Privacy Policy​

I. General

This Privacy Policy explains why Nudge Lifeskills Foundation (“we” or “us” or “our”) collects information about you, the nature of information collected, how that information may be used, processed, protected, transferred and otherwise handled when you use or visit The Nudge/CSI’s website (available at https://csi.thenudge.org/) and the mobile application (collectively referred as “Platform”) and avail the services provided therein.

THIS PRIVACY POLICY IS AN INTEGRAL PART OF THE TERMS OF USE.

YOU HAVE BEEN DIRECTED TO THIS PAGE TO FAMILIARIZE WITH THE TERMS CONTAINED HEREIN. PLEASE PROVIDE YOUR INFORMED CONSENT FOR PROCESSING OF YOUR PERSONAL INFORMATION AS THE SAME IS ESSENTIAL FOR USING THE PLATFORM.

BEFORE YOU SUBMIT ANY PERSONAL INFORMATION TO US, PLEASE READ THIS PRIVACY NOTICE FOR AN EXPLANATION OF HOW WE WILL TREAT YOUR PERSONAL INFORMATION.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, WE REQUEST YOU TO NOT USE THE PLATFORM .

BY PERSONAL INFORMATION WE MEAN ANY INFORMATION WHICH, INDIVIDUALLY OR ALONG WITH ANY OTHER INFORMATION, HAS THE ABILITY TO IDENTIFY YOU AS AN INDIVIDUAL PERSON, INCLUDING ANY SENSITIVE PERSONAL INFORMATION.

II. Application

This Privacy Policy applies to any person (“you” and “your”) visiting, accessing, or using the Platform or availing the services provided therein or has shared any personal information with us (hereinafter referred to as “PD”).

III. Contents of this Privacy Policy

What PD we collect?

We collect and process the following PD from you, including but not limited to:

  • name, email-id, address, mobile number, gender, professional details and such other details as may be required for onboarding and access to the Platform at the time of registering with our Platform, and/or while creating a user account, or while filling questionnaires or forms, or when you subscribe to our updates by email, and/or upload or submit any material or content while using the services /Platform ;
  • log-in/user details and password details during the user account sign-in/registration/change password, etc. processes;
  • financial details solely in respect of the subscriptions availed on the Platform;
  • your data on social media platforms (say Facebook profile data or Google profile data) if You choose to log in through Google or other social media;
  • all communications and emails and other correspondence between you and us;
  • the entire range of material or the content which you post on the Platform;
  • device and hardware information for syncing and seamless access;
  • location information ;
  • information on how you use the Platform through our third-party cookies such as duration of visiting or using the Platform; and
  • your IP address(es), browser and operating system specifications including mobile browser and mobile operating systems.

In the event you do not wish to provide your PD, we will not be under any obligation to make the Platform or the services available to you.

Please note that when you visit or access the Platform, some information may be collected automatically, including, but not limited to, the type of device you use, your device’s unique device ID, the IP address of your device, your operating system, the type of internet browsers you use, and information about the way you use the Platform.

While interacting/transacting on the Platform or for availing the services, you may be required to pay through the services of a third-party payment gateway provider. You understand, agree and acknowledge that the Platform never receives your PD, especially financial data or information, provided to the third-party paymentgateway provider. Your PD will be dealt by third-party payment gateway provider in accordance with their respective privacy policies and other terms and conditions, and you are advised to peruse and familiarise with those terms and policies; and we shall not be liable, accountable or responsible in any manner for your PD which you provide to the third-party payment gateway provider.

While we shall make reasonable endeavors to ensure that your PD is duly protected by undertaking security measures prescribed under applicable laws.You are strongly advised to exercise discretion while providing PD while using the services given that the internet is susceptible to security breaches.

Whenever you use our service, in case of an error in the Platform we collect data and information on your device called log data. This log data may include information such as IP address, device name, operating system version, the time and date of your use of the service, and other statistics.

How do we collect PD?

We collect PD:

  • directly from you when you access the Platform, or voluntarily provide your PD at the time of registration or onboarding to avail our services via the Platform, or request information related to the services or for availing any further services; and
  • indirectly from other sources such as cookies (our cookie policy), web beacons, website traffic, information available in public domain through internet searches, analytic studies, and other information that we may derive while processing PD.

How do we process your PD?

We collect PD only for legitimate and lawful purposes for providing you access to the Platform and for the usage of the services through the Platform.In pursuance of the same, we collect, store, record, organize, structure, align, retrieve, adapt, access, review, archive, analyse, pseudonymize, encrypt, decrypt, profile, transfer, perform other related technological and manual processing activities, and when no longer required, we anonymize or erase your PD.

If You choose to log in or sign up with our services through other providers such as Google or any social media platform like Facebook, etc., we shall request permission to access your profile and seek appropriate permissions from you wherever required.

If you click on links on third party websites, you shall be governed by their terms of use and privacy policies and we do not control the manner as to how and in what manner such third parties collect your PD and how they process it. We do not endorse and neither shall we be responsible for any data breach or infringement of your privacy rights, or for loss, or damage whatsoever if you visit, use or access such third party websites.

We may use your contact information for marketing and promotional purposes about any prospective service(s) of the Platform. However, if you decide and write to us stating that we should refrain from using your contact information in respect of any marketing or promotional purposes, we will honour your decision. If you do not write to us to let us know of any objections to the use of the contact information for promotions and marketing, it shall signify that you have accorded us permission for such use of your contact information.

Please note that your PD shared by you is kept safe and secure, and we use and process any PD in accordance with applicable laws and based on your consent for processing for lawful purposes and for providing you the service(s) and access to the Platform. Your creation of the user account and logging in every time you use our services and/or the Platform amounts to valid consent.

Additionally, certain third-party service providers may be provided your PD to enable us to gain insight into your use of the Platform and personalise your experience. However, we undertake reasonable efforts to ensure that these third-party service providers do not process your PD for any other purpose except as stated in this Privacy Policy or as authorised by us explicitly.

Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any PD or non-personally identifiable information about you to:

  • fulfill a government request;
  • conform with the requirements of the law or legal process;
  • protect or defend our legal rights or property, our Platform, or other users; or
  • protect, in an emergency, the safety of our users or the general public; or
  • for lawful and legitimate business interest in such manner that your privacy rights are not adversely affected.

We process your PD in accordance with fair, accountable and transparent processing principles as required under applicable law. Governing principles thatwe follow for processing are:

  • process lawfully, fairly and with transparency;
  • process only for purposes communicated, or those which are reasonably expected to be connected with the purposes, or for purposes which are compatible with them;
  • minimize collection only as much is adequate, relevant and necessary for the processing purposes;
  • take reasonable steps to maintain accuracy in light of the processing purposes;
  • retain in such form bearing in mind the processing purposes;
  • use technical, operational, and organizational security measures;
  • prevent accidental loss, unlawful destruction or access or damage; and
  • maintain confidentiality and integrity of PD, except otherwise mentioned in this Privacy Policy.

Profiling means automated processing of PD to evaluate certain personal attributes about you. This aims at analysing your behaviour while using the Platform. There will be no profiling by automated means that will affect your PD protection rights and privacy.

Why do we process PD?

We process your PD for entering into a lawful contract with you and thereafter, for performance of the lawful contract so executed and for providing the Platform and/or the services. The processing of your PD is based on your explicit consent. The purpose of processing of your PD also includes those that can be reasonably expected in context thereof, and those that are compatible with the listed-out purposes. If you do not want to consent, we will be unable to provide you with the services.

Additionally, we process PD for the following purposes:

  • providing the services and enabling access to the Platform;
  • communicating with you about new services, additions,new features, and updates available on our Platform;
  • verification of identity at the time of sign in into your user account;
  • analyzing and providingyou with any statistical data on activity;
  • responding to any queries that you may submit to us;
  • send you information/documents/resources including newsletters, event information, useful knowledge materialsfor your organization capacity building, tool kits, forms and call for action etc.;
  • creating, improving, and developing our Platform;
  • creating, improving, and developing our Platform;
  • obtaining feedbacks from you and acting thereupon;
  • improvising, upgrading and implementing security measures for the Platform and your PD;
  • sending direct mailers at the e-mail address given, with an option to opt-out anytime;
  • protecting and securingyour PD;
  • usinganalytics tools to better understand our web traffic and marketing / program effectiveness;
  • detecting and handling data breach scenarios;
  • periodically reviewing PD collected to adhere with your requestsregarding your rights and legal obligations under applicable law;
  • maintaining secure personal information management system;
  • sharing with third parties as mentioned in this Privacy Policy and for the fulfilment of services on the Platform;
  • honouring your requests and right;
  • contactingyou for queries posted on the Platform by you or contact you in any regard;
  • compliance with applicable law;
  • defending or initiating legal, judicial and equitable actions; and
  • for performing any other legitimate and lawful business interest in such manner that your privacy rights are not adversely affected.

We do not use any PD for any other purpose other than for the purposes listed in this Privacy Policy.Apart from the above purposes, please note that we do not sell, rent, or trade your PD in any manner.

Processing of your PD is based upon, and in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”).

How do we protect your PD?

Your PD is as important for us, as it is for you. We honour and value the trust reposed in us and we are committed to ensuring that your PD is secured with confidentiality, integrity, and authenticity. We have implemented reasonable operational, technical, physical and managerial safeguards, practices, procedures, and policies commensurate with the sensitivity of the PD to ensure safety, security, privacy, integrity and protection of all information assets including PD.

All our staff, personnel, officers, representatives, and members receive appropriate and on-going training to ensure they are fully aware of their obligation to uphold confidentiality, protect PD, and respect your privacy. Only limited authorized personnel have access to PD on a strict need-to-know basis and only for specific purposes. If you wish to learn more about our data protection practices, please write to us at csi.alum@thenudge.org

How long do we store PD?

We will store and process your PD for such duration as is reasonably necessary to fulfill the purposes stated in this Privacy Policy and to comply with all applicable laws, after which all PD will be either anonymized or irretrievably destroyed. In the event the user account is terminated/disabled due to any reason whatsoever, we shall not be responsible or liable either to maintain and/or hold any PD whatsoever provided by you.

Do we transfer your PD to third parties?

We may transfer your PD to third-party service providers with whom we have a contractual agreement. Such transfer is strictly undertaken on a need basis to provide the services to you and to enhance your experience while using the Platform. Your PD may be transferred or shared with third parties as set forth below:

  • Service providers: We share your PD with third-party service providers who use this data to perform certain services for us such as analytics, data storage, tech solutions, and information security practices;
  • Legally required: We may disclose your PD if we are required to do so by law or where it is necessary to respond to claims asserted against us or to comply with legal processes, or to initiate claims;and
  • Business transfers: We may disclose or transfer PD as part of any merger, sale and transfer of our assets, acquisition, or any similar transaction.

In all such instances, we require the third-party to maintain confidentiality, use PD only for the limited purpose for which it is disclosed, and restrict onward transfer. We also insist that recipient destroys PD to the extent feasible once the purpose is achieved. However, as you would appreciate, we do not control their ecosystems, and hence, we disclaim any liability whatsoever for any misuse or breach in their ecosystems.

Before transferring PD to a third-party, we conduct reasonable due diligence factoring the purposes, such as evaluation of processes implemented as per information disclosed about processing measures, inspection rights wherever reasonably possible, requiring representations, and mandating compliance with applicable laws concerning data protection and privacy from the third-party.

Google Play Store

The Platform - CSI AlumConnect is distributed on the Google Play Store, a place for the distribution of mobile apps. Your use of Google Play Store is described in more detail at https://play.google.com/about/developer-distribution-agreement.html.

Links to third-party websites

The Platform may contain links to other third-party websites or a third-party electronic communication service who may or may not collect your PD. We do not directly provide any PD to such third-party websites. If you submit your PD to any of those sites, your information will be governed by their privacy policy and terms of use. We encourage you to read the privacy statement of any website you visit. We shall not be liable for any loss, damage, claim or expenses suffered by you as a result of accessing these third-party sites and features.

Personal data transfers

Your PD is processed on cloud servers in India. However, your PD may be stored, transferred or transmitted over, and used, in such locations outside of India . Your PD may be subject to the local laws of the jurisdictions within which it is being collected, stored, used and/or disclosed and may be accessed by courts, law enforcement agencies, regulatory agencies and/or statutory authorities in such jurisdictions.

Userrights under the SPDI Rules

Your rights are:

  • access – seek confirmation on whether and what PD is processed and seek access;
  • lodge complaint - file a complaint with appropriate authority under applicable law;
  • correction – correct/update inaccurate, incomplete, outdated or misleading PD;
  • withdraw or modify consent - withdraw or modify consent at any time; this will not affect processing that has taken place prior to the date You request such withdrawal or modification. If withdrawal or modification will have a bearing on you accessing the Platform or availing services, We will notify you before acting on your request; and
  • erasure and restriction on processing - erase PD, or restrict, object, limit or refuse processing; if you exercise this right, this may have a bearing on using and accessing the Platform and services and we will notify you before acting on your request.

You can exercise these rights by writing to us at csi.alum@thenudge.org. We will try our best to provide the necessary information or undertake the necessary action within 30 days from receipt of the request. If requests are excessive or unfounded or repetitive at our sole discretion, we can refuse your request or charge a reasonable fee for costs.

We do not and shall not undertake any responsibility for the authenticity or genuineness of the PD provided/shared by you, and we do not make/provide any representation(s), warranty(ies), guarantee(s), covenant(s), admissions, estoppels(s), whatsoever that the PD which you provide is correct, accurate and shall be suitable, whether in whole or in part, for the purpose(s) for which it is/was provided by you during the access and/or use of Platform/service(s).

Other types of data/information

Non-Identifiable Data: When you use our services through the Platform, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information, or such information may be included in databases owned and maintained by our affiliates, agents, or service providers. The Platform may use such information and pool it with other information to track, for example, the total number of visitors to our Platform, the number of visitors to each page of our Platform, and the domain names of our visitors’ internet service providers. Please note that it is important to note that no PD is made available or used in this process.

Aggregated data: We may conduct research on our visitor/customer demographics, interests and behavior based on the PD and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents, and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Platform/services to current and prospective business partners, and to other third parties for other lawful purposes.

Publicly visible information

If You create a user account onthePlatform or leave a comment on the Platform, certain information like your name and other information provided in the public portions of the Platform may be publicly visible.

Our cookie policy

Our Platform use cookies to store visitors’ and user’s preferences; record user-specific information on what pages users access or visit; ensure that visitors are not repeatedly sent the same banner ads; or to customize Platform content based on visitors’ browser type or other information that the visitor may send to us. We may also share information about your use of our Platform with our social media, advertising, and analytics partners.

This section of the Privacy Policy will explain what cookies are, how we use cookies and similar technologies on the Platform and what you can do to manage how cookies are used.

WHAT ARE COOKIES?

A cookie is a small text file which is sent to the computer or mobile device (hereinafter “Device”) by the web server so that a website can remember some information about your browsing activity on the website. The cookie collects information relating to your use of the website, information about your Device such as the Device’s internet protocol (IP) address and browser type, demographic data and, if you arrived at the Platform via a link from third party websites, the URL of the linking page.

In addition to cookies, the Platform may use web beacons. Web beacons allow us to count the number of users who have visited or accessed the Platform and to recognize users by accessing our cookies. We may employ web beacons to facilitate Platform administration and navigation, to track the actions of users of the Platform, to compile aggregate statistics about Platform usage and response rates, and to provide an enhanced online experience for visitors to the Platform. We may also include web beacons in HTML-formatted e-mail messages that We send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF.

What are the different types of cookies and how do we use them?

Essential cookies: These are cookies which are essential for the running of our Platform. Without these cookies, parts of our Platform will not function. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Examples of how we may use essential cookies includesetting unique identifiers for each unique visitor, so that website numbers can be analyzed.

Functional cookies: These cookies are used to remember your preferences on our Platform and to provide enhanced, more personal features. The information collected by such cookies is usually anonymized, so we cannot identify you personally. Functional cookies do not track your internet usage or gather information which could be used for selling, advertising etc.

Examples of how we may use functional cookies include

  • gathering data about visits to our Platform, including numbers of visitors and visits, length of time spent on the Platform, pages clicked on or where visitors have come from; or
  • eliminating the need for returning users to re-enter their login details.

Analytical performance cookies: Analytical performance cookies are used to monitor the performance of our Platform, for example, to determine the number of page views and the number of unique users our Platform has. We use this information to improve user experience or identify areas of the Platform which may require maintenance. The information is anonymous (i.e., it cannot be used to identify you and does not contain personal information such as Your name and email address) and it is only used for statistical purposes.

Examples of how we may use analytical performance cookies include

  • measuring users’ behavior; or
  • analyze which pages are viewed and how long for and which links are followed to better develop our Platform.

Advertising cookies: Behavioral advertising cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on the Platform more relevant to you. Although behavioral advertising cookies can track your activity around the internet, these cookies cannot identify you personally, even if you are signed in to our Platform.

Examples of how we may use advertising cookies include

  • manage online advertising where our approved advertising partners may use cookies together with web beacons to provide advertising to you and to enable us to manage our relationship with those advertisers by, for example, tracking how many unique users have seen a particular advertisement or followed a link in an advertisement; or
  • to market to specific users across our Platform and third party sites, so that we and third parties can target advertising to users that will be more relevant to users’ interests.

Third Party Cookies: You may notice on some pages of our Platform that cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own cookies on your Device. We do not control the use of these third party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. Please check the third-party websites for more information about these cookies.

How can you manage or opt out of cookies?

You do not have to accept cookies and you may modify your browser settings to refuse them. Your browser allows you to see, identify and control the use of Platform cookies. You can revoke your earlier provided consent at any time and control the cookies through your browser, deleting them individually or deleting all of them. You can also set your browser to not accept any cookies. If you experience any problems having deleted cookies, you should contact the supplier of your web browser.

Opting out of advertising cookies

If You would like to opt out of Analytics cookies, please do so by clicking on the links below: Opting out of Behavioral Advertising Cookies

Opting out of third party cookies

If You would like to disable “third party” cookies generated by advertisers or providers of targeted advertising services, You can turn them off by going to the third party’s website and getting them to generate a one-time “no thanks” cookie that will stop any further cookies being written to Your Device/machine. Here are links to the main third party advertising platforms We use, each of which have instructions on how to do disable cookies.

If You have any questions about the cookie section or if You would like more information on the cookies that We use and their purposes, please contact Us at csi.alum@thenudge.org.

Minor/children’s PD

We do not knowingly collect any PD from minors/children under the age of 18. If you are under the age of 18, please do not submit any PD through the Platform. We request parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide PD on the Platform without their permission. If a parent or guardian believes that we havePD of a child under the age of 18 in our database, please contact us immediately at csi.alum@thenudge.org and we will use our best efforts to promptly remove such PD from Our records.

Spam policy

We strongly oppose any spam mailing. We will only send e-mail to users that have explicitly requested and/or given their express consent to receive an e-mail from us.

  • opt-in subscribers to The/Nudge CSI Newsletter;
  • users that complete a contact form; and
  • all communicationrelated and relevant to what you have requested.

E-mail communications

If You send us an email with questions or comments, we may use your PD to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public PD, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, provided, however, we reserve the right to send you transactional emails such as customer service communications.

Changes to the privacy policy

We reserve the right to update and modify this Privacy Policy from time to time without prior notice. Please read and visit our Privacy Policy regularly for any changes, alterations, modifications etc. Changes to this Privacy Policy are effective when they are posted on this page of the Privacy Policy. We request you to please review this Privacy Policy periodically, and especially before you provide any PD. Your continued use of the Platform after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Your access to and use of the Platform may also be subject to any separate agreements or terms and conditions you may have signed or agreed to withus. Please refer to those agreements as needed.

How do you contact us?

If you have any genuine questions or concerns in matters regarding this Privacy Policy, you may reach out to csi.alum@thenudge.org for assistance.

Grievances

You can contact our grievance officer atcsi.alum@thenudge.org in case of any grievances.

Signatory

Subhashree Dutta

Vice President, Center for Social Innovation

Privacy Policy

(c) 2018 AIC NCore from The/Nudge. All rights reserved.