1. The Information We Collect
We collect information about you through providing our Services. The types of information we collect depends on the Services and the features you use on the Services. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services. The said information collected from the users could be categorized as “Personal Information”, “Sensitive Personal Information” and “Associated Information”. Personal Information, Sensitive Personal Information and Associated Information (each as individually defined under this Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (the “Data Protection Rules”)) shall collectively be referred to as 'Information' in this Policy.
1. Information You Provide Directly to Us
We may collect information that you provide directly to us through:
- Your use of our Services, e.g. when you register for an account or use the Coaching we offer;
- Your participation in surveys or when you fill out our forms;
- Your request for information about our Services, such as when inquiring about our Coaching services;
- Your purchase or use of our Services, such as when you engage with a Coach or Coachee on our Services;
- Your subscription to newsletters;
- Your registration for contests or promotions;
- Your requests for support and/or technical assistance;
- Your transmission of user content or other information to us; and
- Any other communications you have with us.
The information you provide directly to us may concern you or others and may include, but is not limited to:
- Account Registration and Contact Information: We may collect information from you when you sign up for an account with us. That information may include, among other things, your name, a username, email address, profile picture, password,, and other information you provide.
- Payment and Financial Information: We or our service providers may collect payment information from you, such as payment card number, expiration date, billing address, and payment account name.
- Demographic Information: We may collect your demographic information such as your country of residence, time zone, and language(s) spoken.
- Audio/Video Coaching Data: When you use our Services to engage with a tutor or student, we may retain recordings of the video and chat sessions. We may use such recordings for our internal business purposes, including without limitation for purposes of coach evaluation, coach training, dispute resolution, and improving our Services.
- Other Content and Other Information You Provide to Us: We collect additional content and information that you voluntarily provide us, such as content you submit when you, respond to surveys, use the classroom whiteboard, contact us via the Services or by e-mail.
You are not required to provide us with such information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.
2. Information from Affiliates and Non-Affiliated Third Parties
We may collect information about you or others through our affiliates or through non-affiliated third parties. For example, PracUp Coaches may take notes on your conversations, based on information provided during Coaching sessions. We may combine information that we collect from you through the Services with information that we obtain from such third parties, such as if you sign in with a third party service or social media networks, and information derived from other products or services we provide.
3. Information We Collect Automatically
4. Cookies and Other Electronic Technologies.
We may also use local shared objects (also known as "Flash cookies") to assist in delivering special content, such as video clips or animation. Flash cookies are stored on your device, but they are not managed through your web browser.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser may not affect flash cookies. As we adopt additional technologies, we may also gather additional information through other methods.
Location Information. When you use the Services, we may collect general location information (such as general location inferred from an IP address).
2. How We Use the Information We Collect
We use your information for business and commercial purposes, such as:
- To provide you with the Services, including to register you for an account, enable coaching sessions, and process transactions;
- To respond to your questions or inquiries, including to provide support and troubleshooting assistance;
- To communicate with you, including to communicate with you about your account, inquiries, our company, and related news, as well as to send you promotional emails, surveys, newsletters, or notifications;
- To manage and remember your preferences and customize the Services;
- To analyze and improve the Services or any other products and services we provide;
- To administer surveys, sweepstakes, promotions, or contests;
- To improve our advertising and marketing, such as to provide you with recommendations for products or services that may interest you;
- To verify your identity;
- To comply with our legal obligations or as permitted by law;
- To protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services;
- To prevent fraud and enforce our legal terms; and
- To administer and troubleshoot the Services.
We may combine information that we collect from you through the Services with information that we obtain from affiliated and non-affiliated third parties, and information derived from any other products or services we provide.
We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.
3. With Whom & Why We Share Your Information
We may share or disclose your personal information for the following reasons:
- Affiliates: We may share your information with PracUp and PeopleNorth affiliates.
- Service Providers: We provide access to or share your information with select vendors who perform services on our behalf. They provide a variety of services to us, including data storage, analytics, billing, marketing, product content and features, customer service, data storage, security, fraud prevention, and legal services.
- Legal Requirements: We may share or disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
- Business Transfer: We may share or disclose certain 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.
- Aggregate/Anonymous Information: From time to time, we may share aggregate/anonymous information about use of the Services, such as by creating reports on usage trends. The sharing of such data is unrestricted.
4. Online Analytics and Advertising
We may use third-party web analytics services on the Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information we collect automatically” section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services.
5. Our Legal Bases for Use of Your Information
The laws of some jurisdictions require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing your information. To the extent those laws apply, our legal grounds are as follows:
- Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you. For example, to comply with our User Agreement, which you accept by browsing or otherwise using our Services.
- With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent.
- Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Services, preventing fraud, and managing legal issues.
- Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.
6. Security of Your Information
We implement security measures to protect your information. It is important that you protect and maintain the security of your account credentials and you need to immediately notify us of any unauthorized use of your account. Please understand that no data transmission over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us.
7. Consent to Transfer
8. Third-Party Websites
Our Services may link to third-party websites from companies other than PeopleNorth, such as to relevant online resources, our partners’ websites, and other third-party websites. We are not responsible for the privacy practices or content of such other websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly. We are not responsible for the actions of third parties.
9. Your Choices
You have certain rights and choices with respect to your information, such as:
- Profile Information and Accounts: If you have an account on our Services, you can access and edit the information you provided to us through individual settings in the Services. If you want to terminate your account, please request account termination through settings in the Services or by emailing email@example.com.
- Marketing Emails: To opt out of marketing e-mail communications, you may click the “unsubscribe” link in the marketing emails.
- Cookies & Analytics: You can opt out of certain cookie-related and analytics processing.
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. If you have unresolved concerns, you may lodge a complaint with your local data protection authority.
Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information to comply with a legal obligation. We may request that you provide us with information necessary to confirm your identity before responding to your request.
11. Contacting Us