PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) describes how we, UpGrad Education Private Limited (“UpGrad” or “we” or “us”) collect, use and share information about our users (“you”) through our Platform. Please review our Terms of Use and Privacy Policy (collectively the “Terms”) that govern the use of the Platform and Programs. This Privacy Policy shall form a part of the Terms by way of reference. All capitalized terms not defined in this Privacy Policy, have the respective meanings set forth in the Terms of Use. This Privacy Policy applies only to the part of the Platform provided by UpGrad, and we are not responsible for the practices of persons, companies, institutions or websites that UpGrad does not control, manage, or employ.

Please understand that by using our Platform or submitting any Personally Identifiable Information (defined below) to us, you consent and agree that we may collect, use, 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. UpGrad 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 Platform.

  1. INFORMATION COVERED BY THIS PRIVACY POLICY

    Some of our Platform’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 Platform, 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 such as the web pages that you have viewed. In order to access certain features and benefits on our Platform, 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 UpGrad. Inaccurate information may affect your ability to use the Platform, the information you receive when using the Platform, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

  2. INFORMATION COLLECTION

    1.1 NON-PERSONAL INFORMATION

    When you come to our Platform, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages of our Platform 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 from which you linked to our Platform. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Platform. Although such information is not Personally Identifiable Information, we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.

    1.2 PERSONALLY IDENTIFIABLE INFORMATION

    We collect Personally Identifiable Information that you provide to us when you sign-up for email updates or Programs, participate in our public forums, avail of our chat room services, send us email messages, and/or participate in online events or receive other services on or through our Platform. This information may include, among other things, your name, email address and contact number, educational qualification(s) and post qualification experience among other things.

    UpGrad, or its Educational Partners and third-party service providers, may, for instance, collect certain information from you in conjunction with assignments, exams and other assessments related to the online course. For example, as part of a proctored exam for a course, UpGrad (or its third party service providers) may collect certain information from you in order to (a) verify or authenticate your identity or submissions made by you, such as a signature for a test or assignment log, a photograph or 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). UpGrad may also collect information from you or about your performance or accomplishments, such as quiz/exam scores, grades, project evaluations, teacher evaluations and other evaluations of your performance or accomplishments.

    1.3 THIRD PARTY SERVICE PROVIDERS

    We may receive Personally Identifiable Information when you access or log-in to a third-party site, e.g., Facebook, Whatsapp from our Platforms. 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 Platforms 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 contracts with third parties to serve ads on our behalf across the Internet and sometimes on this Platform. They may collect information about your visits to our Platform, and your interaction with our products and services. They may also use information about your visits to this Platform and to other websites so as to target advertisements for goods and services. This information is collected through the use of a pixel tag, which is industry standard technology used by most major websites. Such third parties are not permitted 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, UpGrad shall not be responsible.

    1.4 INFORMATION WE RECEIVE FROM OTHER SOURCES

    We may receive information about you if you use any of the other platforms we operate or the other services we provide. In this case we will inform you when we collect that data and that it may be shared internally and combined with data collected on the Platform. We are also working closely with third parties (including, for example, Educational Partners, sub-contractors in technical, advertising networks, analytics providers, search information providers) and may receive information about you from such sources. We collect Non-Personally Identifiable information from the Platform visitors to track the total of number of visitors to the Platform in aggregate form and identify the type of Internet web browser (e.g., Internet Explorer®) and operating system (e.g., Windows®) used by the visitor. This information allows us to continuously improve our Platform and our services.

  3. USE OF INFORMATION

    We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific Program related information and/or services you select, send you updates about the Programs or other UpGrad events, and send you email messages about Platform maintenance or updates, among other things.

    We use the Personally Identifiable Information that we collect from you when you participate in a Program for managing and processing purposes, including but not limited to tracking attendance, progress and completion of a Program. As part of our management and processing of the Program, we will use certain Personally Identifiable Information to administer exams, projects, and other assessments for the Program. For example, as part of an exam, UpGrad may use certain information collected from you in order to verify your identity, or to monitor your performance during the exam to confirm that you are abiding by the applicable testing rules or requirements. We may share Personally Identifiable Information that we collect from you when you participate in an Program with the particular Educational Partner (e.g., such as a university or company) that developed or offered the Program and the instructor(s) who taught, managed or otherwise oversaw the Program or 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. In another example, if you are taking a Program sponsored or paid for by your employer, we may share your grades, evaluations, or progress in the Program with your employer and other Personally Identifiable Information. This information may be shared at any time during the Program or afterwards. Personally Identifiable 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.

    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, UpGrad may make available to you chat room services that allow you to communicate with UpGrad staff members and we may use your Personally Identifiable Information to provide these services to you. Moreover, in certain circumstances, we may share certain Personally Identifiable Information and materials with third parties including but not limited to potential employers and/ or service providers such as Facebook in order to provide you services that you have requested or services UpGrad provides in conjunction with the Programs. For example, we may submit your data to potential employers. In another example, UpGrad staff members may create groups on Facebook (or similar service providers) 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 in relation to the Programs, details of potential employers etc. Please be aware that the information disclosed on a third-party service providers platform 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. UpGrad and/or its associates shall have no liability in this regard whatsoever.

    UpGrad may use certain companies that enable you to establish a membership to participate in digital wallets, payment services or rewards programs. If you elect to do so, we will disclose to such companies your information necessary to make their programs work and support your membership with them. We are not responsible for the privacy practices of the companies sponsoring these membership programs and we suggest you review the individual privacy policies of each company with whom you establish such membership. Billing Information may be archived by us or our providers. We may archive Personally Identifiable Information other than Billing Information and/or use it for future communications with you.

    Our operations and maintenance contractors and other service providers may have limited access to your Personally Identifiable Information in the course of providing products or services to us.

    To the extent any Personally Identifiable Information collected by us contains images of you, you grant UpGrad a limited, non-exclusive right to use, reproduce, distribute, prepare derivative works of or publicly display such images and/or your likeness.

    UpGrad may share your Personally Identifiable Information with various government authorities in response to court orders, or other legal process; 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 also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of UpGrad, the Platform, our users, customers, or others; and in connection with our Terms and other agreements.

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

    UpGrad 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 term is defined in the Companies Act, 1956 and Companies Act, 2013 to the extent applicable) of such person.

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

  4. PUBLIC DISCLOSURE OF INFORMATION

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

  5. AGGREGATED DATA

    "Aggregated Data" means records which have been stripped of personally identifying information, and which have been manipulated or combined to provide generalized, 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.

  6. PROTECTION OF INFORMATION

    1.1 CONFIDENTIALITY AND SECURITY

    UpGrad takes all reasonable precautions to protect your Personally Identifiable Information both online and offline, in order to avoid unauthorized breach. In addition, we participate in cooperative database services. These services help us to direct newsletters, mailings and other marketing initiatives to appropriate purchasers and website visitors. Names and mailing addresses may be shared between participating parties in the cooperative database services.

    1.2 NOTIFICATION OF CHANGES

    We may update this Privacy Policy at any time, and it will be posted on this Platform as and when it is so 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 UpGrad has about You and Your account.

    1.3 YOUR EMAIL ADDRESS & MOBILE NUMBER

    We may store the email addresses/mobile numbers of those who communicate with us via email/mobile and add them to our mailing/sms list when you sign up to receive special promotions and updates. By your electing to receive emails/sms/calls from us, we would be able to send you exclusive information and special offers, which you may otherwise not learn about from our Platform. If you are a registered user and wish to change your preferences, or if you prefer to opt out by regular mail/sms/calls, you may mail us at queries@upgrad.com to notify us of your request.

    Once you have submitted your e-mail opt-out request you may assume that it has been successfully received and your request is being processed. Please allow us fourteen 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.

    1.4 THIRD PARTY LINKS

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

  7. CHILDREN AND MINOR’S PRIVACY

    UpGrad 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 also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Platform is not intended for use by minors, UpGrad respects the privacy of minors who may inadvertently use the Platform and shall delete their information upon intimation.

  8. COOKIES & WEB BEACONS

    Cookies are small pieces of information saved by your browser onto your computer/mobile. Cookies are used to record various aspects of your visit and assist UpGrad 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 Platform 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 Platform links, the length of time each user spends at any particular area of our Platform, and the specific functionalities that users choose to use. Cookies and web beacons allow UpGrad to serve you better and more efficiently, and to personalize your experience at our Platform. Cookies and web beacons are not used to retain Personally Identifiable Information. From time to time we may also use additional typical methods of collecting data.

    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 Platform may not work properly.

  9. GRIEVANCE OFFICER

    In accordance with the Information Technology Act, 2000 and applicable rules made thereunder, the Grievance Officer appointed by UpGrad for this Privacy Policy is Mr. Manish Bagadia, who can be reached at queries@upgrad.com.

  10. UPDATING PERSONAL INFORMATION

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

  11. SECURITY STATEMENT

    UpGrad 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 centers which have a holistic security model with seven levels of security. Please note that the Company shall not be liable for any misuse or loss of information carried out by such third-party data centre. 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.

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

  12. ADDRESS FOR PRIVACY QUESTIONS

    Should you have questions about this policy or UpGrad’s process for information collection, use and disclosure practices, feel free to contact us at the address queries@upgrad.com or +91-22-6156-2100. 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, UpGrad cannot ensure a response to questions or comments regarding topics unrelated to this policy or UpGrad’s privacy practices.

  13. CHANGING OUR PRIVACY POLICY

    Please note that we review and may make changes to this Privacy Policy from time to time. Any changes to this Privacy Policy will be effective immediately upon posting on this page. By accessing the Platform, you signify your agreement to the modified Privacy Policy and all of the changes. Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

  14. MISCELLANEOUS PROVISIONS

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

done