Occasionally, we may use certain information that we have collected to send You information about programs or services offered by Manipal, its partners, authorized representatives.
You agree and confirm that Manipal may collect, store, process, disclose and transfer the SPDI collected about you to any of its affiliates, agents or third party service providers in connection with the products and services or courses you have sought from, or to provide better services to you or to ensure compliance with a legal or contractual obligations of Manipal. The purpose for which Manipal would collect and use your SPDI includes instances set out in clause 3.2 below. The types of third parties (whether in India or abroad) that your SPDI could be disclosed to, includes the types of third parties mentioned in clause 5 below. You confirm that the SPDI so far collected, stored, processed, disclosed and transferred by Manipal in the course of your engagement for the above purposes shall continue to be used by Manipal strictly in accordance with the applicable laws.
2.1 Personal Information (the “PI”)for the purposes of this 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 with a body corporate, is capable of identifying such person such as name or address and to be read with the relevant internal policies including that of its associates and subsidiaries or group companies.
2.2 Sensitive Personal Data or information of a person (the “SPDI”) for the purposes of this 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; i.e
- Financial information such as bank account or credit card or debit card or other payment instrument details;
- Physical, physiological and mental health condition;
- Sexual orientation;
- Medical records and history;
- Biometric information;
- Any detail relating to the above clauses as provided to us for providing services; and
- Any of the information received under any of the above clauses by us for processing, storing or processing under lawful contract or otherwise.
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 Policy.
2.3 Information Provider
For the purposes of this Policy, refers to a natural person or individual who provides PI or SPDI to Manipal. In this Policy, the Information Providers are referred to as ‘You’.
3 Purpose of collection and use of SPDI
3.1 Manipal will ordinarily collect 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 an employee or a counterparty to agreement with individuals. Ordinarily, Manipal will collect such SPDI about You when You provide it or You have consented to provide the information or where it is required by law. Manipal reserves the right to disclose your SPDI, including email address, as required by law and when it is believed that disclosure is necessary to protect Manipal’s rights and/or comply with a judicial proceeding, court order or legal process served on the site.
3.2 In general, we would be collecting / handling/ storing /using or transferring your SPDI for the following, including but not limited to:
3.2.1 complying with legislative and regulatory requirements
3.2.2 providing agreed services to You;
3.2.3 performing administrative functions; and
3.3 The SPDI collected from You may be collected and/or retained either directly by Manipal or through or with an affiliate or third party.
Manipal, its affiliates and third parties it shares SPDI with, will retain the SPDI for a reasonable period for the purposes for which such information has been collected and as may be lawfully used or is otherwise required under any law for the time being in force.
The SPDI collected shall be used for the purpose for which it has been collected.
You have the option not to provide Manipal with the 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 SPDI which Manipal deems necessary for providing you with any service is not provided or if consent is withdrawn subsequently, Manipal reserves the right not provide you with such services / benefits / amenities and take any other action in this regard on just and reasonable grounds.
4. SPDI about third parties
While providing SPDI of another natural person (particulars of spouse, children or parents) to Manipal, please ensure that you have the necessary concurrence of that natural person.
5. Disclosure of Sensitive PI
5.1 In general, Manipal will not use or disclose SPDI collected about You to a third party otherwise than for the purposes set out in this Policy, 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 and supported by a valid non-disclosure contract or provisions in the legal contract.
5.2 Provided that such information shall be shared with your consent, with government agencies mandated under law to obtain information including SPDI for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences or any law enforcing authorities.
5.3 Notwithstanding anything contained in the preceding paragraphs of this section, any SPDI shall be disclosed to any third party by an order under a law for the time being in force.
5.4 You authorize Manipal to disclose necessary SPDI to certain employees, consultants, employees or consultants, of Manipal affiliates, agents or third party service providers within India or outside India who provide services to Manipal in connection with the education services you have sought from, or, your employment with, Manipal, on a need-to-know basis. These parties shall use your SPDI only for the specific purpose for which Manipal supplies the SPDI to them and from disclosing it further.
5.5 Subject to what is permitted by law, the types of third parties (whether in India or overseas) your SPDI could be disclosed to may include:
5.5.1 agents, contractors, service providers, insurers and external advisers engaged by Manipal from time to time to carry out, provide services or advise on the functions and activities;
5.5.2 other related bodies corporate /affiliates of Manipal;
5.5.3 any person or organization who introduces you to Manipal;
5.5.4 regulatory bodies, government agencies, law enforcement bodies and courts;
5.5.5 any person or organization who Manipal deems necessary for carrying out the instructions you give to Manipal; and
5.5.6 any prospective transferee in a scheme of arrangement, amalgamation, merger or sale of shares or sale of business relating to the whole or part of Manipal.
6. Transfer of Sensitive Personal Information
Manipal may transfer your SPDI to any person or entity, whether in India or located in any other country, that ensures a similar level of data protection as Manipal employs when it is necessary for the performance of a lawful contract with you or where you have consented to such transfer.
8. Access to your Sensitive Personal Information
You may review and correct or revise the SPDI you have provided to us for the purpose of ensuring the said information is accurate. Manipal shall not be responsible for the authenticity of the information you have supplied to it or to any person acting on its behalf.
9. Information Security Standard for SPDI at MANIPAL
Manipal operates in an environment that is similar to the requirements of ISO/IEC 27001 Security Standards for ensuring that the SPDI it holds is protected from misuse, loss and unauthorized access, modification or disclosure. Some of the SPDI we collect online is used for verification of your identity while taking our Programs online. While taking our Programs online, security questions will appear on the screen asking you to identify yourself. The correct answers to the questions are based on the information you provided us with during enrollment.
10. Non-Personal information gathered automatically
If you do nothing during your visit but browse through the website, read pages, or download information, our website’s operating system will automatically record some general information about your visit. During your visit our web operating system will record:
- The Internet domain or internet service provider for your internet service, Browser type, type of operating system platform, date / time stamp, referring / exit pages address of the previous website that you were visiting, if you linked to us from another website, domain name and country/state.
- IP address to help diagnose problems with servers that host and administer our website.
We use this information for statistical analysis, to help us make our site more useful to visitors. This tracking system does not record information about individuals.
The information generated by the cookie about your use of the website includes your IP address. This information will be transmitted to and stored by Google on its servers. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Updating your personal information and privacy preferences
You have the right to access, correct and delete inaccuracies in your personal information and privacy preferences at any time. With respect to Registration Information (as defined in the section entitled "Protection of your personal information"), this may be accomplished by logging in to your account on the relevant website, where you can typically view and make changes to your personal information. You may also access and correct your personal information and privacy preferences (such as whether you wish to receive promotional communications of Manipal, and its affiliates within the Manipal Global Education framework) by writing to Student Services, Manipal ProLearn, C/o Manipal Global Education Services Private Limited, Manipal Towers, No.14, Old Airport Road, Bangalore-560038.
Collection of personal information
As a visitor to this Site, you can engage in many activities without providing any personal information. In connection with other activities, such as utilizing online or hosted Programs and Services, Manipal may ask you to provide certain information about yourself by filling out and submitting a form. It is optional for you to engage in these activities. If you elect to engage in these activities, however, Manipal may ask that you provide certain personal information (as well as certain non-personal information that may be tied to personal information), such as your first and last name, mailing address (including ZIP code), country, e-mail address, employer, job title and department, and telephone and facsimile numbers,. Depending upon the activity you intend to use on some Manipal Services and Programs that you have enrolled, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity. Similarly, if you wish to delete your information that is mandatory, you will no longer be able to engage in that particular activity.
If you decide to send us an electronic mail message (e-mail), the message will usually contain return e-mail address. If you include, personally-identifiable information in your e-mail, because you want us to address specific to your situation. We may use that information in responding to your request, e-mail is not necessarily secure against interception. Please send us only information to help us process your request for the specified service.
Invite / Referral Program: Personal Information that users choose to provide about other individuals under the referral policy/ features for tell-a-friend on the Site or within Programs and Services, we ask to provide name and email address and phone number of such referred or your friends. We will send to such person whom you have referred a one-time contact related to your referral request. We store this information in our system for the sole purpose of sending one-time contact and tracking the success of our referral program. The friends of the users will not receive any more communication unless they choose to receive more communication or if they become a registered user of our site or upon enrollment as a student.
If you are invited by someone else to participate in shared editing or viewing of documents, photos, websites or other content, you will typically be required to contact the person who invited you to update, correct or delete the personal information they provided about you or . In general, even though we may delete an account you hold with us in these types of shared editing or viewing areas, we may continue to retain information regarding your past actions with respect to content reviews or sharing initiated by others. Your referral friend may contact our support service to request that we remove this information from our database.
We may also ask you to provide information of others such as when reporting suspected piracy. In this instance, we will ask for the person's or company's name and contact information so that we may investigate. Personal information supplied in these instances will only be used for the purpose being submitted.
Manipal also hires other companies to place our banner ads on other websites. Such companies perform tracking and reporting activities on ads served and user reaction ("third-party advertisement servers"). They do not collect any information other than IP addresses and behaviour associated with those IP addresses on our behalf, and we do not give any personal information to them. Third-party advertisement servers are subject to their own privacy policies. Manipal may also allow other companies to display advertisements on certain pages of the Site or within the Programs and Services. If you click on these advertisements these companies may place a persistent cookie on your computer which may allow them to display further advertisements to you. It is our policy to require these companies to provide accessible methods for you to disable these cookies.
Manipal reserves the right, at its sole discretion, to review, edit or any material posted by users which Manipal deems defamatory, unlawful, threatening, obscene or otherwise objectionable. Notwithstanding the foregoing, Manipal Global Education expressly disclaims any responsibility or liability for any material communicated by third parties through this web site.
Emails: Manipal will not send unsolicited emails to registered users of the site without consent. Additional users may choose to receive Manipal correspondence, including email reminders, specific offers and newsletters. The ‘My Account” link on the site, displays the correspondence that you wish to receive, and provide the option to unsubscribe from future communication from Manipal entities related emails. In case a user who wishes that their personal information, including email address to be completely removed from the website database should use the support or contact us page. We will respond to your request within 21 (twenty one) business days. An individual’s complete removal of his or her personal information from the website database negates that individual user’s ability to login to the Manipal ProLearn website and access to the services.
11. Subscribing to Programs directly through Manipal website
Manipal ProLearn uses other third parties to process your orders, and a payment card processing company to bill you for goods and services. These companies do not retain, share, store or use SPDI including email address, for any other purposes.
Services through distributors or channel partners: Manipal ProLearn uses other third parties to proces payment card transactions on the sites. When you sign up for our Program directly, we will share first name, last name, payment card information and billing address as necessary for third party to provide that service. No other information is shared with third parties for this purpose. For users transactions, the transaction and discount / offer information is shared with the users payment card issuer and processor only for the purpose of applying the appropriate discount to the user’s payment card.
These third parties are prohibited from using your personally identifiable information, including email address, for any other purpose.
12. Surveys/Feedback, Contests and Testimonials
After the Program completion, our site requests information from users through surveys or feedback. We also provide you an opportunity to participate in contests. Participation in these surveys or feedback and contests is completely voluntarily and the user therefore has a choice whether or not to disclose this information. The requested information typically asks the reason for choosing our programs, how you heard about our Programs, and why you preferred buying our program. Survey, feedback and contests information will be used for internal purposes for monitoring and improving the use and satisfaction of our Program, site user friendliness and for statistical purposes and to deliver the contest winners prizes, if any.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
13. Service Announcements and Business Transition
Sometimes it may be necessary to send out a strictly service related announcement, such as if we are experiencing technical difficulties or if our service is temporarily suspended for maintenance. Those who have unsubscribed from receiving emails will not receive these notices. In the event Manipal ProLearn services goes through any type of business transition, such as merger, acquisition, by another company, or sells a portion of its assets, user’s SPDI will, in most instances, be part of the assets transferred. Users will be notified via email and a prominent notice will be placed on our site for thirty(30) days prior to change of ownership or control of their SPDI. If as a result of business transition, the users’ SPDI will be used in a manner different from that stated at the time of collection.
14. Communications, special offers and updates
We send all new users a welcoming email to verify successful enrollment. When an account is created, the user first enters our list database, and is sent notifications vide e-mail/sms, relevant to the chosen Program/ course. We also send an e-mail/sms when the user’s assessment due date is near and after they complete the Program successfully. Upon completion of the Program, users are added to the newsletter list- these newsletters offer news, program information, and offers information across all Manipal brands. We provide a way to opt out of our news, promotion and associate emails. Users can click on the “Unsubscribe” link at the bottom of the email or contact our Support service to have their emails blocked. We then remove the user’s email / contact no. from our mailing / messaging list.
15. Support Service
You may contact the Grievance Redressal Officer (GRO), who is the designated grievance officer, for any grievances with respect to processing your Sensitive Personal Information. Manipal will make every effort to resolve your grievance expeditiously.
Name of GRO: Mr. Alex Mendes, Dy. General Manager
This Policy is updated on August 08, 2015