For the purposes of this Policy, “Personal Data” means your personal data and any personal data of your parents (as applicable for specific services)
1.2 Occasionally, we may use certain information that we have collected to send You information about programs or services offered by us.
1.3 If You are providing PI 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.
- Personal Information we collect
(ii) Financial information such as bank account or credit card or debit card or other payment instrument details;
(vii) Any detail relating to your social security, biometrics or genetic characteristics, data related to racial or ethnic origin, political opinions, religion or other belies, criminal background as provided to us for providing specific services or otherwise to us; and
(viii) Any of the information received under any of the above clauses by us for processing, stored or processed under lawful contract or otherwise.
2.3 We use third-party advertising companies to serve advertisements regarding the products and services that may be of interest to you when you access and use the Services and other websites or online services. Such advertisements are based on your access to and use of our services and other websites or online services on any of your devices, as well as data received from third parties. When You visit the Site, we / third party advertisement companies make this possible by placing or recognizing a unique cookie on your browser (including the use of pixel tags). These also use these technologies along with data they automatically collect certain information about Your device your use (such as mobile phone and a computer), including information about Your web browser, IP address, time zone, and some of the cookies that are installed on Your device.
2.4 We may obtain data about you from following sources:
2.4.1 From You, when you submit your resumes or other information online on our Site;
2.4.2 From conversations with third party recruitment partner and interviews with MGSA personnel or counsellors, some of which may be recorded (with your express knowledge and consent) as well as from internet searches that these individuals may perform, or data that they may obtain from job search or professional networking websites (e.g., Naukri.com, Linkedin, etc.) where you may have made data about yourself publicly available.
2.4.3 From third-party student recruiters, or websites where you are being introduced to MGSA. From background checks, as applicable, where permitted by law, MGSA may contract with a third party to perform a background screening. The content of background check information varies in compliance with our client requirements, but may include information gathered from publicly available resources, your former employer or colleagues, schools / colleges you have attended, credit reporting agencies and criminal records databases. These types of information will be collected with your consent and where required by applicable local law, you may be asked to provide certain background check information (which may include PI and SPDI) directly to MGSA.
- Purposes of Collecting and Processing of Personal Information
3.1 MGSA 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, MGSA 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, placement drives, survey respondents, visiting our Site(s). To the extent that information requested is not required for Your participation in a given MGSA program /course, You will be told which information is optional. Should You fail to provide optional information certain MGSA programs 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 of your application and registration and/or enquiry of any programs offered by us or our partners; responding to inquiry, made, for example, responding to a specific inquiry or providing you with access to specific course content and/or services you select; and
(c) Tracking both individual and aggregate attendance, progress and completion of a course, and analysing statistics on a learner performance and the manner in which learners learn.
(d) complying with legislative and regulatory requirements
3.2 MGSA engage other companies and individuals in addition to MGSA partners to perform functions on our behalf (each a third party and collectively third parties. They will require access to the Personal Data or Information needed to perform certain limited functions for MGSA. We may share PI and SPDI with third parties for legitimate business purposes, including for the following reasons or in the following circumstances:
- within our corporate family of companies including subsidiaries and affiliates that are related by common ownership or control to enable or support us in providing the MGSA services/ courses/ training programs, which involves transferring your data outside India. We ensure your Personal Information is protected by requiring all our affiliates or group companies to follow the same, when processing your Personal Information. These group companies will ensure your Personal Information a similar degree of protection afforded as per applicable data protection laws of India.
- to vendors or third-parties who deliver or provide products and services or otherwise act on behalf of or at the direction of MGSA, which third parties include, for example certain functions on our Site, including managing our learning management system providers, hosting training materials (viz., videos, presentations, courseware etc., processing information provided to us) training providers, partners, processing other transactions through the Site, providing or administering courses, third party event hosting sites, other third parties who may provide services in connection with other aspects as part of agreed MGSA services to you, purchases via third party providers, on web sites that are accessible from links on one of our Site; bank/credit card/credit providing entities processing payment; to MGSA employees, officers and directors, program coordinators and also to MGSA partners for legitimate interests where appropriate. These parties shall use Your PI and SPDI only for the specific purpose for which we supply the PI and SPDI to them and only in providing agreed services. In case you have been enrolled to any of our courses / training programs basis your direct engagement with our partner organisation customers, who have recommended your enrolment to course / training programs offered by MGSA, you have expressly consented directly with such partner organisation customer to share your PI and SPDI with us;
- if You use any our career centre services, Your information may be accessible to potential employer or recruiters;
- to those who wish to determine if You have completed the training program or course enrolled with MGSA, Your certification / course completion status will be shared with those partner organisation customers who have recommended your enrolment to the specific courses / training programs;
- to investigate potentially fraudulent or questionable activities or transactions;
- 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). MGSA Site may provide links to website published by a third parties (including content providers and service providers such as those who process payments on behalf of MGSA) who is assisting in or providing certain services as part of program /course. MGSA has no control over the content displayed on such third party websites, nor over the steps, that are taken by such third-party websites to protect the privacy of Your information. The inclusion of a link on the Services does not imply endorsement of the linked site or services by us or by our subsidiaries or affiliates. In addition, we are not responsible for the data collection, use, disclosure, or security policies or practices of other organizations or other app developer, social media platform provider, operating system provider, wireless or telecom service provider, or device manufacturer, including with respect to Personal Data you SPDI, that you disclose to other organizations through or in connection with our Apps opr our Social Media pages. Once You have used these links to leave our site, we encourage you to read privacy notice of every third party website you visit. Therefore you agree, 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 practices of each of those third party websites you visit and use.
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. We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This will enable us to decide which products, services and offers may be relevant for you. You may receive marketing communication (via email, telephone, direct mails, SMS or other method of communications to you) from us, if you have requested information from us or purchased products or services from us, if you have provided us with your details when you participated in a feedback or registered for a trial/evaluation or promotion and in each you, you have not opted-out of receiving that marketing.
3.8 While providing PI and SPDI of another natural person to MGSA, please ensure that You have the necessary concurrence of that natural person.
Please note that whenever you voluntarily disclose Personal Data or Information online for example on message boards, blogs, emails or in chats areas, such information can be collected and used by others By positing Personal Data or Information online that is publicly accessible, you may receive unsolicited message from other parties in return, for which MGSA is not responsible.
- Disclosure of Personal Information
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.
4.3 The following categories of individuals will have access to your personal information (PI)
4.3.1 MGSA’s product, solutions and marketing personnel, individuals performing administrative and IT support functions;
4.3.2 Partners who support in student counselling and supports
4.3.3 Clients or customers with whom MGSA has contracts engaged to provide trained and skilled candidates, meeting their employment eligibility criteria;
4.3.4 Companies contracted by MGSA to perform background checks as pre-employment requirement for MGSA clients or customers.
4.3.5 Government agencies, where legal reporting requirements may exist, or law enforcement agencies or private litigants in respect to valid law enforcement (sub-poena, or court order);
4.3.6 A successor of MGSA or Manipal, in the event that it sells or divests all or part of its business.
- 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 and where necessary, kept upto date Any of the information that we process that you inform us is inaccurate, is either erased or rectified. Please contact us via firstname.lastname@example.org should you wish to update, correct or withdraw your consent to collect and use your Personal Information (when you stop using any of our products and services on the Site(s). Please identify yourself and which Personal Data or Information about its use or disclosure is requested. MGSA 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 MGSA 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 MGSA deems necessary for providing You with any service is not provided or if consent is withdrawn subsequently, MGSA reserves the right does not provide You with such services/benefits/amenities.
5.3 You have the right to communicate to us any changes to (correct or update) Your PI or privacy preferences at any time. For your protection we may only implement such requests with your PI, that you have previously provided to us, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
5.4 Option Out: You may choose not to receive promotional communications from us (marketing-related emails, texts, or SMS messages from us) by clicking on the unsubscribe link or contacting us as specified in the “Contact Us” section below. Please allow us seven (7) business days for changes to take effect. For certain services and related communications are an integral part of such services to which you subscribe and you continue to receive emails as part of that particular portion of Services unless you cancel your account on the Site(s), even though you have opted out of the newsletters or email list. In case you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe links on any marketing communication for each email address that you have provided.
- 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 communications or method of electronic storage is 100% secure. We cannot guarantee there will be not a breach of security, and we are not responsible for any breach of security or for the actions of any third parties. In order to prevent unauthorized access or disclosure, we have put in place suitable/reasonable physical, technical electronic and organisational security measures and managerial procedures as per applicable industry practices to safeguard, secure and protect the Personal Information we collect from You against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other unauthorised forms of processing, in accordance with applicable law. All electronic storage and transmission of Personal Data and Sensitive Personal Data is secured and stored on managed servers with controlled access and appropriate security technologies. We may at times, use Secured Sockets Lawyer encryption and/or transfer Personal Data in a non-human readable format for adequate protection. 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) while the hard copies are held locally in our office in India and digital copies may be stored on servers which are hosted on the cloud (i.e, AWS servers in Singapore, or India or other cloud service providers and vendors in Singapore, India).
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.
6.4 We will retain Personal Information so long as is necessary or permitted for the purposes for which it was obtained and consistent with applicable law and as set out in this Policy. The criteria to determine may include the length of time we provide the Services to you or we have an ongoing relationship with you, there is a legal obligation to which we are subject and where retention is advisable in light of statutes of limitation, litigation, government investigation or regulatory considerations. In addition, we may retain and use Personal Information to the extent necessary to comply with our legal obligations and to comply with applicable laws, resolve disputes, and enforce our legal agreements and policies.
In some circumstances we may aggregate your Personal Information (so that it can no longer associated with you) for research or statistical purposes in which case we may use this information without any further notice to you.
- Other Data, Cookies and other technologies
- Contact Us
Data Privacy Officer
Manipal Global Education Services Private limited
No.14, Manipal Towers, Old Airport Road, Bangalore- 560008
Effective Date: 16 December, 2021