(last updated January 1, 2023)
Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
WHO IS THIS POLICY ADDRESSED TO?
For the purpose of data protection legislation including the EU General Data Protection Regulation ('GDPR'), the data controller of your personal data is Empass Learning Private Ltd registered at G-72, Second Floor, South City-II, Gurugram - 122018, Haryana, INDIA (an MCA registered company with CIN U72500HR2017PTC070286 and known as Empass).
When we refer in this policy to 'you', we are referring to a customer of our services, or a person visiting and or using our website, mobile apps.
If you are a contact on our list and have not yet used any services offered by Empass and would like to cease receiving emails from us, please unsubscribe directly using the unsubscribe link in the email message, or contact the customer directly.
We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. We will make readily available to customers information about our policies and practices relating to the management of personal information.
We will only retain personal information as long as necessary for the fulfillment of those purposes. We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
WHAT INFORMATION DO WE COLLECT?
We collect information from you when you register on our site, mobile apps, subscribe to our newsletter, login with your social media accounts or fill out an online form.
When registering on our mobile app or our website, as appropriate, you may be asked to enter your name, e-mail address, demographic information, mailing address, mobile and telephone number, employment information and credit card information.
WHAT DO WE USE YOUR INFORMATION FOR?
Any information we collect from you may be used in one of the following ways:
Should you decide, at any time after subscription, that you would like to unsubscribe from receiving future emails or app updates, we have included a detailed unsubscribe instructors at the bottom of each email.
With the usage of the Empass website, mobile apps on iOS, Android or other devices, it is explicitly understood that the best method of usage for any mobile app is performed over a Wi-Fi connection. Although you may use the app with your mobile data plan, your wireless carrier may charge you fees if your mobile data plan is exceeded because of your use of the app(s) when not on Wi-Fi. No matter which method you use to connect to our mobile app and platform, the apps and services we provided come with the disclaimer of "use at your own risk" and services are provided "as-is."
With respect to capturing your demographic information and/or text, voice, video responses on mobile or web apps as well as through contact forms or contest forms in the app or website, Empass Learning will NOT sell your demographic information to third parties or use your personally identifiable information for any other purpose for what the information is intended when it is requested.
Any personally identifiable information (PII) you submit through our web site(s), or mobile apps, are used solely for assessments, quizzes, contests and digital promotion purposes.
On Contact Us forms or request for demo forms, personally identifiable information is only used internally to disseminate your message to the correct department so that the message you submit to reaches the proper destination. For personally identifiable information you submit via the mobile apps or our online web site(s), the demographic information captured is only stored internally or visible to clients who sponsor the specific contests, learning courses and job opportunities to you under a paid and contracted relationship with Empass Learning.
On registration you agree to:
You may remove yourself from the promotional mailer, email and mobile database and make yourself non-searchable by writing to us on firstname.lastname@example.org
HOW DO WE PROTECT YOUR INFORMATION?
We implement variety of security measures to maintain the safety of your personal information when you register, play a game, buy a product or service from our mobile apps or websites to safeguard your personal information.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted before being passed onto any 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.) will remain secure and not be shared or used anywhere without your permission.
We might use other payment providers in future for international currency payments and the chosen provider will undergo rigorous checks to ensure that the security of your information and money transacted is handled professionally and suitably.
Our website uses retargeted advertising provided by Facebook and Google. As a result of this retargeting, you may see ads for our services on other sites such as Facebook. This happens in one of two ways:
One way is that our retargeting provider will read a cookie that is already in your browser, or they will place an anonymous cookie or 'pixel' in your browser when you visit our site. This can only happen if your browser is set to let it happen - you can control your settings in your browser to stop this.
The other method of retargeting is to use your email address to match Empass ads to you when you browse other sites. This involves us sharing your email address with Facebook and Google. This form of retargeting is generally used to update you on new functionality added to the Empass platform.
Conversely, we also use Facebook to ensure that we don't present some Empass ads to our existing customers. Again, this involves our sharing your email address with Facebook.
LOCATION OF YOUR DATA
Your PII and data is stored on the secure servers of Amazon Web Services ("AWS"). We don't, under any circumstances, sell or share your data. If someone complains or contacts us, only then will we respond to that person. Only you, and our authorised employees, have access to view your marketing lists.
You may export (download) your PII data from Empass at any time. We'll only ever use and disclose the information in your data for the reasons listed in this section or in the section entitled "How we use your personal information" above.
We will rarely use or disclose the information in your personally identifiable data to send our own informational and promotional content. We may also be required to disclose it to law enforcement or regulatory bodies. We will only do so if legally required.
We may conduct analysis on your use of the service and the results generated by your emails sent by means of the service. This analysis is conducted solely on an aggregated and anonymised basis.
Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.
If you prefer, you can choose to have your computer want you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if your turn your cookies off, some of our services may not function properly.
THIRD PARTY LINKS
Our service provides you with links to other, third party, sites. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Third parties provide certain services available on Empass Learning's mobile apps and websites on its behalf. Empass Learning may provide information, including Personal Information that it collects on the Web or through its mobile apps to third-party service providers to help us deliver programs, products, information, and services. Empass Learning also works with service providers to maintain its Website, message services and email campaign lists. Empass Learning will take reasonable steps to ensure that these third-party service providers are obligated to protect Personal Information on its behalf.
INTEGRATIONS AMAZON SES and Other 3rd PARTIES
We can additionally integrate Empass with other third party apps, websites or other services and will ensure that the privacy and security of your data is never compromised.
RETENTION OF YOUR PERSONAL INFORMATION
The periods for which we keep your information depend on why your information was collected and what we use it for. We will not keep your personal information for longer than necessary for our business purposes or for legal requirements.
Some account information will be held for 6 years from your last sign in or use of the service. Logs of your use of the services will be deleted within 12 months of your last sign in or use of the service.
We will keep your contact information, emails and lists for 12 months after your last sign in or use of the service, in case you decide to use our services again. We may contact you about our services during this time (unless you have asked us not to contact you for marketing purposes).
LEGAL BASIS FOR PROCESSING
We are required to state the legal basis on which we undertake processing of your personal information. We will only use your information where:
Any consent you provide may be withdrawn at any time by emailing us.
You have the right to request access to personal data that we may process about you.
You have the right to require us to correct any inaccuracies in your data, free of charge. If you wish to exercise this right, you should:
You can access, correct, update or request deletion of your personal information at any time, either through your online account or by contacting us.
Deletion of data will be carried out on the understanding that removal of some information (e.g. email address) during an active membership term may negatively affect your ability to use the Empass service.
We cannot delete any invoices, as these are kept for tax purposes.
You can request that we restrict processing of your personal information, object to processing of your information or request portability of your personal information. For these requests please contact us. We will comply with your request where your rights have been exercised in accordance with applicable laws.
If we have collected and processed your personal information with your consent, then you can withdraw that consent at any time. To be clear, we may still continue to process your data if we have a different legal basis for doing so (for example, if we are required by law to do so, or we need to do so for the purposes of fulfilling our obligations to you under our terms and conditions of service).
You also have the right to ask us to stop processing your personal data for direct marketing purposes. You can do this through your Empass dashboard or via email. If you wish to exercise this right via email, you should:
CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE