PRIVACY POLICY OF CDP360

Introduction:

(a) CDP360 Technologies Pvt Ltd, (hereinafter “CDP360” which expression shall unless otherwise provided, include it’s successors and assigns), having address at 4, Metrohm India Ltd, Siri Towers, Fourts Ave, Annai Indira Nagar, Thoraipakkam, Tamil Nadu 600 097 values your trust and understands the importance of your privacy.

(b) In order to respect that trust, CDP360 adheres to ethical standards in collecting, using, and protecting any information you provide. CDP360 empowers schools in actively participating in the digital age by partnering with them to help their students prepare for their competitive exams (NEET, JEE and other entrance/competitive exams)

(c) This privacy policy (hereinafter “Privacy Policy”) governs your use of the application software CDP 360 (‘CDP-App)

(d) This Privacy Policy is intended to assist you in understanding how we collect and use the Personal Information you provide to us and to assist you in making informed decisions when using CDP-App.

(e) Please read the Privacy Policy with due care before using the CDP-App. Your use of the CDP-App, or services in connection with the CDP-App or registrations with us through the internet accessed in any form shall signify your acceptance of this Privacy Policy and your agreement to be legally bound by the same. If you do not agree with the terms of the Privacy Policy, we advise you not use the CDP-App.

Interpretation:

The titles and subtitles used in this Privacy Policy are for convenience only and are not to be considered in construing or interpreting this Privacy Policy. In this Privacy Policy, unless the context otherwise requires: (i) any pronoun used in this Agreement shall include the corresponding masculine, feminine or neuter forms, and the singular form of nouns, pronouns and verbs shall include the plural and vice versa; (ii) “including” (and with correlative meaning “include”) means including without limiting the generality of any description preceding or succeeding such term and shall be deemed in each case to be followed by the words “without limitation”; (iii) the words “herein,” “hereto,” and “hereby” and other words of similar import in this Privacy Policy certificate or other document made or delivered pursuant hereto unless otherwise defined therein.

Definitions:For the purposes of this Privacy Policy:

“Account” means a unique account created for user to access our CDP360 or parts of

“Application” shall mean the CDP-App.

“CDP-App” shall mean the Application Software.

“Data Protection Rules” shall mean the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011

“Information” shall mean “Personal Information” and/or, “Sensitive Personal Data or Information”

"Payment Gateway” is a service that allows merchants to accept payments from customers online. It is a secure intermediary between the merchant's website or point-of-sale system and the customer's bank. When a customer makes a purchase, the payment gateway encrypts the customer's payment information and sends it to the customer's bank for authorization. If the payment is authorized, the gateway sends the funds to the merchant's account.

“Personal Information” and/or, “Sensitive Personal Data or Information” shall have the meaning ascribed to it under the Data Protection Rules.

Service refers to the courses offered in CDP-App.

Service Provider means any natural or legal person who processes the data on behalf of CDP360 including but not limited to third-parties employed by CDP360 to facilitate or provide the Service, on behalf of the Company, to perform services related to the Service or to assist CDP-360in analysing how the Service is used.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

You/ User means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

User Provided Information

The data we collect when you down load, register and create your account depends on the context of your interactions with CDP360. The data we collect can include the following:

(a)Name and contact details- We collect your first and last name, email address, postal address, phone number and other similar contact details.

(b)Credentials- We collect your username and password when you create your personal account on our websites.

(c)Demographic data- We collect data about you such as your date of birth, parent/guardian name, photograph, address, age, gender, country, blood group, citizenship, and preferred language.

(d)Educational and professional background- We collect data about your employment history, education history and possibly your standardized test scores.

(e)Videos and pictures- Photographs or video recordings may be taken during our physical events. We may use the visual or video captures of your person on our websites or promotional material.

(f)Other information- Any other information that you may provide to us through feedback forms or through the "Contact Us" feature on our Sites.

(g)Information Collected by Automated Means- When you visit our websites, we may collect certain information by automated means such as cookies, web beacons and web server logs.

(h)The information we may collect in this manner includes:

(i)IP address

(ii)IP Unique device identifier

(iii)IP Browser characteristics

(iv)Device characteristics

(v)IP Operating system

(vi)Language preferences

(vii)IP Referring URLs

(viii)IP Information on actions taken on our websites

(ix)IP Dates and times of visits to our sites and other usage statistics

(x)IP Location data

(i)Your Usage Data and your ward's educational interests;

(j)Transaction-related information, such as when you make purchases and respond to any offers. However, financial information including but not limited to bank account or credit card or debit card or other payment instruments details are collected by Payment Gateways through whom the subscription payments are processed. CDP360 does not store or retain any such financial information;

(k)Information you provide us when you contact us for help;

(i)Information you enter into our system when using the CDP-App, such as while asking doubts, participating in discussions and taking tests;

(ii)Information regarding your location- We use this information to provide features of our Service, to improve and customize our Service. The information may be uploaded to the CDP360's servers and/or a Service Provider's server or it may be simply stored on your device. You can enable or disable access to this information at any time, through the settings on your device;

(iii)The said information collected from the users could be categorized as “Personal Information” and/or, “Sensitive Personal Data or Information” Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (the “Data Protection Rules”) and shall collectively be referred to as 'Information' in this Privacy Policy.

Automatically Collected Information

(a)Information you enter into our system when using the CDP-App, such as while asking doubts, participating in discussions and taking tests;

(b)All telephone conversations between you, your ward, and our instructors, representatives, or agents are taped for training and quality assurance purposes. You or your ward will not receive access to these recordings for any reason. By accepting this privacy statement, you (on your own behalf and/or that of your ward) give us permission to collect, record, and use the personal data of your ward for the aforementioned uses.

(c)CDP360 follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this as a part of hosting services analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analysing trends, administer the site, track user's movement on the website, and gather demographic information.

How do we use the information provided

(a)We may occasionally contact you using the information you provide, to deliver the Services, critical information, and necessary notices,. When we require additional details that permit us to identify you personally (Personal Information) or get in touch with you, we will notify you.

(c)As long as the login/account access credentials match yours, we won't make any distinctions regarding who is utilizing the device to access the CDP-App or Services. You must be logged in with your own credentials in order to use the CDP-App to its fullest potential and allow for the accurate gathering of your information on the Application. Unless indispensable, we will, at all times, provide the option to you to not provide the Personal Information or Sensitive Personal Data or Information, which we seek from you.

(c)CDP 360, will send email notices or contact you to communicate about our Services, products and benefits, as they are considered an essential part of the Services you have chosen. We may disclose information:

(i)as required by law, such as to comply with a summons, or similar legal process;

(ii)to enforce applicable terms of use provided in CDP-App, including investigation of potential violations thereof;

(iii)when we believe in good faith that disclosure is ncessary to protect our rights, protect your safety or the safety of others, investigate fraud, address security or technical issues or respond to a government request;

(iv)with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this Policy;

(v)For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.

(vi)If CDP360 is involved in a merger, acquisition or asset sale or any other business transaction, your Personal Information or Sensitive Personal Data or Information may be transferred. We will provide notice before Your Personal Information or Sensitive Personal Data is transferred and becomes subject to a different Privacy Policy.

(vii)to protect against imminent harm to the rights, property or safety of the Application/Website/ or its users or the public as required or permitted by law;

(viii)with third party service providers in order to personalize the Application/Website/Services/products for a better user experience and to perform behavioural analysis;

(d)We will share your information with third parties only in the ways that are described below in this Policy. Third parties provide certain services which we may use to analyse the data and information to personalize, drive insights and help us better your experience or reach out to you with more value added applications, products, information and services. However, these third party companies do not have any independent right to share this information. We do not sell, trade or rent your Information to any third party unless we have been expressly authorized by you either in writing or electronically. We may at times provide aggregate statistics about our customers, traffic patterns, and related site information to reputable third parties, however this information when disclosed will be in an aggregate form and does not contain any of your Personal Information or Sensitive Personal Data or Information.

(e)Any portion of the information containing Personal Information or Sensitive Personal Data or Information relating to minors provided by you shall be deemed to be given with the consent of the minor's legal guardian. Such consent is deemed to be provided by your registration with us.

(f)When you share personal information or otherwise interact in the public comments/review column within the CDP-App with other users, such information may be viewed by all users and may be publicly distributed outside.

(g)We may disclose your Personal Information or Sensitive Personal Data or Information for any other purpose with your consent.

Option to withdraw consent

Further, you shall, at any time while using the Application, also have an option to unsubscribe or “opting out” to any of our service at any point of time by sending an email to unsubcribe@cdp360.org or by reaching out through the contact details provided in the end this policy. In such event, however, the CDP360 fully reserves the right not to allow further usage of the Application or provide any Services/products thereunder to you.

Access to your Personal Information

We will give you the tools you need to check that your personal information is accurate and up to date. If you have created a user profile, we will make it easy for you to access and edit it using our application. To prevent the exposure or disclosure of your password to other parties, we maintain reasonable security precautions.

Security

Our main focus is preserving the privacy of your information. We provide physical, electronic, and procedural safeguards to protect Information we process and maintain. For instance, we only allow authorized personnel who require access to this information to operate, develop, or enhance our Application. Please be advised that no security system can completely thwart security breaches, despite our best efforts to provide reasonable protection for the information we process and keep.

How Long Do We Retain User Data?

We retain user data while an account is active and for at least two years afterwards. Depending on the needs of the business and the law, we might change this procedure. For instance, if it's necessary to follow the law or voluntary norms of conduct, we may extend the retention duration for particular data. If it's necessary to free up storage space, we may reduce the retention term for specific categories of data, unless doing so is forbidden.

Log information

When you access our Website, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, internet protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Cookies

We send cookies (small files containing a string of characters) to your computer, thereby uniquely identifying your browser. Cookies are used to track your preferences, help you login faster, and aggregated to determine user trends. This data is used to enhance our services, such as by adding more content in topics that are more popular with users. The default setting for most browsers is to allow cookies, but you can change this setting to make your browser reject all cookies or warn you when one is being sent. If you disable cookies, some of our features and services might not work properly.

User communications

When you send an email or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services.

User Consent

We think that each user of our application should be able to give their informed consent before supplying any information that is necessary for using the application. You expressly consent to the collection, processing, storage, disclosure, and handling of your information by us as described in this Privacy Policy as it is currently written and as we may alter it by registering with us. Processing your information in any way, including, but not limited to, collecting, storing, deleting, using, combining, sharing, transferring and disclosing information, all of which activities will take place in India. If you reside outside India your information will be transferred, processed and stored in accordance with the applicable data protection laws of India.

Changes to This Privacy Policy

As CDP360 evolves, our Privacy Policy will need to evolve as well to cover new situations. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page. You are advised to review this Policy regularly for any changes, as continued use is deemed approval of all changes

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

(a)The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.

(b)The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

(c)The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

Contact Information

Our Grievance Officer shall undertake all reasonable efforts to address your grievances at the earliest possible opportunity.

You may contact us at:

Grievance Officer- Anu Kumaran at anu@cdp360.org. in case of any queries.,

CDP360 Technologies Pvt Ltd, Plot 3 & 4 Fourrts Avenue, Annai Indra Nagar, Thoraipakkam, Chennai – 600097.

©2023, CDP360 Technology Pvt. Ltd. All Rights Reserved