Privacy Policy

Table of contents:

A. General

B. Applicability

C. Access

D. Personal Information

E. Automatic Information Collection

F. Information Security

G. Use of your personal information

H. Exceptions

A. General

In this policy, the words “we”, “our”, and “us” refer to Padhio (Tramseb Learning Solutions Pvt. Ltd.) and the privacy mechanism outlined identify personally identifiable or personal information that may be collected, how such information is used, and the choices You have regarding our use of this information.

In addition to the terms stated in ‘Terms and Conditions and Content Policy’ provided under this Website/mobile application (together “Platform”), we are committed to protecting Your privacy. We constantly review our systems and data to secure Your personal information. In the event of any identified unauthorized use or disclosure of information or upon Your complaint, we will investigate any such complaint or such actions with a view to prosecuting and/or taking civil proceedings to recover damages against those responsible. Any User who does not agree with any provisions of this ‘Privacy Policy’ and the ‘Terms and Conditions and Content Policy’ may be required to leave the Platform immediately. Padhio disclaim all the liabilities arising therefrom and it shall be assumed by Your continued use of the Platform that You have accepted the Policy and any other  terms and conditions available online on the Platform.

If any information You have provided or uploaded on the Platform violates the terms of this Policy, Padhio may be required to delete such information upon informing You of the same and revoke Your access if required without incurring any liability to You.

B. Applicability

This privacy policy (“Policy”) applies to all Users who access the Platform and are therefore required to read and understand the Policy before submitting any Personal Information (defined hereinafter). By submitting Personal Information, You are consenting to the use and processing of such information in accordance with this Policy.

If you install, use, access Padhio or any of its features, you have read and accepted the terms of this Policy. You have also accepted the Padhio ‘Terms and Conditions and Content Policy’, and other terms which are available on the Padhio App, Padhio Website, and otherwise. If you don’t agree with and accept the above, please do not use, install, access Padhio or any of its features.

This Policy applies to the Platform and any other services that are owned and operated by Padhio. Third party websites and advertisers may place their own cookies or other files on the Users’ computer, collect data or solicit personal information from the Users, for which Padhio is not responsible or liable. Accordingly, Padhio does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does Padhio guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Padhio of the website, the website’s provider, or the information on the website. Padhio encourages the User to read the privacy policies of each such website and the User understands that its solely such third party who is responsible to the User in this regard.

Padhio has taken reasonable precautions as per industry standards to treat Personal Information as confidential and to protect it from unauthorized access, improper use or disclosure, modification and unlawful destruction or accidental loss of the Personal Information.

 

C. Access

This privacy policy (“Policy”)In order to have access to all the features and benefits on our Platform, a User is required to first create an account on Padhio Platform. To create an account, a User is required to provide Personal Information as may be required during the time of registration. Other information requested on the registration page, including the ability to receive promotional offers from Padhio, is optional. Padhio may, in future, include other optional requests for information from the User to help Padhio to customize the Platform to deliver improved and personalized experience to the User. Without the User’s agreement, Padhio will not share, rent or sell any Personal Information with third parties in any way other than what is disclosed in this Policy. Padhio may keep records of telephone calls received and made for making enquiries, registered courses, feedback or other purposes for the purpose of rendering services effectively and efficiently.

D.   Personal Information

This privacy policy (“Policy”)“Personal Information” shall mean the information which identifies the User, name, identification number, email address, age, gender, or phone number provided to Padhio at the time of registration or any time thereafter. Personal information may include “sensitive personal information or data” as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and in this context, includes passwords or any financial account information provided by You during registration or any time thereafter.

We request You to not provide anyone with Personal Information seeking it on behalf of Padhio, unless specifically requested by us through official channels. In such events, we bear no liability to such Personal Information provided by You.

E. Automatic Information Collection

Our system may collect information that is sent over the internet without Your control. Some examples of the information we may collect and analyse include the Internet protocol (IP) address used to connect Your computer to the internet; login; email; computer and connection information such as browser type and version, operating system, and platform; video watch history, which we sometimes aggregate with similar information from other users to create features, reports such as popular videos, curated courses, most used features etc; the full Uniform Resource Locator (URL) click stream to, and from our Platform, including date and time; cookie number; courses or videos You viewed or searched for; the email id You used to call our customer service.

During some visits we may use software tools to measure and collect session information, including page response times, download errors, length of visits to certain pages, courses and videos, page interaction information (such as scrolling, clicks and mouse overs), and methods used to browse away from the page. Often, this information is used to analyse root causes in case of app crashes, network errors and other misbehavior of the app.

We also collect Information related to your use of Padhio such as content preferences and consumption, interaction with other users, user activity, etc. Padhio will need to access your device’s camera, microphone, photo and/or video and/or audio library or gallery in order to provide some of our features (eg: video recording and editing). We also collect service-related, diagnostic, and performance information. This includes information about your activity (such as how you use Padhio, how you interact with others using Padhio, etc.), log files, and diagnostics, crash information, website, and performance logs and reports, etc.

F. Information Security

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on file. We cannot, however, ensure or warrant the absolute security of any information you transmit to Padhio or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

G. Use of your personal information

While availing our services You will provide access to Padhio with Your Personal Information. If that information is wrong, You can request us to modify or delete the same. Padhio will take all reasonable measures to ensure that the Personal Information is modified and used for rendering services to You and as otherwise in compliance with laws. When editing or deleting Personal Information, we may ask You to verify Your identity before we can act on Your request. Padhio may at its discretion reject any request that is contrary to law or requires un-reasonable technical efforts. We do not assure that we will delete all residual copies and archives made by any third party without our knowledge and consent. We never retain Your Personal Information longer than it is required for the purposes of providing services through the Platform or as required by applicable Indian law. At times, we may also require to transfer Your Personal Information to third-party service providers, for instance to authorize transactions we may share Your financial data with such third-party providers. You hereby consent to Your transfer of Personal Information in all such instances. Padhio carries out all such transfers strictly in accordance with law.


How do we use your phone number?

By submitting your Phone Number on Padhio website/app, you agree to receive calls and messages from us. The Phone Number is also used as a verification method. We only call or text people who have authorized us to contact them, either directly, or through a third party.

Padhio shall use Your Personal Information to ensure services with respect to the Platform are presented to You in the most effective manner, to secure the Platform and make improvements, to carry out our obligations to You, and to communicate with You. The said communication can either be by calls, text or emails and for purposes which include transactional, service, or promotional calls or messages. If at any time You wish to not receive any communication from our end You can opt-out of the same by writing to us on support@padhio.com.

H. Exceptions

This privacy policy (“Policy”)Your Personal Information may be shared with third parties who have a need or authority to receive such information, if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to comply with (i) in response to any authority having to receive such information under law (ii) any order of court (iii) detect, prevent, or otherwise address fraud, security or technical issues (iv) protect against harm to the rights, property or safety of Padhio, our users or the public as required or permitted by law.

 

User choices with regard to access of information

Padhio does not make any unsolicited calls or otherwise market any products or services, except for in relation to the purpose for which such information has been provided or taking any feedback, addressing any complaints, informing You about new features or free/paid courses. Users shall not disclose their Personal Information to any third parties that are not authorised by Padhio and verify the identity of such person who seek information. Padhio will communicate with the Users through call, SMS, email or notices posted on the Platform or through any other means available, which shall include but not be limited to text, other forms of messaging, calls etc. The Users can change their e-mail and contact preferences at any time by logging into their account or by emailing at support@padhio.com.

 

Report, Analysis & Confidentiality

Padhio may have to use Personal Information without reference to any persona or identity for research, statistical analysis improving the Platform of functionalities offered thereon and business intelligence purpose and may transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.

All Padhio employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every User’s sensitive personal data and information.

 

Sharing of Information

Padhio may also disclose or transfer User’s personal and other information which a User provides, to another third party as part of reorganization or a sale of the assets of Padhio corporation division or company. Any third party to which Padhio transfers or sells its assets will have the right to continue to use the personal and other information that a User provides to us.

To the extent necessary to provide Users with the services on the Platform, Padhio may provide User’s Personal Information to third party contractors who work on behalf of or with Padhio to provide Users with such services, to help Padhio communicate with Users or to maintain the Platform. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Platform, including the providers of online communications services, online payment gateway services, will have rights to use and disclose the Personal Information collected in connection with the provision of these services in accordance with their own privacy policies.

Furthermore, please note that we cannot control the actions of other Users of the Platform with whom You may choose to share Your Personal Information, and any such actions on Your behalf shall be solely Your responsibility.

 

Interest-Based Ads

Padhio may display interest-based advertising using information You make available to us when You interact with our Platform, content, or services. Interest-based ads, also sometimes referred to as personalised or targeted ads, are displayed to You based on information from activities such as subscription on our Platform, visiting sites that contain Padhio content or ads. In providing interest-based ads, we follow applicable Indian laws, as well as the Code for Self-Regulation in Advertising by the Advertising Standards Council of India and the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance (a coalition of marketing, online advertising, and consumer advocacy organizations).

Like other online ad networks, we use cookies, web beacons (also known as action tags or single-pixel gifs), and other technologies (collectively, “cookies”). Cookies enable us to learn about what ads You see, what ads You click, and other actions You take on our sites and other sites. This allows us to provide You with more useful and relevant ads. For example, if we know what ads You are shown we can be careful not to show You the same ones repeatedly. 

We do not provide any personal information to advertisers or to third party sites that display our interest-based ads. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalised ad or content are part of the group that the ad or content is directed towards (for example, users in northern India who bought or browsed for academic books). Also, some third-parties may provide us information about You (such as the sites where You have been shown ads or demographic information) from offline and online sources that we may use to provide You more relevant and useful advertising.

Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on our sites directly to Your browser. They automatically receive Your IP address when this happens. They may also use cookies to measure the effectiveness of their ads and to personalise ad content. We do not have access to or control over cookies or other features that advertisers and third party sites may use, and the information practices of these advertisers and third party websites are not covered by our Policy. Please contact them directly for more information about their privacy practices.

 

Revision of Terms and Grievance Policy 

This privacy policy (“Policy”)Padhio may update or amend this Policy at any time, with or without advance notice. In the event, there are significant changes in the way Padhio treats User’s personally identifiable information, Padhio will display a notice on the Platform or send Users an email. Padhio’s current Policy concerns all information that Padhio has about Users and their account.

Notwithstanding the above, Padhio shall not be required to notify the Users of any changes made to the privacy policy. Should You have any concern or reject the changes in the privacy policy You can refuse to accept the amendments and opt for withdrawing Your Personal Information by writing to us at support@padhio.com.