Your Consent

Your use of the Platform and the Services and the processing of information about you for the purposes providing our Services are based on your consent. Any processing of your personal data in connection with your use of the Services is based on your explicit consent. Please note that you can always close your account and withdraw your consent, although this may affect our ability to provide you, our Services.

In certain circumstances, we are required to obtain your consent to process your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent. The Data Protection Laws require that consent should be freely given, should be specific and unconditional and be based on informed and unambiguous indication of the individual’s wish by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. In plain language, this means that: (i) you have to give us your consent freely, without us putting you under any type of pressure; (ii) you have to know what you are consenting to – so we will make sure we give you enough information; (iii) you should have control over which processing activities you consent to and which you don’t; and (iv) you need to take positive and affirmative action in giving us your consent. We will obtain your consent in a document when the subscribe to our Services or provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion. We may also provide for such other methods by which the above requirement can be met. As we have mentioned, you have the right to withdraw your consent to these activities.

Performance of Contract

Novatr offers a technology-based platform that enables its learners to purchase or subscribe to the Courses offered by Novatr through its Platform and enhance their knowledge and skills and also get placed with reputed employers and our User contractual obligation towards our Subscribers is based upon terms and conditions published by Novatr from time to time on its Platform. These terms and conditions set out the essential provisions that govern: (i) its relationship with the Subscribers/Users and clearly define and document our rights, responsibilities and obligations; (ii) a User’s access to and use of the Platform and the Services; and (iii) the transactions and activities undertaken by a User pursuant to the Services. We may have to process your information to perform our contractual obligations towards you. For example, where you have purchased a subscription from us and we need to use your contact details and payment information in order to process your order and deliver your subscription.

Legitimate Interests

If you are a Subscriber and have subscribed to our Courses and Services, we feel its reasonable to expect that you are happy for us to collect and use personal data about you to help you provide our Courses and Services. We need to do these things so that we can function as a business, and provide and help you with availing our Courses and Services.

The processing of information about you as part of our Services is based on our legitimate interest to enable you to effectively subscribe and avail our Courses and Services.

Simply put, our processing of information about you for business operations purposes is based on our legitimate interest in operating our business in an efficient and appropriate manner. We have to make sure our business runs smoothly, so that we can carry on providing Services to our Subscribers/Users.

Establishing, Exercising or Defending Legal Claims

Sometimes, it may be necessary for us to process personal data in connection with exercising or defending legal claims. The Data Protection Laws allow this when the processing "is necessary for the establishment, exercise, or defense of legal claims, or whenever courts are acting in their judicial capacity." This may arise, for example, when we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

Communications

In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing your information.

• Website Contact Forms and Phone Number Collection

  When you provide your phone number through our website contact forms, the following applies:

  • If phone number collection is mandatory: "By providing a telephone number and submitting the form you are consenting to be contacted by SMS text message. Message and data rates may apply. Reply STOP to opt out of further messaging."
  • If phone number collection is optional: We consider voluntary provision of your phone number as consent to receive communications from us via that number.

• Third-Party Data Sharing Restrictions

  While we may share certain personal information with third parties as described in this Privacy Policy, we specifically exclude SMS/text messaging consent and phone numbers collected for messaging purposes from such sharing. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All text messaging originator opt-in data and consent will not be shared with any third parties.

Identity & Contact

When you visit the Platform, you can browse without submitting any personal information about yourself. We will, however, receive and store some non-personally identifiable information about your visit, as described below. In order to participate in certain functionalities, you may be asked to provide personally identifiable information. Personally identifiable information is information that can identify you, including, for example your name or email address. It will always be your choice, or the choice of anyone acting for you, to provide personally identifiable information.

When you subscribe to a Course or register with us (or create an Account on the Platform and use the Services), we collect information that you provide voluntarily during your subscription or registration or creation and use of your Account. This includes information such as:

• Name (first, middle, and last names);
• Profile Name;
• Username;
• Email;
• Gender;
• Mobile/Contact Number; and
• Password.

In addition to the above, you may also choose to add more details and information about yourself to your Account to further build your profile. These may include the following:

• Photograph/profile picture;
• Location;
• City;
• State;
• Physical/postal address;
• Education;
• Occupation/Profession;
• Name of your organization/employer;
• Title/job title/designation;
• Job functions;
• Work experience;
• Expertise;
• Skills;
• Endorsements;
• Achievements;
• Language preferences; and
• Self-description.

Please note that you do not have to provide additional information to build your profile and it is solely at your choice to do so, including whether or not to include any personal information. We collect information that only you choose to give us. We strongly recommend you not to post or add personal data to your profile that you would not want to be publicly available or visible to others.

Please be aware that your profile is publicly available and visible to all Users of the Platform. You can however control how and what appears on your profile.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Transaction Data

This includes details about payments to and from you and other details of Services you have purchased from us.

Communications

If you contact us for customer support or otherwise communicate with us, we collect the content of these communications.

Location Information

When we provide our Services, we may ask you for, access, or track geo-location-based information from your device while using our Platform or downloading or using our applications or other functionality. If you choose to engage with these Services, we will receive certain information about your location, which may include country, state, city, or more specific location information, in order to provide you with the requested Services including geographically relevant features, offers, applications, and application recommendations.

Technical & Usage Data

When you access the Platform and/or use the Services, certain information is stored in our servers automatically. The information captured automatically includes the following:

• Your login information;
• Data about the pages you access within the Platform;
• Your choices and behaviour;
• Browser type and version;
• Time zone setting;
• Browser plug-in types and versions;
• Your internet protocol (“IP”) address;
• Device identity or unique identifier;
• Device type;
• Geo-location information (subject to your consent);
• Device and connection information;
• Operating system;
• Technology on the devices you use to access the Platform;
• Mobile network information;
• history of your visit, statistics on page views; and
• Traffic to and from the sites, referral URL, ad data, and standard web log data and other information.

As you interact with our Platform, we may automatically collect technical data about your equipment, browsing actions and patterns. We may also collect information about your visit including the pages you visited, frequency of your visits, what you searched for, length of visits and methods used to browse away from the page. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

We also collect anonymous information through our use of cookies and web beacons.

The Platform uses persistent and session cookies and other similar technologies to offer you a personalised experience and to remember your browsing preferences, including your log in details and choice of language. Cookies are stored primarily to ensure that in the event you return to the Platform, it shall personalise your browsing, including, enabling you to be logged on the Platform automatically. This information may, where permitted by Applicable Law, also be combined with other information we hold about you. The cookies are uniquely assigned to you and can only be accessed by your web page server in our domain. You can disable our cookies or all cookies through your browser settings. Upon the beginning of each of your visits to the Platform, the Platform also provides the choice to turn off all cookies which are not strictly necessary for the provision of Services. Please be advised that disabling cookies through either method may impact many of the Platform’s features. In addition to cookies, we and/or our third-party advertising partners may use technologies that help us better manage and analyse content.

Third party platforms

If you register for or log into the Platform or Service using a third-party platform (like Google), they will furnish certain information to us to facilitate your account creation or log-in with us

Technical service partners

We sometimes receive information about you from technical service partners.

Providing Services

We may use your personal data to fulfil a contract or take steps linked to a contract and to provide our Services to you. We may use your personal data to: (i) administer the Platform; (ii) improve your browsing experience by personalising the Platform; (iii) enable your use of the Services available on the Platform; (iv) supply to you the Services purchased via the Platform; (v) send statements and invoices to you, and collect payments from you; and (vi) send you email notifications which you have specifically requested.

We may also use your personal data to: (i) review your activity on our Services to detect spam or activity that poses a risk to our community or the public; (ii) analyse your log data and device information to identify and investigate suspicious behaviour or violations of our policies or Terms; (iii) conduct any verification, as appropriate; (iv) conduct analytics and research on who is using our Services and what they are doing; (v) improve our products and services and those of our group companies and offer new features; (vi) create aggregated or de-identified information that cannot reasonably be used to identify you (we process, maintain, and use this information only in a de-identified fashion for the purposes of this Privacy Policy and will not attempt to re-identify such information).

Communications & Administrative Support

We may use your personal data to:

• To communicate with you in relation to the provision of the contracted Services;
• To provide you with administrative support such as account creation, security and responding to issues;
• To provide an improved user experience;
• to provide you with surveys, information about our offers and promotions, related to our Services; and
• Deal with enquiries and complaints made by or about you relating to the Platform

Consent

Where you have given your express permission to receive marketing communications, we may use your personal data to send you newsletters, surveys, information about our awards and events, examinations, offers and promotions, related to our services which may be of interest to you.

Where required by law

We may also process your personal data if required by law or to comply with applicable laws and regulations, including responding to requests by government or law enforcement agencies or for the prevention of crime or fraud.

Marketing

We may use personal data to send direct marketing communications about our products and services that we feel you will be interested in. This may be in the form of email, or by SMS or any other electronic message. We may also send to you our newsletter and other marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, where you have specifically agreed to this. You can always choose to opt out of receiving direct marketing as all our marketing communications include unsubscribe links, alternatively, you can contact us to stop further communications. We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do this.

Statistical Purposes

We may use personal data for statistical purposes such as analysing the performance of our sites and apps and to understand how visitors use them. We may look at what you have viewed on our sites and apps and what services you have bought to better understand what your interests and preferences are.

Security of the Platform

We may use personal data to maintain the security of the Platform and our systems and networks. For example, we may process information about you when investigating suspicious activity on our sites, systems and networks.

Employees of Novatr

We may share your personal data with the employees, personnel and members of staff within Novatr when you provide Novatr with your information. We take all reasonable steps to ensure that our employees, personnel and staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a business need to know it.

Third Parties

We may also share your personal data with trusted third parties including:

• Hiring Partners, contractors, service providers, vendors, and suppliers contracted to us in connection with the provision of our products and services; and
• External and internal lawyers and/or specialist advisors and consultants.
• SMS/text messaging service providers and telecommunications carriers who assist in delivering our text messaging services

Law Enforcement Agencies & Prevention of Unlawful Acts

We may disclose your personal data:

• to the extent that we are required to do so by law;
• to a court or governmental authority based on an order or direction from such authority;
• with the police or other law enforcement agencies in the event of a crime or offence or prevention of or detection or investigation of a crime or offence or cyber incidents;
• in connection with any legal proceedings or prospective legal proceedings for prosecution or punishment of offences;
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
• to prevent bodily harm to any person;
• to protect the safety, rights, or property of any person or the public;
• to protect the rights of anyone else; and/or
• to combat societal harms.

Successors

We may reveal your personal data to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with our privacy policy. If we were to engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Privacy Policy, we would share your information with a party involved in such a process (for example, a potential purchaser).