Privacy Policy

Privacy Policy

A. General

Welcome to Witsavvy, provided by Witsavvy, and its affiliates (referred to as "Witsavvy," "we," "us," or "our"). We value your trust and are committed to protecting your privacy. This Privacy Policy outlines the types of information collected when you use the Witsavvy platform (referred to as the "Platform") and how we collect, use, share, and store such information. It also explains the rationale for collecting this information and the privacy rights and choices you have regarding your submitted information.

1. Definitions

In this Privacy Policy:

• "Witsavvy," "we," "us," or "our" refers to Witsavvy. and its affiliates.


• "You," "yours," and/or "User(s)" refer to all users of the Platform, including Learners and Content Providers, as defined in our Terms and Conditions.

2. Governance

This Privacy Policy, in conjunction with our Terms and Conditions and any other applicable rules, policies, or guidelines on the Platform, governs the use of Witsavvy's services (referred to as the "Services"). It is essential to carefully read this Policy before accessing our Platform and using the Services. By accessing and using the Platform, providing your Personal Information (defined below), or signaling your agreement when presented with the option, you consent to the collection, use, disclosure, sharing, and storing of information as described in this Policy, our Terms of Service, and any other applicable rules, policies, or guidelines on the Platform (collectively referred to as the "Platform Terms"). Witsavvy disclaims all liabilities arising from these terms.

If you have inadvertently submitted any Personal Information to Witsavvy before reading this Policy or if you disagree with the way your Personal Information is collected, stored, or used, you may access, modify, and/or delete your Personal Information in accordance with this Policy (refer to the sections about "Your Choices" and "Your Rights").

If any information you have provided or uploaded on the Platform violates the Platform Terms, Witsavvy may be required to delete such information upon informing you and may revoke your access to the Platform if necessary.

3. Contact Information

If you have any questions about this Privacy Policy, please contact us at connect@witsavvy.com.

Note: Capitalized terms used but not defined in this Policy can be found in our Terms and Conditions.

B. Applicability

This Policy is applicable to all users of the Platform.

Witsavvy oversees and/or oversees various platforms, apart from the Platform, providing a diverse array of services, including those related to technological solutions in the field of education, either independently or through its affiliates and subsidiaries (collectively referred to as "Witsavvy Group Platforms"). Each Witsavvy Group Platform has established its own privacy policies. Consequently, this Policy pertains solely to information collected through the Platform and does not extend to information gathered via Witsavvy Group Platforms. For insights into the privacy practices adopted by Witsavvy Group Platforms, please refer to the respective platforms.

Witsavvy has undertaken reasonable precautions, in accordance with applicable laws and industry standards, to treat Personal Information confidentially and safeguard it against unauthorized access, improper use or disclosure, modification, unlawful destruction, or accidental loss of Personal Information.

C. Access

You may access and browse the Platform as a guest without creating an account or providing any Personal Information; however, Witsavvy does not verify or assume responsibility for any information provided by you as a guest, unless required by law, regulation, or an order from a competent authority. To unlock all features and benefits on our Platform, creating an account is necessary. During registration, you must furnish specific Personal Information as required, and providing additional information, including the option to receive promotional offers from Witsavvy, is discretionary. Witsavvy may introduce optional requests for additional information in the future to enhance customization and deliver personalized content. Records of telephone calls or emails received from or made by you may be retained by Witsavvy for inquiries, feedback, or other purposes, ensuring effective and efficient service delivery.

D. Use of the Platform/Services by Children

As outlined in our Terms and Conditions, registration on the Witsavvy Platform requires compliance with the 'Age Requirements' (as defined in our Terms and Conditions). If you are a "Minor" or "Child," meaning an individual not meeting the Age Requirements, you may not register on the Platform. Only your Parent (defined below) has the authority to register on the Platform on your behalf, agree to all Platform Terms, and enable access under their guidance and supervision.

While some of our Services may necessitate the collection of a Child’s Personal Information, we do not knowingly collect such information without the consent of the Parent. If you are a Parent and become aware that your Child has provided Personal Information without your consent, please contact us at connect@witsavvy.com. If we discover that Personal Information has been collected from a Child without Parental consent, we will take prompt action to remove such information from our servers.

The information in the relevant sections of this notice applies to both Children and adults. If your Child encounters any form of abuse or harassment while utilizing our Services, please reach out to us at connect@witsavvy.com so that necessary actions can be considered.

E. Controllers

Witsavvy acts as the controller of Personal Information collected and processed in connection with the use of the Platform and the provision of Services on the Platform. Details of the Personal Information collected in such instances are outlined below.

 

 

 

F. Personal Information

"Personal Information" refers to information that identifies a User, such as the first and last name, identification number, email address, age, gender, location, photograph, and/or phone number provided at the time of registration or subsequently on the Platform.

"Sensitive Personal Information" includes (i) passwords and financial data (except the truncated last four digits of credit/debit cards), (ii) health data, (iii) official identifiers (such as biometric data, Aadhar number, social security number, driver’s license, passport, etc.), (iv) information about sexual life, sexual identifier, race, ethnicity, political or religious beliefs or affiliations, (v) account details and passwords, or (vi) other data/information categorized as 'sensitive personal data' or 'special categories of data' under the Information Technology Act, and within the context of this Policy or other equivalent/similar legislations.

The use of the term 'Personal Information' encompasses 'Sensitive Personal Information' as applicable to the context of its usage.

We advise against providing Witsavvy with any Personal Information unless explicitly requested by us. In the event you share Personal Information with Witsavvy without our explicit request, we bear no liability regarding such information provided by you.

G. Information We Collect

We only collect information about you when there is a legitimate reason to do so, such as providing our Services on the Witsavvy Platform, facilitating communication with you, or enhancing our Services.

Information we collect from You:

1. Basic account information: To access specific features on the Platform, you must create an account, providing basic information such as your name, email address, state of residence, country, password, username, and phone/mobile number.


2. Know Your Customer ('KYC') information: For Content Providers, we collect KYC information, including PAN number, Aadhaar number, driver’s license, passport, entity details (such as name, MOU/AOA, certificate of incorporation, list of directors/partners), social security number, and relevant documents. This information is essential for verification purposes in accordance with any agreement executed with you.


3. Public profile information: For Content Providers, additional information may be collected to create a public profile on the Platform, excluding KYC details. Public profiles include relevant information for Learners and Users to better understand you, such as your username, content availability, educational qualifications, associations, photo, and similar details.


4. Information when you communicate with us: Correspondence with us, including questions or requests for assistance, and any provided phone/mobile numbers are kept for future reference. Browsing activity on the Platform is tracked for statistical purposes, and communication through surveys, contests, events, or other means is stored.


5. Information related to location: You can choose to provide location-related information, including GPS access, enabling customized offerings based on relevant location data.

Information we collect automatically:

1. Device and Log information: When you access our Platform, we gather standard information typically provided by web browsers, mobile devices, and servers, including browser type, IP address, device identifiers, language preference, referring site, date and time of access, operating system, and mobile network details.


2. Usage information: Data on your Platform usage, interactions, and Supported Device information (e.g., screen size, cellular network name, mobile device manufacturer) is collected for service provision, insights into user behavior, and improving the Platform.


3. Location information: We may determine the approximate location of your Supported Device from your IP address, using this information for regional insights and to enhance our Platform Services.


4. Information from cookies & other technologies: We may employ cookies and similar technologies to gather information about your activities on the Platform. Refer to our Cookie Policy for more details.

Information we collect from other sources:

We may receive information about you from other sources, either through their services to us or publicly available sources, in compliance with the law. This information may be combined with other data we collect from or about you, enhancing our understanding of your profile. For instance, information from social media sites or Google services may be received if you connect to the Services through these platforms or use Google sign-in.

H. Basis of Collection and Processing of Your Personal Information

Basis for Collection:

We collect and process your Personal Information based on the following legal parameters, determined by the nature of the Personal Information and the purposes for which it is processed:

1. Consent: Your consent is sought at the time of collecting and processing certain Personal Information where required by applicable Data Protection Laws. Processing is carried out only when consent is secured.


2. Compliance with a Legal Obligation: Processing of your Personal Information may occur to the extent necessary for compliance with a legal obligation.

Processing of Your Personal Information:

We may process your Personal Information for the purposes outlined in this Policy based on one or more of the following legal grounds:

1. Necessity for Services: Processing is necessary to perform the Services you have requested or to comply with instructions or other contractual obligations between you and us.


2. Legal Obligations: Processing is necessary to comply with legal obligations and maintain records of our compliance processes.


3. Legitimate Interests: Processing is necessary for our legitimate interests or those of a third-party recipient of your Personal Information, provided such interests are not overridden by your interests or fundamental rights and freedoms.


4. Public Display: Processing may occur if you choose to publish or display your Personal Information in a public area of the Platform, such as a comment area.


5. Vital Interests: Processing is necessary to protect your vital interests.


6. Public Interest: Processing is necessary in the public interest.


7. Consent: Processing is carried out based on your express consent for a particular manner of processing.

We do not use Personal Information to make automated decisions or create profiles beyond what is described in this Policy.

If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent at any time, as per this Policy. Please note that withdrawal may impact our ability to continue offering Services, and we reserve the right to withdraw or cease offering Services upon your consent withdrawal. To withdraw consent, contact us with a written request using the details provided in the 'Grievances' section below. Upon receiving your consent withdrawal request, we will communicate the consequences of withdrawal, and upon your agreement, the withdrawal request will be processed.

I. How We Use and Share the Information Collected

Usage and Processing of Information:

We utilize/process your information as follows:

1. To Provide Services on our Platform: Your information is used to enable Platform access, maintain your account, offer customer service, process purchases, verify user details, and address Platform glitches. This processing is based on consent or, where applicable, our legitimate interests or contract performance.


2. To Improve Our Platform and Maintain Safety: Information is employed to enhance and customize the Platform, provide automatic updates, and prevent criminal activity, fraud, or misuse. This processing is based on consent or, where applicable, our legitimate interests or contract performance.


3. To Market Our Platform and Communicate with You: Your information is utilized for targeted marketing, communication about offers, new products, services, or gathering feedback. This processing is based on consent or, where applicable, our legitimate interests or contract performance.


4. To Establish, Exercise, or Defend Legal Claims: Personal Information may be processed for legal claims in court, administrative, or other proceedings, based on our legitimate interest.


5. To Manage Risk and Obtain Professional Advice: Personal Information may be processed to manage risk or obtain professional advice, based on our legitimate interest.


6. Consent: Your information may be used with your consent or at your direction.


7. To Better Understand Our Users: Information is used to identify frequently visited areas for Service enhancement.

Sharing of Information:

Information is shared per the terms of this Policy as specified below. Personal Information is not sold or disclosed for monetary consideration. Authorized Witsavvy representatives, on a need-to-know basis, use the information with your consent.

1. Affiliates and Subsidiaries: Information may be disclosed to affiliates, subsidiaries, and businesses under the same control, following this Privacy Policy. If you availed Services in collaboration with Witsavvy Group Platforms, your Personal Information may be shared with them for communication on separate products/services, with opt-out options.


2. Third-Party Vendors/Service Providers: Information may be shared with third-party vendors or service providers for support services, business analysis, website functionality, payment processing, and other Platform features. They are bound by this Privacy Policy.


3. Third-Party Platforms for Additional Offerings: Information may be shared with third-party platforms facilitating interactive forums, based on your consent. Privacy practices of these platforms are independent, and users are advised to review their policies.


4. Legal Disclosures: Information may be disclosed in response to a court order, government request, or to protect rights, property, safety, or enforce Terms and Conditions. Attempted prior notice will be given as permitted by law.


5. Business Transfers: User information may be transferred in mergers, acquisitions, or bankruptcy events, with the Privacy Policy applying to the acquiring party.


6. Advertising and Analytics Partners: Usage data may be shared with advertisers, advertisement networks, and analytics providers through cookies and similar technologies.


7. With Your Consent: Information may be shared and disclosed with your consent or at your direction.

Your information may be shared for reasons not outlined in this Policy, with consent or direction sought before such sharing.

 J. Cross-Border Data Transfer

Witsavvy may utilize servers in other countries, contingent upon the locations of its affiliates and service providers.

Please be aware that these countries may have varying privacy laws, potentially less stringent, and Personal Information may become subject to the laws and disclosure requirements of these countries. This includes disclosure to governmental bodies, regulatory agencies, and private entities due to applicable governmental or regulatory inquiries, court orders, or similar processes.

If you access our Platform from outside India, including the USA, EU, EEA, and UK, your information may be transferred to, stored, and processed in India. By accessing our Platform or providing us with information, you consent to the transfer of information to India and other countries outside your country of residence. 

Any transferred Personal Information is protected according to this Policy and in compliance with applicable Data Protection Laws and regulations.

K. Duration for which Your Information is Stored

Generally, when you delete provided information or your account on the Platform, it is also deleted from our servers. However, in specific cases, we retain your information for as long as necessary, considering purposes mentioned herein, including legal obligations or business compliances.

Please note that we may not delete all communications, photos, files, or other publicly available documents (e.g., comments, feedback). In such cases, we anonymise your Personal Information to prevent individual identification. Aggregated or de-identified information will never be disclosed in a way that could identify you.

Note: To exercise your rights (specified in the 'Your Rights' section below) for accessing, modifying, or deleting information stored about you, use the options within the Platform. For clarifications, you can contact us at connect@witsavvy.com.

 L. Your Choices

1. Limit the Information You Provide:
   
   
   
   • You have the option to select the information you share with us, including the ability to update or delete your information. However, please note that certain information may be essential for accessing the Platform or its features.
   
   
   
   


2. Limit Communications You Receive:
   
   
   
   • Choose the type and frequency of communications you receive from us or opt out altogether. Some communications, necessary for legal or security reasons, may not be subject to limitation.
   
   
   
   


3. Reject Cookies and Similar Technologies:
   
   
   
   • You can reject or remove cookies from your web browser, and adjust default settings accordingly. Keep in mind that some Platform services may be affected when cookies are rejected, removed, or disabled.
   
   
   
   

 

 

M. Your Rights

In general, all Users possess the rights outlined in this section. Specific rights may vary based on your location. Refer to the Country Specific Additional Terms below for detailed information. Users can exercise these rights through the options provided on the Platform upon login. For any issues or clarifications, contact us at the address provided in the 'Grievances' section below, and we will address concerns as required by applicable law.

1. Right to Confirmation and Access:
   
   
   
   • Obtain confirmation and access to your Personal Information along with supporting details.
   
   
   
   


2. Right to Correction:
   
   
   
   • Request the rectification of inaccurate Personal Information and update incomplete or outdated information.
   
   
   
   


3. Right to Be Forgotten:
   
   
   
   • Restrict or prevent the continued disclosure of your Personal Information under specific circumstances.
   
   
   
   


4. Right to Erasure:
   
   
   
   • Request the removal of your Personal Information from our Platform, understanding that it may result in the permanent deletion of your account.
   
   
   
   

Remember, these rights apply solely to your information, and identity verification may be required in compliance with Data Protection Laws.

N. Information Security

1. Transmission Security:
   
   
   
   • We employ Transport Layer Security (TLS) or Secure Sockets Layer (SSL) software to encrypt information during transmission, ensuring its security as mandated by applicable laws.
   
   
   
   


2. Safeguards and Procedures:
   
   
   
   • We maintain electronic and procedural safeguards for the collection, storage, and disclosure of Personal Information, including Sensitive Personal Information.
   
   
   
   


3. Identity Verification:
   
   
   
   • Proof of identity may be requested before disclosing Personal Information to ensure it belongs to the rightful owner.
   
   
   
   


4. No Absolute Security Guarantee:
   
   
   
   • While we strive for security, no data storage or transmission system is entirely foolproof. We cannot guarantee absolute security in the event of a breach.
   
   
   
   


5. User Responsibility:
   
   
   
   • Protect your account against unauthorized access, change your password if compromised, and sign off on shared computers promptly.
   
   
   
   


6. KYC Information Encryption:
   
   
   
   • All KYC information collected is fully encrypted and accessible only to designated authorities within Witsavvy.
   
   
   
   


7. Third-Party Security Measures:
   
   
   
   • Third parties providing services to us are contractually bound to implement appropriate security measures aligning with our policies.
   
   
   
   

O. Opting Out of Promotional Communications

 

At Witsavvy, you're always in control. Choose to opt out of receiving some or all of our promotional communications through the settings within the platform upon logging in. You can also utilize the unsubscribe link in any email we send or reach out to us at connect@witsavvy.com.

Even if you opt out of promotional communications, essential transactional updates like service announcements, administrative notices, and account information may still be sent to you without the option to opt out. If you decide to part ways with our platform or want to cease all communications (except those legally required), you can delete your account through the platform or contact us at connect@witsavvy.com.

Advertisers and their agents may use technology to deliver ads directly to your browser while accessing our sites. They automatically receive your IP address, and cookies may be used to gauge ad effectiveness and personalize content. We don't control these features, and the information practices of advertisers and third-party sites aren't covered by our policy. For details, reach out to them directly.

Please note that opting out of promotional emails affects only future communications from us. If we've already shared your information with a third party as per our policy, you may need to adjust your preferences directly with that third party.

Rest assured, we don't sell your personal information to third parties, nor do we use your name or your company's name in marketing statements without your consent.

P. Interest-Based Ads

On external sites, Witsavvy may present interest-based ads using information you provide when interacting with our platform and services. These ads, also known as personalized or targeted ads, are shown based on activities like platform registration or visits to sites featuring Witsavvy content or ads.

In delivering interest-based ads, we adhere to relevant laws, the Code for Self-Regulation in Advertising by the Advertising Standards Council of India, and the Self-Regulatory Principles for Online Behavioral Advertising from the Digital Advertising Alliance. We also follow other rules and guidelines issued by the Federal Trade Commission regarding digital advertising.

We don't share any personal information with advertisers or third-party sites displaying our interest-based ads. However, these parties may assume that users engaging with personalized ads belong to the targeted audience. Some third parties might provide us with information about you from offline and online sources, enhancing the relevance of advertising.

Similar to promotional communications, advertisers or their agents may use technology to serve ads directly to your browser. Your IP address is automatically received, and cookies may be employed to measure ad effectiveness and personalize content. We lack control over these features, and the information practices of advertisers and third-party sites aren't governed by our policy. For more details, get in touch with them directly.

Q. Updates to Witsavvy's Privacy Policy

As Witsavvy evolves, so does our commitment to safeguarding your privacy. Our Policy is subject to change, and we may, at our discretion (unless required by applicable laws), send periodic reminders of our notices and conditions via email, unless you've opted otherwise. We encourage you to stay informed by checking our platform regularly for the latest updates. Unless stated otherwise, the current Policy applies to all information we have about you and your account. While our business transforms, we uphold our promises and won't substantially alter our policies and practices, making them less protective of customer information collected in the past, without your consent.

R. Privacy Concerns and Complaints

If you have any inquiries about our Policy, want to exercise your rights, express concerns about the privacy of your data, or have any privacy-related grievances regarding the platform, please submit your complaint with a detailed description via email to connect@witsavvy.com, addressed to our grievance officer, Mr.Alok (Associate Counsel). Alternatively, you can send a registered post to the following address:

Witsavvy

FF-103, Near Bakson Hospital, KP-1,

Greater Noida, Uttar Pradesh-201308

S. Specific Privacy Terms for Witsavvy Users 

TERMS FOR INDIAN RESIDENTS

Your Rights under the Personal Data Protection Bill (PDPB):

If you're located in India, you have specific rights under the PDPB:

1. Right to Confirmation and Access:
   
   
   
   • Obtain confirmation and access to your Personal Information.
   
   
   • Request supporting information.
   
   
   
   


2. Right to Correction:
   
   
   
   • Ask for the rectification of inaccurate Personal Information.
   
   
   • Request updates for incomplete or outdated information.
   
   
   
   


3. Right to Data Portability:
   
   
   
   • Request the transfer of your Personal Information to another organization or yourself under certain circumstances.
   
   
   
   


4. Right to be Forgotten:
   
   
   
   • Restrict or prevent the ongoing disclosure of your Personal Information under certain conditions.
   
   
   
   


5. Right to Erasure:
   
   
   
   • Request the removal of your Personal Information from our Platform. Note that this erasure may result in the permanent deletion of your account.
   
   
   
   

T. Collection Notice

We collect the information outlined above, we gather the following categories of Personal Information from you:

1. Identifiers:
   
   
   
   • Information such as your name, email address, mobile number, username, unique personal identifier, and Internet Protocol (IP) address. We utilize Identifiers, as explained in the "How We Use and Share the Information Collected" section of this Policy, for purposes like personalization, contact, and device and online identification.
   
   
   
   


2. Characteristics of Personal Information:
   
   
   
   • Details including your name, email address, username, unique personal identifier, and gender. We employ these Characteristics of Personal Information, in alignment with the 'How We Use and Share the Information Collected' section of this Policy.
   
   
   
   


3. Internet or Electronic Network Activity Information:
   
   
   
   • Data collected through cookies (refer to our Cookie Policy) and automatically received from your browser and device. This includes the date and time of your Platform visit, location, IP address, domain server, browser type, access time, and information about your Platform page visits. We utilize this information, as detailed in the 'How We Use and Share the Information Collected' section of this Policy.
   
   
   
   


4. Geolocation Data:
   
   
   
   • Your IP address, utilized for purposes such as location tracking based on your IP address, as explained in the 'How We Use and Share the Information Collected' section of this Policy.
   
   
   
   


5. Audio, Electronic, Visual, or Similar Information:
   
   
   
   • This may include your profile picture or other audio/visual content uploaded to the Platform. We use such information, as outlined in the 'How We Use and Share the Information Collected' section of this Policy.
   
   
   
   


6. Inferences:
   
   
   
   • Inferences drawn from the Personal Information collected, such as predictions regarding retention or attrition. We use Inference information as detailed in the 'How We Use and Share the Information Collected' section of this Policy.
   
   
   
   

U. Data Practices in the Last 12 Months

Personal Information Collected: As per this Policy, we have collected the following categories of Personal Information over the past 12 months:

• Identifiers


• Characteristics of Personal Information 


• Internet or Electronic Network Activity Information


• Geolocation Data


• Commercial Information


• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information


• Inferences

Categories of Sources: We have collected Personal Information from you and our payment processors.

Business and Commercial Purposes for Collection: We collected the mentioned Personal Information categories for the following purposes:

• Operating the Platform


• Providing Services


• Adhering to Terms and Conditions


• Ensuring Platform and Service Privacy and Security


• Managing Customer Relationships


• Communication


• Analyzing Platform and Service Usage


• Enhancing User Experience


• Tracking Platform Visits


• Providing a Personalized and Interactive Platform Experience


• Usage Analytics

Personal Information Sold: No categories of Personal Information have been sold during the preceding 12 months.

Personal Information Disclosed for a Business Purpose: We have disclosed the following categories of Personal Information for a business purpose to:

1. Corporate parents, subsidiaries, and affiliates


2. Advisors (accountants, attorneys)


3. Service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support)


4. Operating systems and platforms.

V. Consumer Rights and Requests at Witsavvy

Consumers with the right to request (1) disclosure of collected Personal Information and (2) deletion of specific Personal Information. Witsavvy respects and honors these rights as applicable.

If a request is not submitted through the designated methods or is deficient, we will either (i) treat it as if submitted correctly or (ii) guide you on proper submission.

Request to Know: As an resident, you can request:

1. Specific pieces of Personal Information.


2. Categories of Personal Information collected.


3. Categories of sources for Personal Information.


4. Categories of Personal Information sold and the recipients.


5. Categories of Personal Information disclosed for a business purpose and the recipients.


6. Business or commercial purpose for collecting, disclosing, or selling Personal Information.


7. Categories of third parties with whom we share Personal Information. Our response covers the 12 months preceding the request.

Request to Delete: As a resident, you have the right to request erasure of specific Personal Information collected or maintained. We will delete your information from our records and instruct service providers to do the same. However, certain exemptions may apply.

Submitting a Request: You can submit a request via email to connect@witsavvy.com. For deletion requests, we may offer the option to delete select portions or all Personal Information.

Verification Process: We verify identities to match information in the request with existing records. You may need to provide your name, email, and mobile number (if provided during registration). We'll inform if verification fails.

Authorized Agents: Agents can submit requests with signed permission and identity verification. 

Excessive Requests: If requests are excessive, we may (1) charge a reasonable fee, or (2) refuse with an explanation. Fees are based on administrative costs.

Privacy Policy – Version 1.1

Last Updated on 24December 2023