PRIVACY POLICY

We understand that Your privacy is important. This Privacy Policy (“Privacy Policy”) describes how MeritTrac Services Private Limited (“MeritTrac”) collects, uses, shares and otherwise processes Your personal information in accordance with Information Technology Act, 2000 (as amended) and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. We encourage You to review this Privacy Policy before disclosing any personal information. This Privacy Policy applies to MeritTrac’s website, social media, email, chat (“Site”).

1. Notice

1.1 This Privacy Policy is to inform You ("You/Your") of the procedures regarding how we collect, use, share and retain Your Personal Information ("PI") or Sensitive Personal Data or Information ("SPDI") that we receive from You. We recognize the importance of PI including SPDI provided to us by a natural person and we collect no personal information about You unless You affirmatively choose to provide that information to us. By interacting with us regarding our services or enquiring about our programs or during registration for the courses or by providing us with Your information, You consent to the collection, transfer, storage, and processing of Your personal information as stated in this Privacy Policy. We do not give, share, sell, or transfer any personal information to any unrelated third party. In this Privacy Policy "we" and "us” and “our” refers to MeritTrac, our vendors and third-parties who provide goods and services. Please read the information provided in our products, services, websites, applications and software for additional details.

1.2 Occasionally, we may use certain information that we have collected to send You information about products or services offered by us.

1.3 If You are providing PI and SPDI and are not a resident of India, Your country's laws governing data collection differ from those in India, in particular, India may not provide the same level of protection as those in Your own country. By providing information to us, You are transferring Your personal data (including PI and SPDI) to India, and You consent to the transfer to, retention of and processing of Your data in the India.

1.4 For the purpose of providing services to You, we may transfer Your personal data (including PI and SPDI) to different jurisdictions, including jurisdictions that may not provide the same level of data protection as Your home country. When You submit PI and SPDI to us You are accepting that such data can be transferred across borders and applicable privacy laws of such territory shall apply.

2. Personal Information we collect

2.1 PI for the purposes of this Privacy Policy, refers to any information that relates to a natural person which either directly or indirectly, in combination with other information available or likely to be available, is capable of identifying such person. The specific kind of information collected will depend on the products or services used by You. The following are examples of the type of PI that may be collected such as name, date of birth, citizenship, biometric data such as fingerprints, voice recognition, captured live images through the web camera enabled tests, phone number, residential/mailing address, email address, demographic information.

2.2 SPDI for the purposes of this Privacy Policy, shall be the same as defined in the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the "SPDI") Rules, as amended from time to time, such as:

(i) Password;
(ii) Financial information such as bank account or credit card or debit card or other payment instrument details;
(iii) Physical, physiological and mental health condition;
(iv) Sexual orientation;
(v) Medical records and history;
(vi) Biometric information;
(vii) Any detail relating to the above clauses as provided to us for providing services; and
(viii) Any of the information received under any of the above clauses by us for providing services.

Provided that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Information for the purposes of this Privacy Policy.

2.3 When You visit the Site, we automatically collect certain information about Your device, including information about Your web browser, IP address, time zone, and some of the cookies that are installed on Your device. Additionally, as You browse the Site, we collect information about the individual web pages that You view, and information about how You interact with the Site. We refer to this as “Device Information”.

3. Purposes of Collecting and Processing of Personal Information

3.1 MeritTrac will ordinarily collect PI and SPDI that it believes is necessary for any purpose connected with a function or activity necessary to deliver, promote or market services or to carry out primary business functions and/or activities, comply with applicable regulations or in capacity as a counterparty to agreement with individuals. Ordinarily, MeritTrac will collect such PI and SPDI about You when You provide it or You have consented to provide the information, as applicants, through online registration forms, through assessment, events, survey respondents, visiting the Site. To the extent that information requested is not required for Your participation in a given MeritTrac product/service, You will be told which information is optional. Should You fail to provide optional information certain MeritTrac products/services or features of the Site may not be available to You. In general, we would be collecting/handling/storing /using or transferring Your PI and SPDI for the following, including but not limited to:

(a) providing agreed services to You;

(b) performing administrative functions; and

(c) complying with legislative and regulatory requirements.

3.2 MeritTrac may share PI and SPDI with third parties for legitimate business purposes, including for the following reasons or in the following circumstances:

1. to vendors or third-parties who deliver or provide goods and services or otherwise act on behalf of or at the direction of MeritTrac, which third parties include, for example human proctors, partners, third party event hosting sites, other third parties who may provide services on web sites that are accessible from links on one of our Site; bank/credit card/credit providing companies processing payment; to MeritTrac employees, officers and directors, service coordinators and also to MeritTrac partners. These parties shall use Your PI and SPDI only for the specific purpose for which we supply the PI and SPDI to them;
2. if You are attending an event as attendee or speaker, certain of Your information will be included in the event calendar which may be publicly disclosed, and may also be shared with third party event sponsors and exhibitors;
3.  if You are a part of our career counselling services on behalf of our clients, Your information may be accessible to potential employer or recruiters. 
4. to those who wish to determine if You have a  valid certification of any assessment, Your certification status will be shared with those who inquire;
5. to investigate potentially fraudulent or questionable activities or transactions;
6. may use Your PI on an aggregate basis to provide third parties with information, such as to help us develop new features and content for the Sites, and to provide and other with aggregate information about our users and the usage patterns of the Sites.

 3.3 Our Sites, products and applications and services may contain links to other third-party websites, products and services of interest (partner networks, payment gateways, vendor website). For example, MeritTrac may link to a third party who is assisting in or providing certain services as part of product. MeritTrac has no control over the content displayed on such sites, nor over the steps, that are taken by such sites to protect the privacy of Your information. Once You have used these links to leave our Site, You should note that we do not have any control over that other websites. Therefore, we will not be held responsible for the protection and privacy of any information which You provide whilst visiting such other third party websites and such third party websites are governed by their own privacy policies contained therein.

3.4 The PI and SPDI collected shall be used for the purpose for which it has been collected.

3.5 We may also use Your PI and SPDI to tailor Your experiences at our Sites, to compile and display content and information that we think You might be interested in, and to provide You with content according to such preferences.

3.8 While providing PI and SPDI of another natural person (particulars of spouse, children or parents) to MeritTrac, please ensure that You have the necessary concurrence of that natural person.

4. Disclosure of Personal Information

4.1 MeritTrac will not use or disclose Your PI and SPDI to a third party otherwise than for the purposes set out in this Privacy Policy or unless the disclosure is necessary for compliance of a legal obligation or where it is agreed to in the contract with You or as consented by You.

4.2 Mandatory disclosures and legal claims: We share personal information in order to comply with any court order or other legal process, subpoena, to comply with a request from our regulators, governmental request or any other legally enforceable demand.  We also share personal information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

5. Access to Your Personal Information

5.1 You may review and correct or revise the PI and SPDI You have provided to us for the purpose of ensuring the said information is accurate. MeritTrac shall not be responsible for the authenticity of the information You have supplied to it or to any person acting on its behalf.

5.2 You have the option not to provide MeritTrac with the PI and SPDI sought to be collected. You also have the option to withdraw the consent given earlier, provided it is sent to us in writing. In the event PI and SPDI which MeritTrac deems necessary for providing You with any service is not provided or if consent is withdrawn subsequently, MeritTrac reserves the right to not provide You with such services/benefits/amenities.

5.3 You have the right to communicate to us any changes to Your PI and SPDI or privacy preferences at any time.

5.4 You may choose not to receive promotional communications from us by clicking on the unsubscribe link or contacting us as specified in the “Contact Us” section below.

6. Security and Retention of Personal Information

6.1 The security of Your PI and SPDI is important to us, however, no method of transmission over the internet or method of electronic storage is 100% secure. In order to prevent unauthorized access or disclosure, we have put in place suitable/reasonable physical, electronic and managerial procedures as per applicable industry practices to safeguard and secure the personal information we collect from You. We regularly test our website, data centres, systems, and other IT assets for security vulnerabilities to address the same, however, we cannot guarantee its absolute security.

6.2 The storage mechanisms of the personal information (either in digital or hard copy) - the hard copies are held locally in India and our Sites are hosted on AWS servers on the cloud Singapore, United States and India Region.

6.3 You also have an important role in protecting personal information. You should not share any username, password or other authentication data provided to You with anyone, and we recommend that You do not re-use passwords across more than one website or application.  If You have any reason to believe that Your username or password on the Sites has been compromised, please contact us as specified in the “Contact Us” section below.

7. Cookies and other technologies

Cookies are small files which are stored on a user's computer (unless You block them). They are designed to hold a modest amount of data specific to a particular visitor and website and can be accessed either by the web server or the visitor’s computer. MeritTrac Sites may use ‘cookies’ and other technologies such as pixel tag and web beacons to identify You. We use cookies to understand and save Your preferences for future visits and compile aggregate data about Site traffic and Site interaction, tell us which parts of our Site visitors have visited, so that we can facilitate better Site experiences and tools in the future and measure the effectiveness of advertisement and web searches. You may disable cookies through Your individual web browser options. We treat information collected by cookies and other technologies as non-personal information. However, to the extent Internet Protocol (IP) addresses or similar identifiers are considered personal information by local laws, we also treat these identifiers as personal information, for the purposes of this Privacy Policy.

8. Changes to this Privacy Policy

We may modify or amend this Privacy Policy from time to time at our discretion. When we make changes to this Privacy Policy, we will amend the revision date at the top of this page. We encourage You to periodically review this Privacy Policy to be informed about how we are protecting Your personal information.

9. Contact Us

If You have questions or concerns regarding this Privacy Policy, please contact our Privacy office. 

PRIVACY OFFICE DETAILS:

Blessing Samuel Premkumar

Grievance Office

MeritTrac Services Private Limited

No.1/1, Swami Vivekananda Road, Off M G Road, Near Trinity Circle, Halasuru, Bangalore, Karnataka 560008

blessing.premkumar@u-next.com

+91 080 24499100