ads on our behalf across the internet, social networking sites and blogs. They may collect or store information about your visits to our Website and your interaction with our products and services. They may also use information about your visits to this Website and to other websites to target advertisements for goods and services or for any other purpose. This information is collected using a pixel tag, which is an industry standard technology used by most major websites. Such third parties are not permitted by GlobalGrads to sell or share your Personally Identifiable Information as part of this process. If such third parties sell or share the Personally Identifiable Information as part of the process, GlobalGrads’s liability shall be limited to providing you with reasonable assistance in any action you may choose to take against such third parties, at your sole cost and expense.

We have third-party sales and marketing affiliates who may collect your information through one of the various channels owned by them and share this information with us, based on your interest in our Programs. For example, an affiliate may hold an event and share the details of the attendees with GlobalGrads.

INFORMATION WE RECEIVE FROM OTHER SOURCES

We may receive information about you if you use any of the other Websites we operate or the other services we provide. In this case, the data may be shared internally and combined with the data collected on the Website. We are also working closely with third parties (including, for example, Educational Partners, scholarship providers, marketing partners, sales affiliates, subcontractors in technical/advertising networks, analytics providers, and search information providers) and may receive information about you from such sources. We may also receive your information from your employers, educational institution, or scholarship providers, where your Program is partly or fully sponsored by such a third-party. The third-party sponsoring your participation in the Programs may provide us with your information, subject to our agreement with them and, therefore, the third-party sponsor may be the controller with respect to such data. In cases where you have been referred under any referral scheme, we will receive your information from the referrer.

3. USE OF INFORMATION

We may use the information we collect with your consent to register you on our Website, to provide you with information relating to our Program and/or other GlobalGrads Services, offers from time to time in connection with GlobalGrads or its subsidiary and affiliated companies, to respond to your questions or interest shown in our Programs, and to send you updates about the Programs, other GlobalGrads events, Website maintenance or new services provided by GlobalGrads, among other things, through itself or through third parties, via email, SMS, phone call or any other medium.

Irrespective of the fact if also you have registered yourself under DND or DNC or NCPR service, you still authorize us to give you a call from us or any third party for the above-mentioned purposes till 365 days of your registration with us. GlobalGrads may send email notices or contact you via SMS, phone call or any other medium to communicate about its Services, Website and other information. We may, from time to time, use business partners, operational service providers and subcontractors ("Service Providers") to operate and provide our services to Users 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 over their privacy practices.

We may use your Personally Identifiable Information in order to provide such services to you and for quality control purposes, and we may also archive this information and/or use it for future communications with you. For example, GlobalGrads may make available to you chat room services that allow you to communicate with GlobalGrads’s staff members and we may use and share your Personally Identifiable Information to provide these services to you. In another example, GlobalGrads’s staff members may create groups on WhatsApp (or similar service providers) with other students and make you a member of such a group. These groups may be used to provide services in conjunction with the Programs, including, but not limited to, updates related to the Programs, details of potential employers, etc. Please be aware that the information disclosed on a third-party service provider’s Website will be dependent and subject to such third-party’s privacy policies and/or on your settings regarding what information you have consented to share with them. GlobalGrads and/or its associates shall have no liability in this regard whatsoever.

GlobalGrads may use and share your information to improve its services and offerings. For example, we, through our service providers (like auditors or surveyors), may approach you to understand the impact of our Programs on your careers. For this purpose, we may connect with you via a phone call, email you questionnaires, or request you to attend workshops.

To the extent any Personally Identifiable Information collected by us contains images of you, you grant GlobalGrads a limited, non-exclusive right to use, reproduce, distribute, or prepare derivative works of or publicly display such images and/or your likeness in relation to the Program or for marketing purposes. We may use your photograph along with employer information, testimonials, transition information, designation change, etc., for Ads/and or social media posts to highlight our learners’ achievements.

We use Non-Personal Information in aggregate form to build higher-quality, more useful services by performing statistical analysis of the collective characteristics and behaviour of our Users and by measuring demographics and interests regarding specific areas of our Website.

If the processing of your Personal Identifiable Information is subject to the EU General Data Protection Regulations, we use your Personal Identifiable Information where the processing is in our legitimate interests.

4. SHARING YOUR INFORMATION

In addition to the examples provided above, we will share your information in the following manner:

EDUCATIONAL PARTNERS

We may share the information that we collect from you with the particular Educational Partner (e.g., a university or a company) that developed or offered the Program you are taking; the instructor(s) who taught, managed or otherwise oversaw the Program; external graders who will be assessing your performance; or mentors who will be supporting students. For example, if you are taking a Program through a university, we may share Personally Identifiable Information about you and your performance with the university to report on your progress in the Program and to enable them to issue a certificate to you on completion of the Program. Information shared with our Educational Partners will be subject to the privacy policies and procedures of such partners. Also, we may archive this information and/or use it for future communications with you.

EMPLOYERS, SPONSORS AND SCHOLARSHIP PROVIDERS

If you are taking a Program that is sponsored or paid for by your employer or a sponsor, or if you have availed a scholarship from a third-party scholarship provider, we may share your Personally Identifiable Information and grades, evaluations or progress in the Program with your employer/sponsor/scholarship provider. This information may be shared at any time during the Program or afterwards.

SERVICE PROVIDERS

We provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf strictly on confidential terms. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, test proctoring, couriers, mentoring, recruitment consulting, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, credit facilities, payment processing and legal services. Moreover, in certain circumstances, we may share certain Personally Identifiable Information and materials with third parties including, but not limited to, service providers such as Facebook or WhatsApp in order to provide you services that you have requested or services that GlobalGrads provides in conjunction with the Programs. Also, we use certain third-party Websites to collect your information (such as Typeform or Google Forms), as a consequence of which, your information may be stored on their servers.

ALUMNI PORTAL AND NETWORKING SERVICES

We may collaborate with certain third-party service providers to arrange and provide networking activities to previous, current, or potential students of GlobalGrads. For this purpose, GlobalGrads may share certain basic information such as your name, email address and cohort details with such third-party service providers in order to enable them to invite you to connect. Should you agree to sign up to their services, please note that any information you provide will be governed by their policies. In certain cases, in order to facilitate communication between students, we may share your information with other students on chat forums such as WhatsApp and Facebook.

GOVERNMENT AND REGULATORY DISCLOSURE

GlobalGrads may share your Information with various government authorities in response to court orders or other legal processes to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us. We may also share your information when we believe it is appropriate to investigate, prevent or take appropriate action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of GlobalGrads, the Website, our users, customers, or others; and in connection with our Terms and other agreements.

ASSOCIATES AND BUSINESS TRANSFERS

GlobalGrads may share your Personally Identifiable Information with any Associate. The term “Associate” includes, with respect to any person, any entity that is controlled by such person, or any entity that controls such person, or any entity that is under common control with such person, whether directly or indirectly, or, in the case of a natural person, any Relative (as such a term is defined in the Companies Act, 1956, and Companies Act, 2013, to the extent applicable) of such a person.

GlobalGrads may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganisation of all or substantially all of the equity, business or assets of GlobalGrads to which your Personally Identifiable Information relates.

BUSINESS PARTNERS

GlobalGrads may share information that can be used to directly contact you with third-party business partners, such as companies that may be offering products or services or other opportunities that may be of interest to you.

5. PUBLIC DISCLOSURE OF INFORMATION

Any Personally Identifiable Information that is voluntarily displayed by you on the Website may be used by third parties for unsolicited purposes. Please note that GlobalGrads shall not be liable for such unsolicited use by third parties of your Personally Identifiable Information that has been voluntarily displayed by you.

6. AGGREGATED DATA

"Aggregated Data" means records that have been stripped of Personally Identifying Information and that have been manipulated or combined to provide generalised, anonymous information. Your identity and personal information are not available in Aggregated Data. We may combine your personal information on an anonymous basis with other information to generate Aggregated Data for internal and commercial use, and for sharing with affiliates, subsidiaries and business partners for planning and marketing purposes.

7. PROTECTION OF INFORMATION

CONFIDENTIALITY AND SECURITY

GlobalGrads takes all reasonable precautions to protect your Personally Identifiable Information both online and offline, in order to avoid any unauthorised access or breach.

NOTIFICATION OF CHANGES

We may update this Privacy Policy at any time, and it will be posted on this Website as and when it is updated, so that you are always aware of what information we collect, how we use it, and the circumstances under which we may disclose it. Unless stated otherwise, our current privacy policy applies to all information that GlobalGrads has about You and Your account, even if it was collected in the past.

YOUR EMAIL ADDRESS AND MOBILE NUMBER

We may store the email addresses/mobile numbers of those who communicate with us via email/mobile or who have shown interest in our Programs and add them to our mailing/SMS/call list when you sign up to receive special promotions and updates.

OPTING OUT

If you are a registered user and wish to change your preferences, or if you prefer to opt out of regular mail/SMS/calls, you may mail us at queries@GlobalGrads.com to notify us of your request. Once you have submitted your opt-out request, you may assume that it has been successfully received and is being processed. Please allow us 30 business days from when the request was received to complete the removal, as some of our promotions may already have been in process before you submitted your request. Getting unsubscribed from the communication services doesn’t necessarily mean that the information being collected will be deleted. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personally Identifiable Information, we may not be able to provide you the services that can be offered on our Website.

THIRD-PARTY LINKS

Our Website may contain links to other sites. The linked sites are not under the control of GlobalGrads. Please be aware that GlobalGrads is not responsible for the privacy practices of such other sites. GlobalGrads advises you to read the privacy policies of each and every website that collects your information, including Personally Identifiable Information. If you decide to access any of the third-party sites linked to the Website, you do so entirely at your own risk. Any links to any partner of the Website should be the responsibility of the linking party, and GlobalGrads shall not be responsible for notifying you of any change in the name or location of any information on the Website.

RETENTION OF PERSONALLY IDENTIFIABLE INFORMATION

We keep your Personally Identifiable Information as long as necessary for providing you the Services and as per the data protection laws, rules or regulations applicable to you. The length of time we retain Personally Identifiable Information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

8. DATA STORAGE, TRANSFER & PROCESSING GLOBALLY

GlobalGrads and its Indian service providers store information about you on servers located in India, whereas our international service providers may store your information on servers located in other countries. By using our services, you consent to the storage of your information within India or such other countries. If you are using the services from outside India, please know the information you submit will be transferred to and stored in our servers in India or such other countries. The data protection and other laws of India and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our services, you acknowledge the transfer, storage and processing of your information in and to India.

As described above, GlobalGrads also may subcontract the processing of your data to, or otherwise share your data with affiliated companies, service providers or any third-party entity in countries other than your country of residence, including India, in accordance with the applicable law. Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions and/or the provision of support services. By consenting to this Policy, you also provide consent to GlobalGrads to transfer your information to GlobalGrads affiliated companies, service providers or any third-party entity in locations around the world. Wherever your information is transferred, stored or processed by us or our affiliates or service providers, we will take reasonable steps to safeguard the privacy of your Personal Identifiable Information.

9. CHILDREN’S AND MINORS’ PRIVACY

GlobalGrads strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools can also prevent minors from disclosing their name, address and other Personally Identifiable Information online without parental permission. Although the Website is not intended for use by minors, GlobalGrads respects the privacy of minors who may inadvertently use the Website and shall delete their information upon intimation.

10. COOKIES AND WEB BEACONS

Cookies are small pieces of information saved by your browser onto your device’s hard drive. Cookies are used to record various aspects of your visit and to assist GlobalGrads to provide you with uninterrupted service. Web beacons are small graphic files linked to our servers that allow us to track your use of our Website and related functionalities.

We also use or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Website links, the length of time each user spends at any particular area of our Website, and the specific functionalities that users choose to use. Cookies and web beacons allow GlobalGrads to serve you better and more efficiently, and to personalise your experience at our Website. Cookies and web beacons are not used to retain Personally Identifiable Information. From time to time, we may also use additional methods of collecting data.
We may allow third-party companies, including advertising companies (such as Facebook, Google, Twitter, Quora and Bing) to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display Ads and record your activities, so they can show Ads that they consider relevant to you as you browse the Internet. These cookies store information about the content you are browsing, together with an identifier linked to your device or IP address.

These cookies also allow us and third parties to know whether you've seen an Ad or a type of Ad, and how long it has been since you've last seen it. This information is used for frequency capping purposes, to help tailor the Ads you see and to measure their effectiveness.
You should be able to control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar. If you reject our cookies, many functions and conveniences of this Website may not work properly.

11. RIGHTS OF USERS

You may access your rights under the purview of applicable Data Protection Laws by writing an email at compliance@GlobalGrads.com. The primary rights of the Users with respect to data protection are:

The right to access: Users shall have the right to confirm whether or not GlobalGrads is allowed to process their personal data. Additionally, all Users shall have the right to access the Personal Information shared with GlobalGrads including certain other information like the details relating to the purpose of processing information which we shall provide them with upon their demand.

The right to rectification: Users shall have a right to correct any inaccurate Personal Information about themselves and further complete any incomplete information related to them is available with GlobalGrads.

The right to erasure: Users shall at all times have the right to erase any Personal Information concerning them. In such a case, the User is required to request GlobalGrads to delete the Personal Information relating to such User by writing to GlobalGrads at compliance@GlobalGrads.com.

Right to restrict processing: Users shall have the right to restrict GlobalGrads from processing their Personal Information entirely or for any specific purpose as detailed under this Policy. However, GlobalGrads shall continue to have the right to process such Personal Information if the same is required as per applicable laws or to defend any legal claims against GlobalGrads.

Right to object Processing: Users shall have the right to object to our processing of their personal data for one or more purposes. Any such formal objection from User will be recorded, analysed and necessary actions will be carried out within reasonable time limits.

Right to withdraw consent: The personal information processed by GlobalGrads is conditional upon the requisite consent being provided by You to process such personal information. You have the right to withdraw such consent at any time should you wish to decide against permitting GlobalGrads to process your Personal Information.

Access to Information: Users have right or they are able to upon request to have confirmation whether or not personal information concerning them is being processed, and where that is the case users have access to personal information, they can have a piece of copy of their personal information and how it is processed.

You may update or modify your contact information and user preferences by emailing us at compliance@GlobalGrads.com.

13. SECURITY STATEMENT

GlobalGrads has put in place various physical, electronic, and managerial procedures to try to safeguard and secure the information we collect. For example, we provide strong encryptions to store certain information and have stringent managerial checks and password change policies in place. The information we collect is stored with third-party data centres that have a holistic security model with seven levels of security. Please note that GlobalGrads shall not be liable for any misuse or loss of information carried out by such third-party data centres. Furthermore, we also rely on your cell phones’ strong security model to ensure that there is no information or security leak, unless intentionally processed for authentication.

However, please note that while we implement many security measures on this site, 100% security cannot be guaranteed.

14. ADDRESS FOR PRIVACY QUESTIONS

Should you have questions about this policy or GlobalGrads’s process for information collection, use and disclosure practices, feel free to contact us at compliance@GlobalGrads.com. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of your information. Except where required by law, GlobalGrads cannot ensure a response to questions or comments regarding topics unrelated to this policy or GlobalGrads’s privacy practices.

15. CHANGING OUR PRIVACY POLICY

This Policy is subject to change from time to time and shall be uploaded on our Website for your reference. Any changes to this Privacy Policy will be effective immediately upon being posted on this page. By accessing the Website, you indicate your agreement to the modified Privacy Policy and all the changes. Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

16. GOVERNING LAW

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

17. MISCELLANEOUS PROVISIONS

The miscellaneous provisions provided in our Terms of Use shall apply to this Privacy Policy as well.