Skills Caravan Private Limited Sector 62, Gurgaon, Haryana ,India

Last Updated

March, 2023

We are grateful that you have chosen to be part of our learning community at Skills Caravan. We are doing business as Skills Caravan ("Skills Caravan ", “We”,", Us", or "Our"). We respect your privacy and will protect your personal data. You can contact us at info@skillscaravan.com if you have any questions about our privacy policies or practices regarding your personal data.We appreciate you trusting us with personal information when you visit our website or skillscaravan.com("the "Website") and our platform ("the "Platform). Your privacy is very important to us. This privacy policy explains very clearly to you what data we collect and how we use it. It also outlines your rights in relation to that information. It is important that you carefully read it. Please discontinue using our Services immediately if you disagree with any of the terms contained in this privacy statement.This privacy policy covers all information that is collected by our Platform, which, as mentioned above, includes our Website, as well as any related services or sales, marketing, or events.

1. BACKGROUND

(a)At Skills Caravan, we are passionate about lifelong learning, making learning accessible to people in all parts of the world and providing those people with a digital learning record.

(b) We are registered in India and operate globally. The business of Skills Caravan includes an online marketplace for e-learning resources(alongside software and services to produce and deliver such training and resources) (hereinafter the “Platform”), which are made available by and through a number of partners, including content partners, distribution partners and implementation partners, (collectively, “Partners”).

(c) We acknowledge our obligations to all recipients of our products and services (hereinafter the “Services”), including visitors (hereinafter the “Visitors”) to our website atskillscaravan.com (hereinafter the “Website”), our registered users and administrators(hereinafter the “User”) of our Platform on behalf of our customers (hereinafter the “Customer”) (hereinafter together the “Data Subject” or “you” and “your”) to collect, manage, process and use their personal information (hereinafter the “Personal Data”) in accordance with the laws and regulations of each of the countries in which we operate.(hereinafter the “Policy”), they mean Skills Caravan Private Limited, and any of our corporate affiliates including but not limited to (i)Skills Caravan Private Limited

(d)By accessing and using the Website and the Platform, you confirm that you have read and fully understood this Policy, that you agree to the collection and the usage of your own and others’ Personal Data in accordance with this Policy, and that you have the authority to provide us with all Personal Data submitted by you via the Website and the Platform. By registering for or using Skills Caravan Services you consent to the collection, transfer, processing, storage, disclosure, and other uses of your Personal Data described in this Policy.

2. SCOPE OF THIS PRIVACY POLICY

Our Policy explains

(a)the Personal Data we collect about you when you use the Website, the Platform when you contract with us or otherwise interact with us (for example, by attending our premises or events or by communicating with us); and

(b)your rights surrounding how we use your Personal Data, which include how you can object to certain uses of your Personal Data and how you can access and update your Personal Data (for more details see section 7).

3. WHAT PERSONAL DATA DO WE COLLECT

3.1 General

(a) We collect Personal Data, including:

(i) the name, email address, phone number, and country of residence;

(ii)where the relevant, name of employer and title;

(iii) other information volunteered by the Data Subject (e.g. information entered on our Platform or our Website or provided to our team) or given to us with consent;

(iv) information derived by use of cookies (e.g. IP addresses– please refer to the Cookie Policy here); and

(v) Personal Data about the learning activities undertaken by the User, including course completion, and use of features, links, and third-party integrations.

(b)The information described in section 3.1(a)(v) forms part of a User’s profile, which is created when a Data Subject first opens an account with an email address and password and which forms the basis of the User’s learning record.

(c) In addition to the Personal Data we collect about Users, we also collect Customer Personal Data that is required for your contract with us, such as company affiliation, contact information, invoicing data, and physical address.

(d) We may receive Personal Data about you from other Skills Caravan Users or Partners, from third-party services, from our related companies, social media platforms, public databases, and from our business and channel partners. We may combine this Personal Data with Personal Data we collect through other means described above. This helps us to update and improve our records, identify new customers, create more personalized advertising, and suggest Services that may be of interest to you.

3.2 Sensitive Information and Personal Data of children

(a) Under the Customer Terms, all our Users must be over the age of 18.

(b) Skills Caravan does not solicit, collect or knowingly process sensitive information(as defined under the Privacy Act 1988 (Cth) or sensitive personal data (as defined under GDPR, the FDPA, and the UK Data Protection Act 2018).

4. HOW WE COLLECT PERSONAL DATA

4.1 Collection from an individual

‍We collect Personal Data directly from Data Subjects via the Website and the Platform, including when you submit a query and via correspondence if you contact us (including via email or phone). This Personal Data may include your name, email address, phone number, company, role, and any other information you provide us. We also collect Personal Data directly from Customers when you contract with us for the provision of our Services.

4.2 Collection from authorized representatives

We collect information from employers and organizations on behalf of their employees, contractors, consultants, volunteers, and other parties that they wish to register for our Services. This information may include the name, email address, role, and further contact information of the Users if necessary or volunteered by the disclosing authorized representative.

4.3 Collection via Cookies and log files

(a) We receive information via third parties including the employer / company /organization when it is provided to us by such an authorized representative to enable the use of the Services.

(b) This information may include the name, email address, phone number, company, role, and other User information as provided to us by the authorized representative.

4.4 Collection via cookies and log trackers

We allow limited use of various technologies to collect and store Personal Data when Visitors visit our Website, which may include using cookies(i.e. a string of unique data that a website stores on a Visitor’s computer and that the Visitor’s browser provides to the Website each time the Visitor returns) or similar technologies to identify the Data Subject’s browser or device.

5. HOW AND WHY DO WE USE THE PERSONAL DATA WE COLLECT

5.1 Data processing activities

‍We act as a data processor to perform our contracts with our Customers and process User’s Personal Data that Customers have provided us with for the following purposes:

(i) performing the Services;

(ii) User registration;

(iii) User enrolment (into courses);

(iv) User learning record creation (once a course is completed);

(v) User reminder notifications (via email) to Users when learning is due; and

(vi) issuing an administrative report to determine the overall User process.

If required, a Data Processing Agreement (DPA) which complies with the DataProtection Law requirements will be signed between Skills Caravan and each Customer that receives Skills Caravan Services.

5.2 Reasons for use

‍The reasons we collect, store, process, and use your Personal Data include:

(a) to perform, personalize and administer our Services;

(b)to identify and authenticate Users;

(d)for support or response purposes, including when Data Subjects request support or make an inquiry;

(e)to plan, improve, tailor, optimize, market, and promote our Services for and to Data Subjects including by asking Users for feedback on our Services;

(f) to provide Data Subjects with relevant information and offers of courses and other services that we believe might be of interest to Data Subjects, which we may do by email;

(g) to manage Users’ accounts;

(h) to send Users prizes, certificates, or scholarships to use our courses and other products and services;

(i) to provide Users with a digital learning record;

(j)for contractual and other lawful, regulatory, or legitimate business purposes or for the establishment, exercise, response, consideration, or defense of regulatory claims or proceedings;

(k) to perform the agreement Skills Caravan entered into with the Customer;

(l) to perform any other functions described in our terms and conditions or this Policy;

(m)to communicate with you about your account or transactions, and provide you with product-related communications, such as information about new features and Policy updates;

(n)to manage, analyze, understand, and develop our relationship with Data Subjects;

(o)responding to your queries or complaints; and

(p) to act pursuant to your consent, for specific purposes e.g. with your consent, we may send you marketing communication or post your testimonial along with your name on our Website. If you wish to update or delete your testimonial, please contact us using the details in section 12 below.

5.3 Disclosure to third parties

‍(a) We may share or internally transfer your Personal Data within our Skills Caravan entities. In such cases, only our authorized personnel will process your Personal Data and only in the framework of their functions

(b) We may share or transfer your Personal Data to our third-party service providers(including Partners and processors) in order to fulfill the purposes described above. These third parties have access to your Personal Data only for the purpose of performing these purposes on our behalf

(i) to provide infrastructure Services;

(ii) to help us provide Customer support and email notifications;

(iii) for marketing and advertising purposes;

(iv) for billing and invoicing purposes; and

(v) to provide additional content in the case of our content Partners. Prior to engaging any processor, Skills Caravan performs due diligence to evaluate their privacy, security, and confidentiality practices and executes an agreement that complies with the Data Protection Law.

(d) All Skills Caravan’s entities and third parties are contractually obligated to comply with the same laws and regulations that we are required to comply with regard to the Personal Data, wherever they are located in the world, and we require them to adopt and apply data protection policies and practices that are consistent with this Policy.

(e) We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to the government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes, to protect the property and rights of Skills Caravan or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be or to pose a risk of being, illegal, unethical, inappropriate or legally actionable

(f) We may share or transfer your Information (including your Personal Data) 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. You will be notified of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data

(g) However, please note that once Personal Data is shared with another company, the Personal Data received by the other company also becomes subject to its privacy policies and practices

(h) Users need to understand that their choice not to provide certain Personal Data, as described above, will limit or prevent their ability to access and use our Services.

6. HOW LONG DO WE HOLD PERSONAL DATA

(a)We hold Personal Data only for so long as is necessary for the purposes set out in this Policy unless a longer retention period is required or permitted by law.

(b) We are guided by our contractual obligations and by other lawful legitimate business interests

(i) the type of information;

(ii) the purpose for which it is used;

(iii) how sensitive it is;

(iv) whether we have an ongoing relationship with the individual it relates to (e.g. you have an account with us, you are subscribed to receive communication from us, or regularly visit or use our Services or Website); and(v) our legitimate interests (e.g. defending claims, resolving disputes, enforcing our rights and agreements, and statistical analysis or research).

(d) The Personal Data may be retained in intermediate archiving if it is necessary

(i)for Skills Caravan to fulfill its legal obligations or

(ii) to provide evidence in case of litigation (data retention only during the local legal statute of limitations).

(e) Aggregated or anonymized information, since this is not Personal Data, may be stored indefinitely.

7. YOUR RIGHTS

(a) Skills Caravan respects your rights as a Data Subject. You have the right to request from Skills Caravan access to and rectification or erasure of your Personal Data, or restriction of processing concerning you, or to object to the processing as well as the right to data portability.

(b) Upon registration, Users have ongoing access to their Skills Caravan accounts. Users can correct any inaccuracies, or update or add any information themselves through their online accounts.

(i) rectify any inaccurate Personal Data relating to you;

(ii)send to you, or transmit to another controller, all of your stored Personal Data (in which case we will do so in a structured, commonly used, and machine-readable format);

(iii) under certain conditions, restrict or object to the processing of your Personal Data;

(iv) under certain conditions, delete your Personal Data; or(v) withdraw your consent for the use of your Personal Data for the purposes which requested consent.

d) You may unsubscribe to any or all emails from us through the automated facility sent with each email.

(e) Any actions or requests made in accordance with section 7(c) may limit the ability of Data Subjects to access and use our Services.

(f)It may be the case that, for contractual or other lawful, regulatory, or legitimate business purposes, we retain and use an archived version of Data Subjects’ Personal Data, which may be pseudonymized, anonymized, or otherwise de-identified.

(g) We have facilities in place to request Partners and other third parties, as necessary, to amend or delete Personal Data held on their systems.

(h) When Skills Caravan processes User’s Personal Data on behalf of and as instructed by its Customers, our Customers are responsible to the Users and such User(s)should contact the respective Customer, acting, for example as their employer, for exercising their rights. In these circumstances, Skills Caravan does not respond directly to the User’s requests for the exercise of their rights that we are notified of, but we inform the relevant Customer without delay and provide all reasonable assistance to satisfy the User’s requests in accordance with instructions of the Customer.

8. INFORMATION SECURITY

(a) We work hard to protect Skills Caravan and the Data Subjects from misuse, interference, loss, unauthorized access, modification, or disclosure of information we hold, including Personal Data.

(b)We apply technical and organizational measures to ensure a level of security appropriate to the risk, including:

(i) analyzing and assessing privacy and security issues, risks, and impacts during the design and development of new features and solutions for our products, services, and delivery platform, governed by guidelines and security standards for our IT developers;

(ii) ensuring confidentiality, integrity, availability, and resilience of processing systems and services (for instance, we restrict access to personal information to Skills Caravan employees, contractors, Partners, and other third parties described above, who need the information for the purposes described above and who are subject to strict contractual privacy and confidentiality obligations);

(iii) ensuring the ability to promptly restore the availability and access to Personal Data in the event of an incident;

(iv)regularly reviewing and testing our information collection, storage, and processing practices, including physical security measures, aimed to ensure the security of data processing; and(v)as we deem necessary, pseudonymizing and encrypting (e.g. using SSL) data (e.g. for the purpose of transfers, when Personal Data is encrypted and access is restricted at rest).

(c)In implementing and carrying out these security measures, we are guided by:

9. INTERNATIONAL TRANSFERS

(a) Given that Skills Caravan operates internationally, Personal Data of Data subjects that we collect Personal Data from, including via the Website and the Platform, may be transferred across national and continental borders, including for contractual and other lawful legitimate business purposes or at the request of Data subjects including to the following locations:

(i) India;

(ii)The United States of America;

10. PRIVACY BREACH

(a)We acknowledge the various data breach obligations in each of the jurisdictions in which we operate.

(b)We commit to promptly identifying and responding to any breaches, to act to prevent harm, and to report, if and as required, to the relevant supervisory authority and the concerned Data Subjects.

11. CHANGES TO THIS PRIVACY POLICY

(a)Our Policy may change from time to time.

(b)We will not reduce Data Subjects’ rights under this Privacy Policy without their explicit consent.

(c)We will post any changes on this page and, if the changes are significant, we will provide a more prominent notice (which may include email notification of Policy changes). We encourage you to check this page from time to time and take notice of any changes we make.

(d)We will also keep prior versions of this Policy in an archive for review by Data Subjects upon request.

12. COMPLAINTS, ENQUIRIES, AND REQUESTS

(a)Privacy complaints, inquiries, and requests to exercise your rights regarding your Personal Data can be made to:

Privacy Officer

info@skillscaravan.com

(b)If you are not satisfied with our answers related to your complaint or inquiries related to your Personal Data, you have a right to lodge a complaint with the competent supervisory authority. We will gladly provide the contact details of the relevant supervisory authorities.

(c)We aim to respond to all privacy requests, inquiries, and complaints within 30 days. Where a different timeline for response is prescribed by law, we will respond within the prescribed time period.

Last updated: March 2023

‍