Privacy Policy

PRIVACY NOTICE 

Last updated October 17, 2022 

This privacy notice for Prolearner Interactives Pvt. Ltd. ('Company', 'we', 'us', or 'our',), describes how and why we might collect, store, use, and/or share ('process') your information when you Download and use our mobile application (ProVR companion application). 

 

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, we request you to please uninstall this application. If you still have any questions or concerns, please contact us at policy@prolearner.net

 

SUMMARY OF KEY POINTS 

This summary provides key points from our privacy notice. 

Q. What personal information do we process? 

When you use our application, we may process personal information depending on how you interact with the application and the Services, the choices you make, and the features you use. This information may include IP addresses, names, email addresses and general location (e.g., the city / name of the location where the training is being conducted). We do not collect or store GPS-based location data.

 

Q. Do we process any sensitive personal information? 

We do not collect or process sensitive personal information. 

 

Q. Do we receive any information from third parties? 

We do not receive any information from third parties. 

 

Q. How do we process your information? 

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. 

 

Q. In what situations and with which types of parties do we share personal information? 

We may share the login details and other collected data (including name of the trainer, stated location of the trainer & training sessions, trainee details, including their name, their company identification number, date and time, the duration of each training session, the score of the trainees, and other related data) with your company as per the terms and conditions of your company’s engagement with Prolearner Interactives Pvt. Ltd. 

 

We use cloud providers such as Amazon Web Services© and other similar service providers to collect, store and process your data. 

 

Q. How do we keep your information safe? 

We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. 

 

Q. What are your rights? 

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. 

How do you exercise your rights? The easiest way to exercise your rights is by contacting us by email at policy@prolearner.net. We will consider and act upon any request in accordance with applicable data protection laws. 

 

Privacy Policy Details

1. WHAT INFORMATION DO WE COLLECT? 

Personal information you disclose to us 

Personal Information Provided by You. The personal information we collect may include your name, your email address, the name of your city or region, the names of your trainees, their company identification number, the IP address you are logging in from, and the dates and times when you use our application.

 

Sensitive Information. We do not process sensitive information. Sensitive information includes any financial data such as transactions, banking information, etc., personal information including gender, age, etc. 

 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. 

 

Information automatically collected 

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. 

 

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. This log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, tabs and application features used, and other actions you take), device event information (such as system activity, error reports(sometimes called 'crash dumps'), and hardware settings).

 

Device Data. We collect device data such as information about your phone, tablet, or other device you use to access the Services. This device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

 

Location Data

We do not collect or store your GPS-based location data. However, we do collect and store the name of the city / location you or your company enters in the application.

 

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and login to your account, as well as keep your account in working order.

 

To generate reports and training analytics: We may process your personal data, the data entered by you in the application, including the number of trainees, the details of the training sessions, including the date and time of each session, the scores, the modules viewed by each trainee, etc. for analysis and to generate reports, which may be shared with your company, as per the terms of engagement of your company with us. 

 

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Your company / organization. We may share your data and the data of trainees, as described above, with your company as per the terms of engagement of your company with us. 

 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

Cloud service providers such as Amazon Web Services (AWS)® or other similar 3rd parties.  

 

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, or as per our terms of agreement with your company, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than six (6) months past the termination of the user's account and/or the termination of our agreement with your company.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

 

6. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at policy@prolearner.net.

 

7. WHAT ARE YOUR PRIVACY RIGHTS?

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.

  • Contact us using the contact information provided.

 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, subject to our agreement with your company. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

 

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

9. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at policy@prolearner.net