1. General

In this policy, the words “we”, “our”, and “us” refer to Hotspot Infodot Pvt. Ltd., hereinafter referred to as “Company” and the privacy mechanism outlined identify personally identifiable or personal information that may be collected, how such information is used, and the choices You have regarding our use of this information.

In addition to the terms stated in Terms and Conditions provided under this Website/mobile application (together “Platform”), we are committed to protecting Your privacy. Only authorized representatives of the Company and on a need to know basis only use any information received from You and as consented by You. We constantly review our systems and data to secure Your personal information. In the event of any identified unauthorized use or disclosure of information or upon Your complaint, we will investigate any such complaint or such actions with a view to prosecuting and/or taking civil proceedings to recover damages against those responsible. Any User who does not agree with any provisions of this Privacy Policy and the Terms and Conditions, is required to leave the Platform immediately. Should You disagree with this Policy (defined below) and still continue to access the Platform and provide Your personal information, the Company disclaims all the liabilities arising therefrom and it shall be assumed by Your continued use of the Platform that You have accepted the Policy and any other online terms and conditions available on the Platform.

If any information You have provided or uploaded on the Platform violates the terms of this Policy,

Company may be required to delete such information upon informing You of the same and revoke

Your access if required without incurring any liability to You.

 

1. Applicability

This privacy policy (“Policy”) applies to all Users who access the Company Platform and are therefore required to read and understand the Policy before submitting any Personal Information (defined hereinafter). By submitting Personal Information, You are consenting to the use and processing of such information in accordance with this Policy. If You have inadvertently submitted any Personal

Information to the Company prior to reading the Policy statements set out herein, or You do not

agree with the manner in which the Personal Information is collected, stored or used, then You may

access, modify and delete all information stored about You by writing to us at

info@hotspotinfo.com. The company is keeping personal data of the User, and every User is also entitled to require to delete and destroy all such information (but not that of other Users). This Policy applies to the Platform and any other services that are owned and operated by the Company. Third party websites may place their own cookies or other files on the Users’ computer, collect data or solicit personal information from the Users, for which the Company is not responsible or liable. Accordingly, the Company does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does the Company guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by the Company of the website, the website’s provider, or the information on the website. The company encourages the User to read the privacy policies of each such website and the User understands that its solely such third party who is responsible to the User in this regard. The company has taken reasonable precautions as per applicable Indian law and implemented industry standards to treat Personal Information as confidential and to protect it from unauthorized access, improper use or disclosure, modification and unlawful destruction or accidental loss of the Personal Information.

 

1. Access

A User is allowed to access the Platform, as a guest and without creating an account on the Platform

or providing any Personal Information, the Company takes no responsibility or validate the information provided by the guest, except as otherwise required under any law, regulation or an order of competent authority. In order to have access to all the features and benefits on our Platform, a User is required to first create an account on our Platform. To create an account, a User is required to provide Personal Information as may be required during the time of registration. Other information requested on the registration page, including the ability to receive promotional offers from the Company is optional. The Company may, in future, include other optional requests for information from the User to help the Company to customize the Platform to deliver personalized information to the User. Without User’s agreement, the Company will not share, rent or sell any Personal Information with third parties in any way other than what is disclosed in this Policy. The Company may keep records of telephone calls received and made for making enquiries, registered courses, feedback or other purposes for the purpose of rendering services effectively and efficiently.

 

1. Personal Information

“Personal Information” shall mean the information which identifies the Username, identification

number, email address, age, gender, or phone number provided to the Company at the time of registration or any time thereafter. Personal information may include “sensitive personal information or

data” as defined under the Information Technology (Reasonable Security Practices and Procedures

and Sensitive Personal Data or Information) Rules, 2011 and in this context, includes passwords or

any financial account information provided by You during registration. When you enroll in and take

courses, we collect certain data including which courses, assignments and quizzes you’ve started

and completed; course purchases and credits; subscriptions; course certificates; your exchanges with instructors, and other students; and essays, answers to questions, and other items submitted to satisfy course requirements. We request You to not provide us with any Personal Information unless specifically requested by us. In such events, we bear no liability to such Personal Information provided by You.

 

1. Automatic Information Collection

Our system collects information that is sent over the internet without Your control. Some examples

of the information we collect and analyse include the Internet protocol (IP) address used to connect

Your computer to the internet; login; email; password; computer and connection information such

as browser type and version, operating system, and platform; course enrolled history, which we

sometimes aggregate with similar information from other users to create features, reports such as

popular courses, most used features etc; the full Uniform Resource Locator (URL) click stream to,

and from our Platform, including date and time; cookie number; courses or videos You viewed or

searched for; the email id You used to call our customer service.

During some visits we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain page, course

and videos, page interaction information (such as scrolling, clicks and mouse overs), and methods

used to browse away from the page.

 

1. Information Security

To protect the security of Your Personal information during transmission, we use Secure Sockets

Layer (SSL) software, which encrypts information You input. To prevent unauthorized access to

sensitive information, it is important for You to monitor those who have access to Your password

and to Your computer, laptop or any other device through which Your account can be accessed. Be

sure to sign off when finished while using a shared computer.

However, please do note that given the nature of internet transactions, the Company does not take

any responsibility for the transmission of information including Personal Information shared by

You other than as set forth in this Policy. Any transmission of information on the internet is done at

Your risk and shall not be responsible for the circumvention of the privacy settings or security measures either by You or any third-party.

 

1. Use of your personal information

While availing our services You will provide access to the Company with Your Personal Information. If that information is wrong, You can request us to modify or delete the same. The Company will take all reasonable measures to ensure that the Personal Information is modified and used for rendering services to You and as otherwise in compliance with laws. When editing or deleting Personal Information, we may ask You to verify Your identity before we can act on Your request. The Company may at its discretion reject any request that is contrary to law, requires un-reasonable technical efforts. We do not assure that we will delete all residual copies and archives made by any third party without our knowledge and consent. We never retain Your Personal Information longer than it is required for the purposes of providing services through the Platform or as required by applicable Indian law. At times, we may also require to transfer Your Personal Information to third-party service providers, for instance to authorize transactions we may share Your financial data with such third-party providers. You hereby consent to Your transfer of Personal Information in all such instances. the Company carries out all such transfers strictly in accordance with law. The Company shall use Your Personal Information to ensure services with respect to the Platform are presented to You in the most effective manner, to secure the Platform and make improvements, to carry out our obligations to You, and to communicate with You. The said communication can either be by calls, text or emails and for purposes which include transactional, service, or promotional calls or messages. If at any time You wish to not receive any communication from our end You can opt-out of the same by writing to us on info@hotspotinfo.com

 

1. Exceptions

Your Personal Information may be shared with third parties who have a need or authority to receive

such information, if we have a good-faith belief that access, use, preservation or disclosure of the

information is reasonably necessary to comply with (i) in response to any authority having to receive such information under law (ii) any order of court (iii) detect, prevent, or otherwise address fraud, security or technical issues (iv) protect against harm to the rights, property or safety of the Company our users or the public as required or permitted by law. User choices with regard to access of information The Company does not make any unsolicited calls or otherwise market any products or services, except for in relation to the purpose for which such information has been provided or taking any feedback, addressing any complaints, informing You about new features or free/paid courses. User shall not disclose their Personal Information to any third parties that is not authorised by the Company and verify the identity of such person who seek information. The Company will communicate with the Users through call, SMS, email or notices posted on the Platform or through any other means available, which shall include but not be limited to text, other forms of messaging, calls etc. The Users can change their e-mail and contact preferences at any time by logging into their account or by emailing at info@hotspotinfo.com. The Company may, if You so choose, send direct mailers to You at the address given by You. You have the option to ‘opt-out’ of this direct mailer by way of links provided at the bottom of each mailer. We respect Your privacy and to the extent that You choose not to receive such mailers, we will take all steps to remove You from the list. Should You evidence any violation of our terms and policies, please write to us at info@hotspotinfo.com and report such incident. All the information provided to the Company by You, You as a User confirms that the same including sensitive Personal Information, is true, accurate and voluntary. User has the right to withdraw information at any time, in accordance with the terms of this Policy and the Terms of Service. Report, Analysis & Confidentiality T he Company may have to use Personal Information without reference to any persona or identity for research, statistical analysis improving the Platform of functionalities offered thereon and business intelligence purpose and may transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. All the Company employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every User’s sensitive personal data and information. Sharing of Information The Company may also disclose or transfer User’s personal and other information which a User provides, to another third party as part of reorganization or a sale of the assets of the Company corporation division or company. Any third party to which the Company transfers or sells its assets will have the right to continue to use the personal and other information that a User provide to us. To the extent necessary to provide Users with the services on the Platform, the Company may provide User’s Personal Information to third party contractors who work on behalf of or with the Company to provide Users with such services, to help the Company communicate with Users or to maintain the Platform. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Platform, including the providers of online communications services, online payment gateway services, will have rights to use and disclose the Personal Information collected in connection with the provision of these services in accordance with their own privacy policies.

Furthermore, please note that we cannot control the actions of other Users of the Platform with

whom You may choose to share Your Personal Information, and any such actions on Your behalf

shall be solely Your responsibility.

Interest-Based Ads

On unaffiliated sites, the Company may display interest-based advertising using information You

make available to us when You interact with our Platform, content, or services. Interest-based ads,

also sometimes referred to as personalised or targeted ads, are displayed to You based on information from activities such as subscription on our Platform, visiting sites that contain the Company

content or ads. In providing interest-based ads, we follow applicable Indian laws, as well as the

Code for Self-Regulation in Advertising by the Advertising Standards Council of India and the

Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising

Alliance (a coalition of marketing, online advertising, and consumer advocacy organizations).

Like other online ad networks, we use cookies, web beacons (also known as action tags or single-

pixel gifs), and other technologies (collectively, “cookies”). Cookies enable us to learn about what

ads You see, what ads You click, and other actions You take on our sites and other sites. This allows us to provide You with more useful and relevant ads. For example, if we know what ads You are shown we can be careful not to show You the same ones repeatedly. We do not associate Your interaction with unaffiliated sites with Your identity in providing You with interest-based ads. We do not provide any personal information to advertisers or to third party sites that display our interest-based ads. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalised ad or content are part of the group that the ad or content is directed towards (for example, users in eastern India who bought or browsed for literature books). Also, some third-parties may provide us information about You (such as the sites where You have been shown ads or demographic information) from offline and online sources that we may use to provide You more relevant and useful advertising.

Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that

appear on our sites directly to Your browser. They automatically receive Your IP address when this happens. They may also use cookies to measure the effectiveness of their ads and to personalise ad

content. We do not have access to or control over cookies or other features that advertisers and third

party sites may use, and the information practices of these advertisers and third party websites are

not covered by our Policy. Please contact them directly for more information about their privacy

practices.

Revision of terms & Grievance reporting The Company may update or amend this Policy at any time, with or without advance notice. In the event there are significant changes in the way the Company treats User’s personally identifiable information, the Company will display a notice on the Platform or send Users an email. The Company’s current Policy to all information that the Company has about Users and their account.

Notwithstanding the above, the Company shall not be required to notify the Users of any changes

made to the privacy policy. Should You have any concern or reject the changes in the privacy policy You can refuse to accept the amendments and opt for withdrawing Your Personal Information by writing to us at

 If You have any compliant or grievances with respect to Website or Privacy Policy, please contact

our Grievance Officer.