This legal document (hereinafter, “Privacy Policy” / “Policy”) is mandated by and published in accordance with the provisions of Rule 3 (1) of the Information Technology (Intermediaries guidelines) Rules, 2011, and Rule 4 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.
This Policy is an electronic record in terms of Information Technology Act, 2000 (hereinafter, the “Act”) and the applicable rules thereunder.
Our website www.stepupwards.com (hereinafter, the “Website”) and our “StepUpwards” application for mobiles and hand held devices (hereinafter, the “App”) and its integrated systems, and/or APIs thereunder, are jointly referred to as the “Platform” and fall within the definition of ‘intermediary’ as defined in clause (w) of sub-section (1) of section 2 of the Act.
The Platform is operated and owned by StepUpwards Learning Private Limited, a company incorporated under the Companies Act, 2013 and having its registered office at No. 14, Bhattarahalli, Old Madras Road, KR Puram, Bangalore, Karnataka 560049, India (hereinafter, “The Company”). The Company is an online Marketplace using its Platform to allow Instructors and Learners to connect, teach, train, and learn. The Company has been providing such services via their Platform through various course instructors.
For the purpose of this electronic record, wherever the context so requires, the terms “you”, “your”, “Learner”, “Instructor”, “Co-instructor”, “Training Associate”, “User”, “Business Partner”, “Client”, or “Licensee” shall mean and refer to any natural person or legal entity who has agreed to become a User on the Platform by providing Registration Data while registering on the Platform as a registered user using any computer system/ mobile/ handheld device. The terms “StepUpwards”, “Licensor”, “Company”, “we”, “us” or “our” shall mean StepUpwards Learning Private Limited.
This Privacy Policy applies to all Users of our Website and App and its integrated systems.
Please read this Policy before using the StepUpwards Platform or submitting any personal information to StepUpwards. This Policy is a part of and incorporated within, and is to be read along with, our Terms of Use (hereinafter, “Terms of Use”).
The use of the Training Sessions and Submitted Content are designed for learning and skill development of Users.
The User is responsible for using, accessing, viewing and browsing the Platform including the Training Sessions and Submitted Content from public place for the purpose of professional learning and skill development. It is the User’s responsibility to not share any sensitive or personal information and to be in a public place where privacy is temporarily relinquished at all such times.
Any capitalized terms not defined in this policy are defined as specified in the Terms of Use.
Any version of this Privacy Policy in a language other than English may be provided for convenience upon request. If there is any conflict with a non-English version, you agree that this English language version of the Privacy Policy (along with any changes thereto) will prevail.
We are committed to protecting and respecting your privacy. This policy together with our Terms of Use sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
You may want to print a copy of this Privacy Policy for future reference.
This electronic record is generated by a computer system and does not require any physical or digital signatures.
YOUR CONSENT
By using this Platform, clicking the “I accept” button or completing the registration process, you agree and acknowledge that you have reviewed this Privacy Policy, given consent and accepted this agreement.
By using the StepUpwards Platform and the services provided via the Platform (hereinafter, “Services”), you agree and consent to the collection, transfer, use, storage, disclosure and sharing of your information as described and collected by us in accordance with this Policy. If you do not agree with the Policy, please do not use or access the StepUpwards Platform.
By using the Platform you consent to the recording of the Training Sessions by StepUpwards for internal monitoring and quality assessment. Such recordings may be converted into transcripts by using any third party software, tools or services. The recording or transcripts of the Training Sessions can be stored, shared or reviewed by StepUpwards for any authorized purpose. Such authorised purposes includes quality monitoring, training, illustrations, disposition, order from competent authority or any other use deemed fit by StepUpwards.
POLICY CHANGES AND EXCEPTION
Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail and where required by applicable law, we will obtain your consent. Changes become effective on the day they are posted unless stated so otherwise. If you do not agree with any changes you should immediately stop using your account. Continued use of your account will be deemed to be acceptance of our changes. The revised Privacy Policy supersedes all previous Privacy Policies.
The StepUpwards Platform may contain links to other websites. Any personal information about you collected whilst visiting such websites is not governed by this Policy. StepUpwards shall not be responsible for and has no control over the practices and content of any website accessed using the links contained on the StepUpwards Platform.
This Policy shall not apply to any information you may disclose to any third party stakeholder outside the purview and operations of the Platform.
INFORMATION WE MAY COLLECT FROM YOU - We may collect and process the following information about you:
The information that you provide by filling in forms, downloading the App, or where you log in via Facebook, Google, or any other social media/ third party platform that we may use.
The information provided at the time of subscribing to our mailing list, or when subscribing to any of the Services or requesting further services.
When you use the Services, including through a third-party platform, we may collect, store, and associate with your account any data you provide therein, including:
Account Data: When you create or update your account, the information you give us may include, your name, age, date of birth, sex, race, ethnicity, address, e-mail address, password, phone number, occupation, skills, interests, government/ official ID information, photo, financial or payment information, information related to social media sites you use, and other registration information and account settings (hereinafter, the “Account Data”). Upon registration, we may assign to you a unique identifying number for our records.
Profile Data: Information like photo, headline, biography, language, website link, social media profiles, country, certifications, awards and publications or any other information. Your Profile Data will be publicly viewable by others.
Shared Content: Usage of our Services lets you interact with other Users or share content publicly, including, posting reviews on a course page, asking or answering questions, sending messages to Learners, and/ or Instructors, or posting photos and/ or uploads related to the course work. Such shared content may be publicly viewable by others.
Course Data: When you enroll in and take courses, we collect certain data including but not limited to: courses, assignments, and quizzes which have been started and/ or completed by you; course purchases and credits; subscriptions; course certificates; your exchanges with Instructors, Co-instructors, Training Associates, and other Learners; essays, answers to questions, and other items submitted by you to satisfy course requirements. If you are an Instructor, we store the course content itself which may also contain any other data as mentioned in this Policy.
Client or End User Payment Data: If you make purchases, we collect certain data about your purchase (including your name, address, and pin code). You must provide the requisite payment, and billing data directly to third-party payment processing partners, including your name, credit card information, billing address, and pin code. The collection, use, and disclosure of your payment, and billing data is subject to the privacy policy and other terms of the third-party payment processing partner. For security, StepUpwards does not collect or store sensitive cardholder data, such as full credit card numbers, or card authentication data.
If you sign up to use our Platform as an Instructor, we may collect location details, copies of government identification documents and other details (KYC), including call and SMS details.
Instructor Payment Data: If you are an Instructor, you can link your PayPal, bank account, or other approved payment account to the Services to receive payments. When you link a payment account, we collect and use information including your payment account email address, ID proof, address, or any other data necessary for us to send payments to your account. In some instances, we may also collect your bank details to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include residency information, tax identification numbers, biographical information, and such other information as may be necessary for taxation purposes. For security, StepUpwards does not collect or store sensitive bank account information, except such details provided for initiating payments or refunds by StepUpwards to any User. The collection, use, and disclosure of your payment, billing, and taxation data is subject to the privacy policy and other terms of the bank and/or payment gateway which is used.
Data About Your Accounts on Other Services: If you access or use our Services through a third-party platform we may obtain certain information through such other accounts if they are connected to your StepUpwards account (including your name, profile picture, any associated account ID number, email address, physical location of your devices, gender, birthday, and list of contacts). The collection, use, and sharing of such data will also be subject to the privacy policies and other agreements of that third-party.
Sweepstakes, Promotions, and Surveys: We may invite you to complete a survey or participate in the interactive Services offered by StepUpwards such as discussion boards, competitions, promotions or sweepstakes, or other social media events and promotions, either through StepUpwards or through a third-party platform. We will collect and store the data you provide as part of participating, such as your name, email address, postal address, date of birth, phone number, comments, and other communications. That data is subject to this Privacy Policy unless otherwise stated in the official rules of the promotion or in another privacy policy. To receive a reward, we may post some of your information publicly. Where we use a third-party platform to administer a survey or promotion, the third party’s privacy policy will also apply.
Communications and Support: If you contact us, we may keep a record of that correspondence. We may also ask you for information such as, your contact information, name, email address, location, StepUpwards user ID, refund transaction IDs, etc, and any other data you provide or that we collect through automated means.
When you use the Services, including through a third-party platform, we may collect, store, and associate with your account any data you provide therein through automated means. Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. Such data collected may include:
Information about you to process your requests and automatically complete forms for future transactions, including but not limited to your phone number, address, email address, billing information and payment information.
We collect usage statistics about your interaction with the Services, including the full Uniform Resource Locators (URL), the type of Services and courses you requested or provided, comments, domain names, search queries, click data, information and pages viewed and searched for, the order of those pages, length of your visit to our Services, the date and time you used the Services, amount charged, details regarding application of promotional code, methods used to browse away from the page and any phone number used to call our customer service number(s) and other related transaction details, reviews, favorite instructors, special instructor requests, contact information of people you refer to us and other information you provide on the StepUpwards Platform (“Usage Data”).
The StepUpwards Platform may also access metadata and other information associated with other files stored on your computer/ mobile/ any other handheld device. If you permit the StepUpwards Platform to access the address book on your device, we may collect names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Policy or at the time of consent or collection. If you permit access to the calendar on your device, we collect calendar information such as event title and description, your response (Yes, No, Maybe), date and time, location and number of attendees.
Details of your visits to our Website including, but not limited to, traffic data, location data (depending on your device permissions, we may collect your real time information, or approximate location information as determined through GPS, IP address, etc.), weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
We collect information as to how you interact with our Services, preferences expressed and settings chosen. StepUpwards Platform may include advertising services (“Ad Services”), which may collect user activity and browsing history within the StepUpwards Platform and across third-party sites and online services, including those sites and services that include our ad pixels (“Pixels”), widgets, plug-ins, buttons, or related services or through the use of cookies. Our Ad Services may collect browsing information including without limitation your Internet protocol (IP) address and location, your login information, browser type and version, date and time stamp, user agent, StepUpwards cookie ID (if applicable), time zone setting, browser plug-in types and versions, operating system and platform, and other information about user activities on the Platform, as well as on third party sites and services that have embedded our Pixels, widgets, plug-ins, buttons, or related services.
We collect small amounts of information/ data contained in your browser for data analytics. Data analytics help us track your navigation so that we can tailor our offerings to your specific needs. The kind of information that may be stored on our data analytics includes registration data so that a user does not need to re-enter the information every time he/she visits a particular area, user IP address, user ISP details, user browser, devices OS details, Current Latitude, Current Longitude, Device Token, Device Type, App Version, Date registered on, Last Logged in, Logged in Latitude, Logged in Longitude, Active, Suspend Reason, Other Reason and Last updated on. You allow us, agree and acknowledge for aforesaid data gathering and analytics so as to get personalized offerings to your specific needs.
When you visit our Platform we may automatically collect technical information about your computer/ mobile/ or handheld device, including where available, your IP address, network information, device type, operating system type and version, browser type and version, browser language, and unique device identifiers (including, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), (“System Data”). Such information may be used for system administration, and to report aggregate information to our advertisers.
Our site uses certain cookies. A cookie is a small file of letters and numbers that we put on your device, if you agree. These cookies allow us to distinguish you from other users of our Platform, which helps us to provide you with a good experience when you browse our Platform, and also allows us to improve our Platform. You can change your browser/ device settings to reject cookies although this may impair the functionality of the Platform.
StepUpwards and service providers acting on our behalf (like Google Analytics and third-party services) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed above) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.
USAGE OF YOUR INFORMATION
We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized user experience and advertising, and as required by law or necessary for safety and integrity.
We analyze the log files of our Platform that may contain Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring, app crashes, page viewed and exit websites and applications, operating system, date/time stamp, and clickstream data. This helps us to administer the Website, to learn about user behavior on the Website, to improve our product and Services, and to gather demographic information about our user base as a whole.
We use information held about you in the following ways (not limited to):
To ensure that content from our Platform is presented in the most effective manner for you and your Device.
Provide and administer the Services, including to facilitate course participation, issue course completion certificates, display customized content, and facilitate communication with other Users;
For marketing purposes. This may include providing you with information, products or services that you request from us, or which we feel may interest you, and to administer surveys and promotions. Our Business Partners may also contact you regarding your order or for marketing purposes.
To process your payment card details in order to complete any purchase that you make through our Platform (although we only retain the last 4 digits of the card number to confirm last used transaction and assist with tokenized payments).
To process Instructor payments.
To carry out our obligations arising from any contracts entered into between you and us, including processing your requests and orders for courses, products, specific services, information, or features.
To communicate with you about your account including:
Responding to your questions and concerns;
Sending you administrative messages and information, including messages from Instructors, Co-instructors, Training Associates, Learners, Clients; notifications about changes to our Service; and updates to our agreements;
Sending you information, such as by email or text messages, about your progress in courses, rewards programs, new services, new features, promotions, newsletters, and other available courses (which you can opt out of at any time);
Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of the mobile app);
Solicit feedback from you regarding our Services;
Notify you about changes to the StepUpwards Platform and its Services.
Manage your account and account preferences.
To allow you to participate in interactive features of our Service, when you choose to do so.
Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers.
Identify unique Users across devices.
Tailor advertisements across devices, and also to advertise the Services on third-party websites and applications.
Monitor and improve our Services and develop new products, services, and features.
We may permit selected third parties to use your data; we (or they) will contact you by electronic means only (e-mail or SMS) if you have consented to this.
To generate and review reports and data about, and to conduct research on, our user base and Service usage patterns;
As required or permitted by law.
As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our Users, employees, third parties, the public, or our Services.
We may combine the information that we receive from third parties with the information you give to us and information we collect about you for the purposes set out above. Further, we may make anonymous and/or de-identify information collected from you through the Services or via other means as stated above. As a result, our use and disclosure of aggregated and/or de-identified information is not restricted by this Policy, and it may be used and disclosed to others without limitation.
DISCLOSURE OF YOUR INFORMATION
We share certain data about you with Learners, Clients, companies performing services for us, StepUpwards affiliates (including Instructors, Co-instructors, Training Associates, Business Partners, and marketing professionals, and others directly or indirectly involved in providing the Submitted Content and Training Services), our business partners, analytics and data enrichment providers, social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:
With Instructors: We share certain data with Instructors and/or Co-instructors and/or Training Associates for courses you enrol in, or request information about, so they can improve their courses for you and other Learners/ Clients. This data may include things like your age, gender, city, country, browser language, operating system, device settings, the site that brought you to StepUpwards, and your activities on StepUpwards. We will not share your email address with Instructors and/or Co-instructors and/or Training Associates. We also enable and implement Google Analytics on Instructor course pages to track sources of traffic to their courses and optimize their course pages.
With Learners/Clients and Instructors: Depending on your settings, your shared content and profile data may be publicly viewable, including to Learners/Clients and Instructors. If you ask a question to an Instructor and/or Co-instructor and/or Training Associate, your information may also be publicly viewable by other Users depending on your settings.
With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
With Business Partners: We may have agreements with other websites and platforms to distribute our Services and drive traffic to StepUpwards. Depending on your location, we may share your data with these partners.
With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics, we share certain contact information, Account Data, System Data, Usage Data, or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
To Power Social Media Features: The social media features in the Services (like a LinkedIn share button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.
To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law, or in accordance with the rules of the promotion or survey.
For Advertising: If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools, to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising), and to undertake web analytics. Advertisers may also share with us the data they collect about you. Note that if you opt out, you’ll continue to be served generic ads.
For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) in good faith believe that the disclosure is:
Obligated under the applicable law or in order to respond to court order and processes, governmental, or legal inquiry, order, or proceeding;
Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
Required to detect, prevent, or address actual or potential occurrence of identity theft, fraud, credit rating/score reduction, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues, and other illegal acts;
Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of StepUpwards, our Users, employees, members of the public, or our Services.
Responding to claims that an advertisement, posting or other content violates the intellectual property rights of a third party;
We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.
With StepUpwards Affiliates: We may share your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services. We may disclose your personal information to any present or future member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
During a Change in Control: If StepUpwards undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the prospective successor organization during such transition or in contemplation of a transition (including during due diligence). If StepUpwards, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers/users will be one of the transferred assets.
After Aggregation/De-identification: we may disclose or use aggregated or de-identified data for any purpose.
With Your Permission: with your consent, we may share data to third parties outside the scope of this Privacy Policy.
SECURITY
All information you provide to us is stored on our secure servers. Our payment gateway and payment processing are compliant with the payment card industry standard (generally referred to as PCI compliant service providers).
You are advised not to send your full credit/debit card details through unencrypted electronic platforms.
Where we have given you (or where you have chosen) a password, which enables you to use our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to contact us if you suspect any unauthorized access to your account. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
ACCESSING, UPDATING, AND DELETING YOUR PERSONAL DATA - You can access and update your personal data that StepUpwards collects and maintains in the following manner:
To update data you provide directly, log into your account and update your account at any time.
In the event you would like to terminate the account, even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been 1. copied, stored, or disseminated by other Users (including in course comment); 2. shared or disseminated by you or others (including in your shared content); or 3. posted to a third-party platform. Even after your account is terminated, we may retain your data in accordance with applicable law, including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy even after your account has been terminated. You can terminate your account through your StepUpwards login. If you have any issues terminating your account, please contact support@stepupwards.com
To request to access, correct, or delete your personal data, please use our online form(s) or submit these requests by emailing to privacy@stepupwards.com . Please allow up to thirty (30) days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data, including for mandatory record-keeping, and to complete transactions.
YOUR RIGHTS
When you sign up for an account, you are opting in to receive emails from StepUpwards. You can log in to manage your email preferences or you can follow the “unsubscribe” instructions to opt out of commercial email messages, but note that you cannot opt-out of receiving certain transactional and relationship messages (including, administrative confirmations, order confirmations, policy updates, and other updates about the Services), service notices, or legal notices from StepUpwards.
You can change your browser/ device settings to reject cookies, and control whether location or other data is collected and shared. Please note that doing so may impair the functionality of the Platform.
If you wish to withdraw your consent for the use and disclosure of your personal information in the manner provided in this Policy, please write to us at privacy@stepupwards.com for deleting such information. Please note that such request may take up to thirty (30) working days, after which we will not use your personal data for any processing unless required by us to comply with our legal obligations. We may not be able offer you any or all Services upon such withdrawal of your consent.
Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Certain third-party platforms connected with the StepUpwards Platform may use certain data as detailed above to provide you a better user experience on the Platform. These third-party services are including but not limited to Google Display Network ads, and Google Analytics. Please visit the relevant third-party website(s) to customize and/ or opt-out of such data usage.
Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings specific to that platform.
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@stepupwards.com
If you come across any abuse or violation of this Policy, please report to privacy@stepupwards.com
OUR POLICY CONCERNING MINORS
We recognize the privacy interests of minors and encourage parents and guardians to take an active role in their children’s online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services, as per applicable law in their country of residence may set up an account and enroll in appropriate courses through their parent or guardian. Individuals younger than the required age for consent to use online services may not use the Services offered by StepUpwards Platform. If we learn that data has been collected from a minor, we will take reasonable steps to delete it.
Parents/ guardians who believe that StepUpwards may have collected personal data from a minor can submit a request to privacy@stepupwards.com for removal of such data.
REPRESENTATIONS
StepUpwards wholly owns the stepupwards.training domain ("Domain") and for the sake of convenience custom email addresses of the Domain are used by Business Partners to facilitate the services provided by StepUpwards. Any communication or representation on behalf of StepUpwards from the Domain is at the sole discretion of the Business Partner, and not binding on StepUpwards. Report to support@stepupwards.com for any clarifications or issues.
No communication or representation is binding to StepUpwards unless accompanied with due authorization for such specific representation or undertaking.