Privacy Policy
General
Thank you for joining clarus-ventures. We at clarus-ventures (“clarus-ventures”, “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights regarding your personal data.
Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use clarus-ventures websites, mobile applications, APIs, or related services (the “Services”). It also applies to prospective customers of our business and enterprise products.
By using the Services, you agree to the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.
We may also allow Our group companies, affiliates and subsidiary companies to use Our Platform to offer their products and services to You, under applicable terms and conditions as may be specified on Our Platform from time to time.
Information We Collect
We only collect information about you if we have a reason to do so — for example, to provide our Services on the Platform, to communicate with you, or to make our Services better.
We collect this information from the following sources:
Information we collect from You:
- Basic account information: In order to access certain features of the Platform, you will need to create an account and register with us. We ask for basic information which may include your name, an email address, state of residence country, and password, along with a username and phone/mobile number.
- Know Your Customer ('KYC') information: If you are an Content Provider registered with us, then, we also collect the KYC information, which may include information pertaining to your PAN number, aadhaar number, driver’s license, passport, your entity details such as name, MOU/AOA, certificate of incorporation, list of directors/partners, social security number etc., along with the relevant documents. We collect this information and documents from you to complete our verification process including pursuant to any other arrangement / agreement executed with you.
- Public profile information: If you are an Content Provider, we may also collect certain additional information from you to enable creation of your public profile, if any, on the Platform to help Learners and other Users know you better. We do not share your KYC information, documents or any such Personal Information on these public profiles. Your public profile will only contain Personal Information that are required for Learners or Users to know you (as applicable) viz., your username, a brief description of any content you have made available on the Platform, your educational qualifications, your past associations, your photo, and such similar information that may enable a Learner or other User to know you better. The information in your public profile will be based on the information you provide to us or as updated by you on such applicable sections.
- Information when you communicate with us: When you write to us with a question or to ask for help, we will keep that correspondence, and the email address, for future reference; this may also include any phone/ mobile numbers if you have provided us the same as part of your communication either in writing (emails included), over a phone call or otherwise. When you browse pages on our Platform, we will track that for statistical purposes which may be to improve the Platform and the Services. You may also provide us your Personal Information or other information when you respond to surveys, enter any form of contests, tests, events, competitions, webinars, etc., hosted by clarus-ventures, either on the Platform or otherwise, or when you otherwise communicate with us via form, e-form, email, phone, or otherwise, we store a copy of our communications (including any call recordings or emails, if any, as permitted by applicable law).
- Information related to location: You may also choose to provide location related information, including but not limited to access to GPS, which will enable us, with your consent, to offer customized offerings for specific services where location data is relevant and/or applicable such as informing you whether services on the Platform that you have expressed interest in may be availed of at or near your location.
Information we collect automatically:
- Device and Log information: When you access our Platform, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Platform — for example, when you create or make changes to your account information on the Platform.
- Usage information: We collect information about your usage of our Platform. We also collect information about what happens when you use our Platform (e.g., page views, support document searches, features enabled for your account, interactions with other parts of our Services) along with information about your Supported Device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to provide our Platform to you, get insights on how people use our Platform so that we can make our Platform better, and understand and make predictions about User retention.
- Location information: We may determine the approximate location of your Supported Device from your Internet Protocol (IP) address. We may collect and use this information to calculate how many people visit from certain geographic regions or to improve our Platform Services.
- Information from cookies & other technologies: We may collect information about you through the use of cookies and other similar technologies. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. For more information on our use of cookies and similar technologies, please refer to Cookie Policy.
Information we collect from other sources:
We might receive and collect information about you from other sources in the course of their services to us or from a publicly available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site or a Google service if you connect to the Services through that site or if you use the Google sign-in.
Basis of Collection and Processing of Your Personal Information
We collect and process your Personal Information based on the following legal parameters depending upon the nature of Personal Information and the purposes for which it is processed:
Basis for collection:
- Consent: We rely on your consent to process your Personal Information in certain situations. If we require your consent to collect and process certain Personal Information, as per the requirements under the applicable Data Protection Laws, your consent is sought at the time of collection of your Personal Information and such processing will be performed where consent is secured.
- Compliance with a legal obligation: Your Personal Information may be processed by us, to the extent that such processing is necessary to comply with a legal obligation.
Processing of your Personal Information:
We may process your Personal Information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
- Because it is necessary to perform the Services you have requested or to comply with your instructions or other contractual obligations between you and us;
- To comply with our legal obligations as well as to keep records of our compliance processes;
- Because our legitimate interests, or those of a third-party recipient of your Personal Information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
- Because you have chosen to publish or display your Personal Information on a public area of the Platform, such as a comment area;
- Because it is necessary to protect your vital interests;
- Because it is necessary in the public interest; or
- Because you have expressly given us your consent to process your Personal Information in a particular manner.
We do not use Personal Information for making any automated decisions affecting or creating profiles other than what is described in this Policy.
Who We Share Your Data With
We share certain data about you with instructors, other students, companies performing services for us, clarus-ventures affiliates, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:
With Your Instructors:
We share data that we have about you (except your email address) with instructors or teaching assistants for educational content you access or request information about, so they can improve their content for you and other students. This data may include things like your country, browser language, operating system, device settings, the site that brought you to clarus-ventures, and certain activities on clarus-ventures, like enrolled courses and course review. We will not share your email address with instructors or teaching assistants. (Account Data; System Data; Usage Data; Approximate Geographic Data)
With Other Students and Instructors:
Depending on your settings, your Shared Content and profile data may be publicly viewable, including to other students and instructors. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable. (Account Data; Profile Data; Shared Content)
With Service Providers, Contractors, and Agents:
We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. (All data categories)
With clarus-ventures Affiliates:
We may share your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services. (All data categories)
With Business Partners:
We have agreements with other websites and platforms to distribute our Services and drive traffic to clarus-ventures. Depending on your location, we may share your data with these trusted partners. (Account Data; Learning Data; Communications and Support; System Data)
With Credit-Granting Organizations for Continuing Education:
If you take a course to fulfill a continuing professional education requirement, we may share that information upon request of the organization granting the continuing education credit. (Account Data; Learning Data)
With Analytics and Data Enrichment Services:
As part of our use of third-party analytics tools like Google Analytics and data enrichment services like ZoomInfo, we share certain contact information or de-identified data. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner. (Account Data; System Data; Usage Data; Cookie Data)
To Power Social Media Features:
The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy. (System Data; Usage Data; Cookie Data)
To Administer Promotions and Surveys:
We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey. (Account Data; Sweepstakes, Promotions, and Surveys)
For Advertising:
If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and to undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads. (System Data)
For Security and Legal Compliance:
We may disclose your data (all data categories) to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of clarus-ventures, our users, employees, members of the public, or our Services;
- We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or
- Required or permitted by law.
During a Change in Control:
If clarus-ventures undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence). (All data categories)
After Aggregation/De-identification:
We may disclose or use aggregated or de-identified data for any purpose.
With Your Permission:
With your consent, we may share data to third parties outside the scope of this Privacy Policy. (All data categories)
If you click on any links to third-party sites, the collection, use, and disclosure of your personal data is governed by the third-party’s privacy policy.
Security Precautions and measures
Our Platform has reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws. Further, whenever You access Your account on the Platform or any information relating to it, We offer the use of a secure server. We cannot however ensure or warrant the security of any information You transmit to the Company or guarantee that Your Personal Information and/or other Non-Personal Information provided for availing the Services or accessing the Platform will not be accessed, disclosed, altered or destroyed by a breach of any of Our security measures and safeguards. It is further clarified that You have, so long as You access and/or use the Platform (directly or indirectly), the obligation to ensure that You shall, at all times, take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information.
When Transaction Information is being transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the sharing of Your information with third party service providers, including payment gateways, to process payments and manage your payment-related information. We take various steps and measures to protect the security of your information from misuse, loss, unauthorised access, modification or disclosure. We use the latest secure server layers encryption and access control on our systems. Please do not share your Account’s login, password, OTP details or credentials with anybody.
While We observe reasonable security measures to protect Your Personal Information on all our digital platforms, security risks may still arise for reasons outside of our control such as hacking, virus dissemination, force majeure events, breach of firewall etc. Please note that the above mentioned measures do not guarantee absolute protection to the Personal Information. The Company assumes no liability or responsibility for disclosure of Your information due to errors in transmission, unauthorised third-party access, or other causes beyond its control. You play an important role in keeping Your personal information secure. You shall not share Your Personal Information or other security information for Your account with anyone. The Company has undertaken reasonable measures to protect Your rights of privacy with respect to Your usage of the Platform controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful disclosures of Your personal information made by any third parties who are not subject to Our control.
You agree to notify us immediately in case of any unauthorized or illegal access/ use of your account or any breach of security arising due to your action/ inaction. We shall notify you and/or the appropriate authority in case of any breach of security, data at our end and in accordance with such timelines as may be prescribed under applicable law(s)
This Privacy Policy and the security controls and practices implemented by Us to Protect Your Personal Information shall be the reasonable security practices and procedures under section 43A of the Information Technology Act, 2000.
You shall not host, display, upload, modify, publish, transmit, store, update or share any information that:
- belongs to another person and to which You do not have any right.
- is obscene, pornographic, paedophilic, invasive of another’s privacy including bodily privacy, insulting or harassing on the basis of gender, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or promoting enmity between different groups on the grounds of religion or caste with the intent to incite violence.
- is harmful to child.
- infringes any patent, trademark, copyright or other proprietary rights.
- deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any misinformation or information which is patently false and untrue or misleading in nature.
- impersonates another person.
- threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign States, or public order, or causes incitement to the commission of any cognizable offence, or prevents investigation of any offence, or is insulting other nation.
- contains software virus or any other computer code, file or program designed to interrupt, destroy or limit the functionality of any computer resource.
- violates any law for the time being in force.
Your Rights
You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain third parties. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.
Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.
To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data claiming mechanism.
Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings on that platform.
If you have any questions about your data, our use of it, or your rights, contact us at clarusventures@gmail.com.
Accessing, Updating, and Deleting Your Personal Data
You can access and update your personal data that Udemy collects and maintains as follows:
To update data you provide directly, log into your account and update your account at any time.
To terminate your account:
If you have any issues terminating your account, please contact our Support Team.
Please note: even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users (including comments on content); (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.