Privacy Policy
We understand that Your privacy is important. This Privacy Policy (“Privacy Policy”) aims to give you information on how Manipal Global Education Services Private Limited or Manipal MedAce (“Manipal MedAce”) collect, use, share processes and protect personal information that we collect, including on manipalglobal.com, manipalmedace.com and each of its respective sub-domains apps, social media, chats (the “Site(s)”), information we collect from websites of our University partners and information we collect from our referral partners. This policy does not apply to physical records provided to us through postal or courier means. Manipal MedAce is committed to maintain high level of confidentiality with respect to Personal Data or Information of our learner community, visitors, alumni, university partners, employees and faculty and other third parties in accordance with requirements of Information Technology Act, 2000 (as amended) and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (collectively “Act”). We encourage You to review this Privacy Policy before disclosing any personal information or sensitive personal information. This Privacy Policy is incorporated into our Terms of Service
1. Notice
1.1 This Privacy Policy is to inform You (“You/Your”) of the procedures regarding how we collect, use, share and retain and protect Your Personal Data or Information (“PI”) or Sensitive Personal Data or Information (“SPDI”) that we receive from You through your use of the Site(s), including any data that you provide through the https://www.manipalmedace.com website, that we sign-up for trial of our products and services, participate in our webinar. It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasion when we collect or process Personal Data or Sensitive Personal Data or Information. This Privacy Policy supplements all notices and is not intended to override them. We recognize the importance of PI including SPDI provided to us by a natural person and we collect no personal information about You unless You affirmatively choose to provide that information to us. By interacting with us regarding our services or enquiring about our software programs or during registration for the courses or by providing us with Your information, You consent to the collection, transfer, storage, and processing of Your personal information as stated in this Privacy Policy. We do not give, share, sell, or transfer any personal information to any unrelated third party. In this Privacy Policy “we” and “us” and “our” refers to Manipal MedAce (and incudes Manipal Global Education Services Private Limited), i (collectively “Manipal MedAce”),. Please read the information provided in our products, course, services, websites, applications and software for additional details. This Privacy Policy governs collection and use of PI and SPDI by Manipal MedAce and does not apply to Third Party or third party websites and Manipal MedAce does not make any representations about these third party practices and policies.
For the purposes of this Policy, “Personal Data” means your personal data and any personal data of your parents (as applicable for specific services)
1.2 Occasionally, we may use certain information that we have collected to send You information about programs or services offered by us.
1.3 If You are providing PI and are not a resident of India, Your country’s laws governing data collection differ from those in India, in particular, India may not provide the same level of protection as those in Your own country. By providing information to us, You are transferring Your personal data (including PI and SPDI) to India, and You consent to the transfer to, retention of and processing of Your data in the India.
1.4 For the purpose of providing services to You, we may transfer Your personal data (including PI and SPDI) to different jurisdictions, including jurisdictions that may not provide the same level of data protection as Your home country. When You submit PI and SPDI to us You are accepting that such data can be transferred across borders and applicable privacy laws of such territory shall apply.
2. Personal Information we collect
2.1 PI for the purposes of this Privacy Policy, refers to any information that relates to a natural person which either directly or indirectly, in combination with other information available or likely to be available, is capable of identifying such person. The specific kind of information collected will depend on the products or services used by You. The following are examples of the type of PI that may be collected such as name, date of birth, citizenship, phone number, residential/mailing address, email address, demographic information, academic qualifications or course you are pursuing. your work history.
2.2 SPDI for the purposes of this Privacy Policy, shall be the same as defined in the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SPDI”) Rules, as amended from time to time, such as:
(i) Password;
(ii) Financial information such as bank account or credit card or debit card or other payment instrument details;
(vii) Any detail relating to the above clauses as provided to us for providing specific services; and
(viii) Any of the information received under any of the above clauses by us for processing, stored or processed under lawful contract or otherwise.
Provided that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Information for the purposes of this Privacy Policy.
2.3 When You visit the Site, we automatically collect certain information about Your device, including information about Your web browser, IP address, time zone, and some of the cookies that are installed on Your device. Additionally, as You browse the Site, we collect information about the individual web pages that You view, and information about how You interact with the Site. We refer to this as “Device Information”.
3. Purposes of Collecting and Processing of Personal Information
3.1 Manipal MedAce will ordinarily collect PI and SPDI that it believes is necessary for any purpose connected with a function or activity necessary to deliver, promote or market services or to carry out primary business functions and/or activities, comply with applicable regulations or in capacity as a counterparty to agreement with individuals. Ordinarily, Manipal MedAce will collect such PI and SPDI about You when You provide it or You have consented to provide the information, as applicants, through online registration forms, through assessment, events, survey respondents, visiting the Site. To the extent that information requested is not required for Your participation in a given Manipal MedAce program /course, You will be told which information is optional. Should You fail to provide optional information certain Manipal MedAce programs or features of the site may not be available to You. In general, we would be collecting/handling/storing /using or transferring Your PI and SPDI for the following, including but not limited to:
(a) providing agreed services to You
(b) performing administrative functions of your application and registration and/or enquiry of any programs offered by us or our partners; responding to inquiry, made, for example, responding to a specific inquiry or providing you with access to specific course content and/or services you select; and
(c) Tracking both individual and aggregate attendance, progress and completion of a course, and analysing statistics on a student performance and the manner in which students learn.
(d) complying with legislative and regulatory requirements
3.2 Manipal MedAce engage other companies and individuals in addition to Manipal MedAce partners to perform functions on our behalf (each a third party and collectively third parties. They will require access to the Personal Data or Information needed to perform certain limited functions for Manipal MedAce. We may share PI and SPDI with third parties for legitimate business purposes, including for the following reasons or in the following circumstances:
- within our corporate family of companies including subsidiaries and affiliates that are related by common ownership or control to enable or support us in providing the Manipal MedAce services, which involves transferring your data outside India. We ensure your Personal Information is protected by requiring all our affiliates or group companies to follow the same, when processing your Personal Information. These group companies will ensure your Personal Information a similar degree of protection afforded as per applicable data protection laws of India.
- to vendors or third-parties who deliver or provide goods and services or otherwise act on behalf of or at the direction of Manipal MedAce, which third parties include, for example certain functions on our Site, including managing our learning management system providers, hosting training materials (viz., videos, presentations, courseware etc., processing information provided to us) training providers, partners, processing other transactions through the Site, providing or administering courses, third party event hosting sites, other third parties who may provide services in connection with other aspects as part of agreed Manipal MedAce services to you, purchases via third party providers, on web sites that are accessible from links on one of our Site; bank/credit card/credit providing entities processing payment; to Manipal MedAce employees, officers and directors, program coordinators and also to Manipal MedAce partners for legitimate interests where appropriate. These parties shall use Your PI and SPDI only for the specific purpose for which we supply the PI and SPDI to them and only in providing agreed services;
- with other visitors to the Site, course platform or our mobile learning app, to the extent that you submit comments, blogs, course work, or other information or content (collectively, “Your Postings”) to a portion of the Site, course platform or mobile learning app designed for public communications, and with other members of Manipal MedAce group/forum of which you are a member to the extent you submit Your Postings to a portion of the Site, course platform or mobile learning app designed for viewing by same classes forum /group members. If we re-post Your Postings originally made to non-public portions of the Site, course platform or mobile learning app or learning management system, we will post them without your real name and email (except with your express permission), however we may use your username without your consent.
- if You use any our career centre services, Your information may be accessible to potential employer or recruiters;
- to those who wish to determine if You are certified, Your certification status will be shared with those University partners who inquire or have enrolled as an academic partner with Manipal MedAce;
- to investigate potentially fraudulent or questionable activities or transactions;
- may use Your PI on an aggregate basis to provide third parties with information, such as to help us develop new features and content for the Sites, and to provide and other with aggregate information about our users and the usage patterns of the sites.
- With the parent company or affiliates of Manipal Global Education Services Pvt. Ltd. or with successors in the event of a merger, acquisition, or reorganisation, for their use consistent with this Privacy Policy.
3.3 Our Sites, products and applications and services may contain links to other third-party websites, products and services of interest (partner networks, payment gateways, vendor website). Manipal MedAce Site may provide links to website published by a third parties (including content providers and service providers such as those who process payments on behalf of Manipal MedAce) who is assisting in or providing certain services as part of program /course. Manipal MedAce has no control over the content displayed on such third party websites, nor over the steps, that are taken by such third-party websites to protect the privacy of Your information. Once You have used these links to leave our site, we encourage you to read privacy notice of every third party website you visit. Therefore you agree, we will not be held responsible for the protection and privacy of any information which You provide whilst visiting such other third party websites and such third party websites are governed by their own privacy practices of each of those third party websites you visit and use.
3.4 The PI and SPDI collected shall be used for the purpose for which it has been collected.
3.5 We may also use Your PI and SPDI to tailor Your experiences at our sites, to compile and display content and information that we think You might be interested in, and to provide You with content according to such preferences. We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This will enable us to decide which products, services and offers may be relevant for you. You may receive marketing communication (via email, telephone, direct mails, SMS or other method of communications to you) from us, if you have requested information from us or purchased products or services from us, if you have provided us with your details when you participated in a feedback or registered for a trial/evaluation or promotion and in each you, you have not opted-out of receiving that marketing.
3.8 While providing PI and SPDI of another natural person to Manipal MedAce, please ensure that You have the necessary concurrence of that natural person.
Please note that whenever you voluntarily disclose Personal Data or Information online for example on message boards, blogs, emails or in chats areas, such information can be collected and used by others By positing Personal Data or Information online that is publicly accessible, you may receive unsolicited message from other parties in return, for which Manipal MedAce is not responsible.
4. Disclosure of Personal Information
4.1 Manipal MedAce will not use or disclose Your PI and SPDI to a third party otherwise than for the purposes set out in this Privacy Policy or unless the disclosure is necessary for compliance of a legal obligation or where it is agreed to in the contract with You or as consented by You.
4.2 Mandatory disclosures and legal claims: We share personal information in order to comply with any court order or other legal process, subpoena, to comply with a request from our regulators, governmental request or any other legally enforceable demand. We also share personal information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
5. Access to Your Personal Information
5.1 You may review and correct or revise the PI and SPDI You have provided to us for the purpose of ensuring the said information is accurate and where necessary, kept upto date Any of the information that we process that you inform us is inaccurate, is either erased or rectified. Please contact us via dpo@manipalglobal.com should you wish to update, correct or withdraw your consent to collect and use your Personal Information (when you stop using any of our products and services on the Site(s). Please identify yourself and which Personal Data or Information about its use or disclosure is requested. Manipal MedAce shall not be responsible for the authenticity of the information You have supplied to it or to any person acting on its behalf.
5.2 You have the option not to provide Manipal MedAce with the PI and SPDI sought to be collected. You also have the option to withdraw the consent given earlier, provided it is sent to us in writing. In the event PI and SPDI which Manipal MedAce deems necessary for providing You with any service is not provided or if consent is withdrawn subsequently, Manipal MedAce reserves the right does not provide You with such services/benefits/amenities.
5.3 You have the right to communicate to us any changes to Your PI and SPDI or privacy preferences at any time.
5.4 Option Out: You may choose not to receive promotional communications from us by clicking on the unsubscribe link or contacting us as specified in the “Contact Us” section below. Please allow us seven (7) business days for changes to take effect. For certain services and related communications are an integral part of such services to which you subscribe and you continue to receive emails as part of ta particular portion of Services unless you cancel your account on the Site(s), even though you have opted out of the newsletters or email list. In case you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe links on any marketing communication for each email address that you have provided.
Our telephone communications with you may be recorded in accordance with this Privacy Policy. By choosing to use our telephone conversation, you acknowledge, agree and consent to terms of this Privacy Policy and the recording of any telecommunication conversation. In case you do not agree to terminate the telephonic conversation immediately and avoid any further telephonically communications.
6. Security and Retention of Personal Information
6.1 The security of Your PI and SPDI is important to us, however, no method of transmission over the internet communications or method of electronic storage is 100% secure. We cannot guarantee there will be not a breach of security, and we are not responsible for any breach of security or for the actions of any third parties. In order to prevent unauthorized access or disclosure, we have put in place suitable/reasonable physical, technical electronic and organisational security measures and managerial procedures as per applicable industry practices to safeguard, secure and protect the Personal Information we collect from You against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other unauthorised forms of processing, in accordance with applicable law. All electronic storage and transmission of Personal Data and Sensitive Personal Data is secured and stored on managed servers with controlled access and appropriate security technologies. We may at times, use Secured Sockets Lawyer encryption and/or transfer Personal Data in a non-human readable format for adequate protection. We regularly test our website, data centres, systems, and other IT assets for security vulnerabilities to address the same, however, we cannot guarantee its absolute security.
6.2 The storage mechanisms of the personal information (either in digital or hard copy) while the hard copies are held locally in our office in India and digital copies may be stored on servers which are hosted on the cloud (i.e, AWS servers in Singapore, or India or other cloud service providers and vendors in Singapore, India .
6.3 You also have an important role in protecting personal information. You should not share any username, password or other authentication data provided to You with anyone, and we recommend that You do not re-use passwords across more than one website or application. If You have any reason to believe that Your username or password on the Sites has been compromised, please contact us as specified in the “Contact Us” section below.
6.4 We will retain Personal Information so long as is necessary for the purposes set out in this Policy. In addition, we may retain and use Personal Information to the extent necessary to comply with our legal obligations and to comply with applicable laws, resolve disputes, and enforce our legal agreements and policies.
In some circumstances we may aggregate your Personal Information (so that it can no longer associated with you) for research or statistical purposes in which case we may use this information without any further notice to you.
7. Cookies and other technologies
Cookies are small files which are stored on a user’s computer (unless You block them). They are designed to hold a modest amount of data specific to a particular visitor and website and can be accessed either by the web server or the visitor’s computer. Manipal MedAce Sites may use ‘cookies’ and other technologies such as pixel tag and web beacons to identify You. We use third party cookies to understand and save Your preferences for future visits and compile aggregate data about site traffic and site interaction, tell us which parts of our Site visitors have visited, so that we can facilitate better site experiences and tools in the future and measure the effectiveness of advertisement and web searches. You may disable cookies through Your individual web browser options. We treat information collected by cookies and other technologies as non-personal information. However, to the extent Internet Protocol (IP) addresses or similar identifiers are considered personal information by local laws, we also treat these identifiers as personal information, for the purposes of this Privacy Policy. We use session cookies (which exist only in temporary memory while you navigate the Site and delete when you close the web browser) and persistence cookies (which data file is capable of providing Sites with user preferences, settings and information for future visits) to understand more about your activities on the Site(s). You may restrict cookies and pixel tags on your computer or purge cookies from the browser by adjusting your web browser preferences. However when you “turn off”, purge or disable cookies or pixel tags, although you may use the services, you may not be able to use all of the features, functions, or services available on the Sites(s).
8. Changes to this Privacy Policy
We may review, modify or amend this Privacy Policy from time to time at our discretion. When we make changes to this Privacy Policy, we will amend the revision date at the top of this page. We encourage You to periodically review this Privacy Policy to be informed about how we are protecting Your Personal Information By accessing this Site(s), after any changes are made, you signify your agreement on a prospective basis to the modified Privacy Policy and any changes contained therein.
9. Contact Us
If You have questions or concerns regarding this Privacy Policy, please contact our Privacy office.
To
Data Privacy Officer
Manipal Global Education Services Private Limited,
5th Floor, Prestige Emerald, #4,
Madras Bank Road (off. Lavelle Road),
Bangalore, Karnataka – 560 001
Email: dpo@manipalglobal.com