Privacy Policy

Welcome to Pupilfirst LMS’s website! This website is owned and operated by Pupilfirst Pvt. Ltd., a private limited company having its registered office at 1st Floor, C M Complex, Kalavath Road, Palarivattom, Kochi (“Pupilfirst”, “we”, “us” or “our”). By accessing our website, viz, lms.pupilfirst.org and/or *.pflms.com (collectively the “Website”) and/or Platform, and/or Pupilfirst Services, all users (“you”/”your”/”Users”) including those who are just browsing as well as registered users who avail Pupilfirst Services and/or users who are in any manner connected with and/or contribute to the use of the Website, Platform and/or Pupilfirst Services are agreeing to be bound by this Privacy Policy, Terms and Conditions of use of the Website (“Terms”) and all applicable laws and regulations. The capitalized words used and are not defined herein shall have the same meaning as assigned to such words in the Terms.

Pupilfirst is committed to respecting and protecting your privacy. This Privacy Policy will explain how Pupilfirst collects, uses and discloses the personal data shared, or communicated by you through this Website.

You can browse the Website without telling us who you are or revealing any personal data about yourself. If you give us your personal data, then, you are not anonymous to us. You always have the option to not provide information by choosing not to use a particular service or feature on the Website. You may need to provide us some of your personal data during the course of using some of the services provided on our Website or while registering with us.

1. What data do we collect?

The personal data (“Data”) we collect is likely to include:

• Cookie IDs
• Full Name
• Email address
• Profile Description
• Business and Billing Address
• School Name
• Zip/PIN code
• State
• Country
• Avatar (image)
• Payment mode through which payment is done on our Platforms
• Technical data like your IP address, login data, date and time of visiting our Platform(s)
• Usage data including information on how you use our Platform(s) and the Pupilfirst Services
• Free form information which Users voluntarily choose to share on the Platform through the features of the Platform such as ‘Community’

Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation. We do not intentionally collect any sensitive personal data from you through the Website.

2. How do we collect your Data?

You directly provide our company the Data when you:

• Use or view our Website via your browser’s cookies
• Register up for an account on lms.pupilfirst.org or enroll in a course or assist in a course in any capacity (like a coach, teacher etc.) powered by the Pupilfirst platform.
• When you subscribe to a paid Pupilfirst plan, we will collect certain personal information (name, address, zip code, state, country) from you for the purposes of billing your subscription fees and any payment service fees, such as your business and billing address. You’ll also need to provide certain payment-related information directly to our third party-payment processors.
• We use third party payment processors like Stripe to process payments through the Pupilfirst Platform - the third party processor provides us with information related to the payment status of your account; this information includes your payment card type and last four digits, payment expiration date, zip code, approximate location based on IP address, country of origin, and any email address associated with the payment type. For security purposes, Pupilfirst does not collect or receive any sensitive payment information, such as your complete card number or authentication data. Our third-party payment processors are independent from Pupilfirst and have their own privacy processes. For additional information about how your payment information is processed and stored, we recommend that you review the applicable payment processor’s Privacy Policy.
• When you enroll in a course, Pupilfirst will collect personal information relating to your participation such as courses enrolled in, quiz results, target feedback, comments progress and certifications.
• You may choose to provide us with other personal information. For example, we may collect your name, email address and other personal information when you fill out a survey, participate in a Pupilfirst-sponsored contest or promotion, request customer support, or otherwise communicate with us.
• Add additional profile information (like your ‘avatar’).
• We collect the data of visitors on the Website using technology such as cookies and IP addresses. If you would like to know more about our use of cookies and how to manage them, please read our Cookie Notice.

3. How will we use your Data?

We use the data we collect to:

• Verify your identity (for example, when you return to the Website, and have already logged in).
• Providing personalized content and information to you.
• Send you service messages regarding your account, for example, if you attempt to reset your password, we’ll need to send you an email at your email address provided.
• If you are a student enrolled in a course powered by Pupilfirst, Pupilfirst will share certain personal information about you (“Student Data”) with the School Admin and Coaches to allow them to provide you with their services. The set of personal information that we share with them are limited to the following:
  • Account information, including your name and email address.
  • Information about your participation in the enrolled course, including target completion status, course progress, quiz results, and certificates.
  • Any messages you exchange with the coaches through Pupilfirst.
• We use personal information to investigate, respond to, and resolve customer queries, send you technical notices and security alerts, and provide other support and administrative services.
• We use personal information to develop targeted advertising both on and off our Platform about Pupilfirst Services, and to communicate with you about our products, services, offers and promotions, including making recommendations about Pupilfirst Services you may be interested in.
• Deal with any query or complaint you submit to our support team
• To store and use information about any service errors or interruptions that you have experienced in order to help us create fixes and to make technical improvements to our Website.
• For complying with applicable laws.

4. What is our legal basis for processing your Data?

• Consent, and the performance of a contract: When you sign up at our Website, we will need to process your details to provide you with our service.
• Legitimate interests: We may process your Data to ensure that your interactions with our Website or service are optimal. For example, if you encounter bugs or crashes on the Website, we may use your personal information to debug the instance, in order to prevent future failures.

5. Who will we share your Data with?

Pupilfirst only shares your personal information with third parties under the circumstances described below. We do not sell or otherwise disclose personal information we collect about you for monetary or other valuable consideration.

With School Admins / Coaches

If you are a student enrolled in a course powered by Pupilfirst, Pupilfirst will share certain personal information about you with the School Admin to allow them to provide you with their services. The set of personal information that we share with them are limited to the following:

• Account information, including your name and email address.
• Information about your participation in the enrolled course, including target completion status, course progress, quiz results, and certificates.
• Any messages you exchange with the coaches through Pupilfirst.
• Questions you ask in the Community page and associated discussions.

Pupilfirst does not disclose any other types of personal information about Students to other platform users. Students are to assume full responsibility for the disclosure and use of any other personal information the Student chooses to disclose to any other users, which at all times shall be subject to the terms of this Privacy Policy and our Terms of Use.

With Students and Other Users

When you use Pupilfirst Services to publish courses, information contained in your courses will be viewable to users who are given access to your courses.

Please keep in mind that all of the information that you share or content that you publish public portions of our platform becomes public information. Because this information is publicly available, we cannot control how others treat it. We ask you to exercise care in deciding what personal information you choose to share, and refrain from sharing your sensitive personal information and those of others.

With Integrated Services

Your personal details may be shared with third party organisations we have contracted to provide services to us which include processing Data. For example, to send you the emails you have signed up for. Only companies who can provide adequate safeguards will be used to ensure your Data is stored and handled securely. We recommend that you read the terms of use and privacy policies of those third party services to understand how they collect, use, and share your personal information.

With Your Consent

Pupilfirst may send your personal information to a third party when you give us consent to do so or at your direction. For example, this may occur when we complete a transaction at your request.

We may disclose your Information to the extent such disclosure is reasonably necessary to enforce our Terms or Privacy Policy and in order to respond to claims of any other user or third-party. We will not transfer your personal data to third parties (other than as set out in this Section 5 of the Privacy Policy) unless we have your permission or are required by law to do so.

With Service Providers

We may share personal information with vendors, consultants, payment processors, and other service providers that provide us with certain services and process personal information on our behalf. These services may include providing customer support, performing business and sales analysis, supporting our website functionality, facilitating payment processing, and supporting contests, surveys, and other features offered on our Platform.

These service providers are not permitted to use your personal information for any other purpose, and their use of such personal information will be subject to appropriate confidentiality and security measures.

With Business Partners

We sometimes partner with third parties to offer you events, promotions, contests and other programs. To participate in these offers, you may be required to provide your email address and other personal information. We will only share your email address and other personal information with a business partner when you expressly authorize us to do so.

With Advertising and Analytics Partners

We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device. For more information on our use of cookies and similar technologies, please refer to our Cookie Policy.

With Affiliates

We may share any information with our other affiliates to help detect and prevent identity theft, fraud and other potentially illegal acts; to prevent abuse of the Website; and to facilitate joint or co-branded services.

We may share personal information with our parent, subsidiaries, affiliates, and other companies under common control and ownership, subject to the terms of this Privacy Policy.

We may also share your personal information in connection with a substantial corporate transaction, such as a sale of our business, a divestiture, merger, consolidation, or asset sale, in the event of bankruptcy, or in preparation for any of these events. Any other entity which buys us or becomes part of our business will have the right to continue to use your personal information, but only in the manner set out in this Privacy Policy unless you agree otherwise.

Legal Disclosures

Pupilfirst may be required to disclose personal information if directed by a court of law or other governmental entity. Without limiting the foregoing, we reserve the right to disclose such information where we have a good faith basis to believe that such action is necessary to:

• Comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests
• Protect and defend Pupilfirst’s or a third party’s rights and property, or the safety of Pupilfirst, our users, our employees, or others
• Prevent, detect, investigate and take measures against criminal activity, fraud and misuse or unauthorized use of our Platform and/or to enforce our Terms of Use or other agreements or policies
• To the extent permitted by law, we will attempt to give you prior notice before disclosing your information in response to such a request.

6. How do we store your Data and will your Data be sent overseas?

As you are probably aware, services on the internet are accessible globally so collection and transmission of personal data is not always confined to one country.

By using this Website or any website we link through to, your Data may be processed in or transferred to other countries and you agree to your Data being transferred or processed in this way.

The Data collected directly from you through the Website, shall be stored in the US.

7. How long do we keep your Data for?

We will keep your Data only for as long as it is relevant and useful for the purpose for which it was originally collected. Local data retention policies and applicable privacy laws will typically dictate the length of time Data is retained. Your personal data will be retained in compliance with privacy laws and regulations.

After the end of the data retention period, your Data will be deleted.

If your account appears to have not been used for 5 years, we will try and contact you to check whether it is still in use. If we fail to contact you, and / or you do not sign in after our check-in email, we will delete your account and all personally identifiable information.

8. What are your data protection rights?

• Right to confirmation and access: you have the right to request a copy of the Data that we hold about you.
• Right to correction and erasure: you have a right to correct Data that we hold about you that is inaccurate or incomplete, and you have a right to request the erasure of personal data.
• Right to data portability: you have the right to have the Data we hold about you transferred to another organisation.
• Right to withdraw your consent: you have the right to withdraw your consent at any time.
• Right to be forgotten: you have the right to prevent the continued disclosure of your Data.

The above rights are not absolute and certain exemptions will apply.

9. How to contact us

If you wish to exercise your data protection rights, or have doubts about this Privacy Policy, please contact us at [email protected].

In accordance with Information Technology Act, 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Name: Hari Gopal
E-mail address: [email protected]

10. Disclaimer

We are committed to making sure your Data is secure. To prevent unauthorized access or disclosure, we have technical and organizational measures to safeguard and secure your Data. All our personnel and third parties that we engage to process your Data are obliged to respect your data’s confidentiality. Due to the existing environment, we however cannot ensure that your Data will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we use industry standard practices to protect your privacy, no method of transmission over the internet, or method of electronic storage, is one hundred percent secure. If you believe your Data has been compromised, please contact us at the details set forth in the How to Contact Us section in this Privacy Policy. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

We use commercially reasonable safeguards to help keep the Data collected through the Website secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, we cannot ensure the security of any Data you transmit on the Website or guarantee that Data on the Website may not be accessed, disclosed, altered, or destroyed.

A Coach or a School Admin or Teacher may collect additional information and personal data from Students or other users who enroll or take part in his/her course through Pupilfirst Platform, which shall be outside the scope and control of Pupilfirst. Please refer to the respective privacy policies of School Admins for further information on the data collected and used by such School Admins.

11. Privacy policies of other websites

This Website contains links to other websites. Our Privacy Policy applies only to our Website. If you click on a link to another website, you shall be bound by the privacy policy of that website.

12. Changes to our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make substantial changes to this Policy that we at our sole discretion determine, which may affect your privacy, and you are a registered user of this Website, then we will endeavour to notify you of the same through email. Irrespective of whether we notify you via email or not, the updated Privacy Policy will always be made available to you on this Website.

Your continued use of our services and this Website shall be deemed your acceptance of the updated Privacy Policy.

This Privacy Policy was last updated on December 10, 2020.

Cookie Notice

This cookie notice (“Notice”) is for visitors and users of the Website. It sets out how we use cookies. Capitalized terms not defined here shall have the same meaning assigned to it in our Terms.

1. What are cookies?

A cookie (also known as browser cookie) is a small piece of data (essentially text files) sent from a website and stored on your browser. Cookies allow websites to remember information, such as recognizing you even when you reload web pages.

When you visit our Website, we may collect information from you automatically through cookies or similar technology. You can learn more about cookies at this website.

2. How do we use cookies?

We collect a number of cookies from our users for various reasons, including serving you content tailored to your own specifications for improving your overall experience of the Website. Amongst other things, the cookies we use allow users to register to enrol in our Public Courses.

We do our utmost to respect users’ privacy, so we only use cookies that are strictly necessary. We believe that your experience of the site would be adversely affected if you opt out of the cookies we use.

3. What types of cookies do we use?

We use the following kinds of cookies on our Website:

Strictly necessary

• Pupilfirst cookies: These are cookies directly managed by our Website and are used for critical functionality like allowing you to sign into the Website, submit application forms, or upload files.
• Cloudflare cookies: Cloudflare is a third-party service we use to improve Website security and performance. You can learn more about how Cloudflare uses these cookies in this article

Analytics

• Google Analytics cookies: These cookies collect information that is used either in aggregate form to help us understand how our Website is being used or how effective our marketing campaigns are, or to help us customize our Website for you.

4. How to manage your cookies

You can use our cookie settings page to control which cookies we use. Strictly necessary cookies will always be enabled, whereas optional cookies can be disabled using this management page. You can also set your browser not to accept cookies, and this website will instruct you on how to remove cookies from your browser. However, some of our Website features may be severely degraded as a result.