privacy policy

1.1

This Privacy Policy is published in compliance with, inter alia: (i) the Information Technology Act, 2000; (ii) the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“Data Security Rules”); and (iii) the (Indian) Information Technology (Intermediaries Guidelines and Digital Media Ethics Code) Rules, 2021.

1.2

This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of all the information you disclose or share with us, including your personal information. This Privacy Policy applies to all information you disclose or share with us, including personal information collected by us in connection with the Services.

1.3

This Privacy Policy states the following: (i) the type of information collected from the Users, including Personal Information (as defined below) and Sensitive Personal Data or Information (as defined below); (ii) the purpose, means and modes of collection, usage, processing, retention, and destruction of such information; and (iii) how and to whom we will disclose such information.

1.4

The information collected from you by Novatr may constitute ‘personal information’ or ‘sensitive personal data or information’ as defined under the Data Security Rules. “Personal Information” is defined under the Data Security Rules to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such a person. The Data Security Rules further define “Sensitive Personal Data or Information” of a person to mean such personal information about that person which consists of information relating to: (i) passwords; (ii) financial information such as bank accounts, credit and debit card details 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 body corporates for providing services; and (viii) any of the information received under the above clauses by body corporates for processing, stored or processed under lawful contract or otherwise.

1.5

You can connect with the Services using a computer, or a mobile device or a tablet. The provisions of this Privacy Policy shall apply to all such access and use of devices.

2.1

You specifically accept this Privacy Policy when you browse, access and/or use the Platform and the Services.

2.2

By accessing, browsing and/or using the Platform and the Services, you are specifically consenting to Novatr collecting, using, storing, sharing, and disclosing your Personal Information and Sensitive Personal Data or Information and other non-personal information in accordance with this Privacy Policy, including for wide circulation. If you do not agree to the collection, use, storage, sharing and disclosure of your Personal Information and Sensitive Personal Data or Information and other non-personal information in this way, please do not use the Platform and the Services or otherwise provide us with your Personal Information and Sensitive Personal Data or Information and other non-personal information.

2.3

You acknowledge that this Privacy Policy is a part of the Terms, and you unconditionally agree that becoming a User of the Platform and the Services signifies your: (i) assent to this Privacy Policy; and (ii) consent to us collecting, storing, processing and/or disclosing all your information, including your Personal Information and Sensitive Personal Data or Information in the manner and for the purposes set out in this Privacy Policy. Your visit to the Platform and/or use of the Services is subject to your unconditional acceptance of this Privacy Policy and the Terms.

2.4

The collection, use and disclosure of information which has been designated as Personal Information or Sensitive Personal Data or Information under the Data Security Rules require your express consent. By affirming your assent to this Privacy Policy, you provide your consent to such use, collection, and disclosure in accordance with this Privacy Policy.

3.1

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.

3.2

We are extremely transparent about the information we collect from our Users and we allow all our Users to choose what information they wish to provide us. When you access or use the Platform and the Services, we collect various types of information about you through different means as described below.

3.3

Information Provided to Novatr: When you register with us or create an account on the Platform to access or Use our Services (“Account”), we collect information that you provide voluntarily during your registration or creation and use of your Account. This information may include the following:

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

• Photograph/profile picture;
• City;
• Location;
• 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.

3.4

Information provided or collected from access or use of the Platform & Services When you access or use our Platform and Services, we collect information about how you have used our Services.

When you access the Platform and/or use the Services, certain information is stored in our servers automatically. The information captured automatically includes, but is not limited to, the following: data about the pages you access within the Platform, User choices and behavior, your internet protocol (“IP”) address, device identity or unique identifier, device type, geo-location information (on obtaining consent), device and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information. We also collect anonymous information through our use of cookies and web beacons.

When we provide our Services, we may ask you for access, or track geo-location-based information from your mobile or other electronic device, including while downloading or using our mobile application or functionality. If you choose to engage with the Services, we will receive certain information about your location, which may include country, state, city, or more specific location information.

We may collect and store any information you provide us when you use our Services, including when you: (i) add information on a web form; (ii) add, edit or update your Account information; (iii) contact us for support or other offerings; (iv) participate in community discussions, chats, etc.; (v) send any messages to us or correspond with us regarding the Platform or the Services; (vi) respond to a survey conducted by us; (vii) register for a promotion provided by us; (viii) request certain features (e.g., newsletters, updates, or other products); and/or (ix) submit feedback to us. Novatr in this regard collects information that identifies you.

We also collect the Content that you create, upload, or post, or Content that you receive from others when using our Services.

3.5

Cookies and Related Tracking Technologies
The Platform uses persistent and session cookies and other similar technologies to offer you a personalized 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 personalize 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 analyze content.

3.6

Buttons, Tools & Content from Other Companies
The Platform may include buttons, tools, or content that link to other companies’ services, such as Facebook, Twitter, Instagram, and LinkedIn. We may collect information about your use of these features. In addition, when you see or interact with these buttons, tools, or content, or view a web page on the Platform, some information from your browser may automatically be sent to the other company, in accordance with the terms and conditions of such other company.

3.7

Information from you about others
If we offer a referral option and you choose to use it to invite a friend to use the Services, we will ask you for your friend’s email address and other personal details. You must make sure your friend has consented before you provide us with your friend’s email address and personal details. We will automatically send your friend emails and other communications inviting your friend to visit the Platform. We store this information only to send emails and other communications to your friend and track the success of our referral program.

3.8

Novatr’s Emails
Emails we send you may include a technology that tells us whether you have received or opened the email or clicked a link in the email. If you do not want us to collect this information from Novatr’s marketing emails, you can opt out of receiving Novatr’s marketing emails. Where permissible under Applicable Law, we may also include web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics purposes.

3.9

Authentication and Fraud Detection
In order to help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with the Platform and other Users. We may also evaluate your computer, mobile phone, or other access devices to identify any malicious software or activity.

3.10

Contacting Novatr
We may also collect information about you from other sources, such as through your contact with us, including our customer support and/or social media team, and your interactions with other Users. Additionally, for quality and training purposes or for our own protection, we may monitor or record telephone conversations with you or anyone acting on your behalf. By communicating with us, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.

4.1

Keeping your information secure is of great concern to us. We exercise care in facilitating the transmission of information between your device or computer and our servers (or the third-party servers that operate and store information for the Platform). Your, Personal Information, Sensitive Personal Data or Information and all other information is maintained by Novatr in electronic form on its equipment, and on the equipment of its employees, consultants, sub-contractors, vendors, service providers, agents, and representatives. Such information may also be converted to physical form from time to time. Personally identifiable information collected by the Platform is stored in operating environments with restricted access and are not available to the public. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized manner. Novatr takes necessary precautions to protect your personal information both online and off-line and implements reasonable security practices and measures including certain managerial, technical, operational, and physical security control measures that are commensurate with respect to the information being collected and the nature of Novatr’s business. In addition, we have limited the access to your personal information to those who have a need to know. While we have mechanisms in place to safeguard your personal information after we receive it, no transmission of data over the internet can be guaranteed to be 100% secure.

4.2

Novatr makes all information of a User accessible to its officers, employees, consultants, agents, representatives, sub-contractors, vendors, service providers, business partners and third parties only on a need-to-know basis and binds all of them to strict confidentiality obligations.

4.3

Part of the functionality of Novatr is assisting Novatr’s service providers and business partners to maintain and organize such information for rendering services, including the Services. Novatr may, therefore, retain and submit all such records and information to Novatr’s service providers and business partners who request access to such information.

4.4

It is necessary for the Users to keep their personal information and their password confidential. The Users must not share their usernames and passwords with anyone to prevent unauthorized use of their personal information. You shall, at all times, be responsible for the protection of and the disclosure of your username and password. We shall, in no way, be liable for disclosure of your username and/or password, or your personal information, in the event of any unauthorized access of your Account. In the event of such unauthorized usage, you shall notify us immediately

5.1

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your information:

• to verify your identity;
• to enable you to access the Platform and use the Services;
• for the provision of seamless and efficient Services to you, customized in accordance with User preference, i.e. for performing our obligations towards you;
• to provide you with necessary details pertaining to your Account and your license to use the Services, including, sending notifications for termination of contract;
• to send transactional communications, including responses to your comments, questions and requests;
• to contact you, through voice call, text messages, or emails, as authorized by you, under the Terms;
• for business management, accounting and auditing purposes;
• to do such activities for which you have explicitly given us consent;
• to comply with Applicable Laws, as updated from time to time;
• to inform you about our new products and/or services;
• to enhance and customize our customer care services to suit your need;
• to respond to your queries or service requests and for resolution of the same;
• to send you technical notices, updates, security alerts, and support and administrative messages;
• to advertise, promote, or market our products and services and to undertake all other types of business development activities; to comply with applicable security standards;
• to detect, prevent or remedy any breach of the Terms;
• to perform research, business and/or operational analysis;
• to protect your (or someone else’s) interest;
• to deal with legal disputes, if any;
• to provide, maintain or improve our products and services;
• to ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution;
• to conduct data analytics studies to review and better understand customer satisfaction and needs;
• to generate internal reports about our User base and service usage patterns, analyze the accuracy, effectiveness and popularity of the Services;
• to track User activity and behavior pattern on the Platform; and/or
• to protect the public interest or for official purposes, if formally requested by any investigative or other governmental authority.
  We may also use your information to generate charts, presentations, reports, logs, or other documents about, inter alia, our User base, service usage patterns, analysis of the accuracy, effectiveness, and popularity of the Services for marketing, or other external purposes. However, in case of such external use, we shall ensure to anonymise the personal information provided by you. You hereby give your express consent to us for using your personal information for this purpose.

6.1

We implement reasonable security practices to store your data accurately, confidentially, and securely. The term for which we shall be retaining your personal information depends solely on the nature of the information. We shall retain your personal information only for such period of time as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

6.2

Novatr may, at any time, delete your information, including but not limited to, your personal information, without any prior notice to you. Upon the expiry of your license to use the Services or deactivation and/or termination of your Account, Novatr shall have the right to, immediately and permanently, delete all stored messages, emails, Contents, and all other records of your Account without any notice.

6.3

Except to the extent provided herein, we will destroy your personal information upon the fulfilment of its purpose. We may, however, retain your personal information for: (i) accounting purposes for such time period as is prescribed under Applicable Law; and (ii) for legal purposes till the completion of statutory limitation for bringing any suit, if any. We will also retain your information for the purposes and for such time periods as may be prescribed under Applicable Laws.

6.4

Under certain circumstances, we alter the personal information collected from Users to render it anonymous so that, it could no longer be personally identifiable. In the event of such anonymization of data, we shall have the right to retain such data for as long as we require and use such data without intimating you of such use and for any lawful purposes of whatsoever nature, whether mentioned in this Privacy Policy or not.

6.5

Retention of your personal information, including your sensitive personal information by a third party, or another User shall be governed by their privacy policies and Novatr is neither responsible nor could be held liable for any breach or non-compliance from such party’s part.

6.6

Please note that certain of your public content and information can exist elsewhere even after you removed or deleted it from the Platform, including with third parties which may retain content and information.

6.7

If you have violated our Terms and Platform usage policies as a consequence of which we have terminated or suspended your account, we may indefinitely keep certain identifying data that you used to create your Account, including email address and phone number to prevent you from offending again, including by creating new accounts.

7.1

Processing of Services: We share information, including personal information, with our officers, employees, consultants, agents, representatives, sub-contractors, service providers and business partners to enable them to undertake, perform and deliver the Services.

7.2

Third Party Service Providers We share information, including personal information, with our third-party service providers that we use to: (i) to host and maintain the Platform, (ii) for application development, back-up, storage, processing, analytics, marketing and front or back-end development and support; and (iii) for audits, web analysis and other services required to enable seamless provision of Services. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us. We forbid the third-party service providers from using your personal data for their marketing purposes or for any purposes other than for the provision of services to us. Please note that third party service providers have their own privacy policies, and Novatr is not responsible for their actions, including their information protection practices.

7.3

Compliance with Laws and Law Enforcement Requests & Protection of our Rights We may also share your personal information and data with third parties where we believe in good faith that such disclosure is necessary to comply with any Applicable Law or to comply with legal processes and to respond to requests from public and Government authorities, including public and government authorities outside your country of residence, to prevent imminent physical harm or financial loss, to enforce our Terms, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms, or as otherwise required by law. We may also share your information in situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of Novatr, our employees, Users, vendors, partners or the public and obtaining your consent is difficult. We, at our sole discretion, shall have the right to disclose your personal information to third parties, in the event we believe it to be necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or any other unlawful activity.

7.4

Insolvency, Business Transitions & Transactions: If we should ever file for bankruptcy or engage in a business transition or a corporate restructuring transaction, we may share your information in connection with any such transition or a corporate restructuring, including a merger, demerger, amalgamation, reorganization, sale of some or all of Novatr’s assets, a change in control transaction or a financing or acquisition of all or a portion of our business by another company.

7.5

Consent: We may share your information in any other circumstances where we have your express consent.

7.6

Novatr’s Affiliates: We may share your information among the affiliates of Novatr so that we can better provide better services that are relevant to you as well as generally to provide the services as applicable.

7.7

Disclaimer. We cannot ensure that all of your information will never be disclosed in ways not otherwise described in this Privacy Policy. For example, a third party may unlawfully intercept or access transmissions or private communications, or other users of the Platform may abuse or misuse your personal information. No transmission of data over the internet can be 100% secure.

8.1

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions. Any processing of your personal information by third parties shall only be done by treating the information collected from you confidentially, legally, and securely.

8.2

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized manner. In addition, we have limited the access to your personal information to those who have a need to know.

8.3

It is necessary for the Users to keep their personal information and their password confidential. The Users must not share their usernames and passwords with anyone to prevent unauthorized use of their personal information. You shall, at all times, be responsible for the protection of and the disclosure of your username and password. We shall, in no way, be liable for disclosure of your username and/or password, or your personal information, in the event of any unauthorized access of your Account. In the event of such unauthorized usage, you shall notify us immediately

8.4

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9.1

You may, under Applicable Law, have the right to access, correct, update, or delete the personal information Novatr holds about you. In order to exercise your rights, to the extent permitted and required of Novatr under Applicable Law, please contact us at privacy@novatr.com.

9.2

We respect your communication preferences, if you no longer wish to receive notifications viaour Platform, you can adjust your preferences. If you prefer not to receive ads that are tailored to your interests, you can opt out by writing to us at privacy@novatr.com at any time.

9.3

Novatr may use your information to contact you in the future to inform you about the services Novatr believes will be of interest to you. If Novatr does so, each communication it sends to you will contain instructions permitting you to "opt-out" of receiving future communications. In addition, if at any time you wish not to receive any future communications or wish to have your name deleted from our mailing lists, please contact us at privacy@novatr.com.

9.4

Due to the nature of the Services, and the restricted access to our Platform, the only way for you to opt out of sharing your personal information with us which are essential for providing the Services is by deactivating your Account. Upon deletion of your Account, Novatr shall, at its earliest, stop sharing your personal information in accordance with this Privacy Policy. Any personal information shared before such deactivation shall be governed by this Privacy Policy. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes. Please note that your withdrawal of consent or cancellation of Account may result in Novatr being unable to provide you with its Services or to terminate any existing relationship Novatr may have with you.

9.5

If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at privacy@novatr.com.

10.1

The Platform may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in the Interactive Areas might be read, collected, and used by others who access it. To request removal of your personal information from an Interactive Area, contact us at . who access it. To request removal of your personal information from an Interactive Area, contact us at privacy@novatr.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

11.1

The Platform may contain links to third-party websites. Your use of these features may result in the collection, processing, use, storage or sharing of information about you, including your personal information, by these websites, depending on the feature. Please be aware that we are not responsible for the content or privacy practices of other websites or services that may be linked on our Services. We do not endorse or make any representations about third-party websites or services. The information you choose to provide to or that is collected by these third parties is not covered by our Privacy Policy. We shall, at no time, be liable for any unauthorised use of your personal information by these third-party websites. We strongly encourage you to read such third parties’ privacy policies.

12.1

We reserve the right to update this Privacy Policy at any time, and from time to time, with or without advance notice. In the event there are significant changes in the way we treat User’s personal information, or in the Privacy Policy itself, we will display a notice on the Platform or send Users an email, so that you may review the changed terms prior to continuing to use the Platform. Please check this page periodically for changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used. Please review the changes carefully. Your continued access to the Platform or use of our Services following the posting of changes to this Privacy Policy will mean you consent to and accept those changes. As always, if you object to any of the changes to our terms, and you no longer wish to use the Services, you may stop browsing through the Platform, deactivate your Account and/or contact us at privacy@novatr.com.

12.2

If a User uses the Services or accesses the Platform after a notice of change has been sent to such User or published on the Platform, such User hereby provides his/her/its consent to the changed terms.

13.1

We may provide certain Courses for young adults who are legally minors and may not be able to provide valid consent to our collection, use, disclosure, storage, or other handling of their personal information. Parents and guardians of children/minors are personally responsible for monitoring their child's/minor's access to, and use of, our Platform and the Services and for providing valid approvals for their child's/minor's access to the Platform and subscription to the Services provided by us. If you are under the age of 18 (eighteen) years, it is mandatory that your parent or guardian has read and accepted this Privacy Policy on your behalf, and it is assumed that you have ensured that the use of the Platform and the Services by you is under the guidance and control of your parents or guardian. If you are a child or young adult under the age of 18 (eighteen) years, you must ask your parent or legal guardian to approve your provision of personal information before you submit your personal details to us. If your parent or guardian has not read and agreed to this policy, you will not have permission to use the Platform and the Services. We have the right to contact the parents of any User as and when required in connection with the Services.

14.1

We shall not be liable for disclosure of your passwords and you shall be solely responsible for protecting your username and passwords, at all times. You shall be solely liable for any unauthorised use of the Platform through your Account. In the event of such unauthorised usage, you shall notify us immediately and reset your password accordingly.

14.2

While we give utmost importance to protecting User data and information, we cannot ensure that all your personal information (including sensitive information) will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your personal information will always remain private. As a User of the Platform, you understand and agree that you assume all responsibility and risk for your use of the Platform, the internet generally, and the Content you post or access and for your conduct on and off the Platform.

Should you have questions about this Privacy Policy or our information collection, use and disclosure practices or grievance with respect to our use of your information, you may contact our grievance officer identified below We will use reasonable efforts to respond promptly to any requests, questions, or concerns, which you may have regarding our use of your personal information.