Privacy Policy

EMPASS PRIVACY POLICY


PRIVACY STATEMENT

Your privacy is important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate, disclose and make use of personal information. The following outlines our privacy policy.
Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.


WHO IS THIS POLICY ADDRESSED TO?

For the purpose of data protection legislation including the EU General Data Protection Regulation ('GDPR'), the data controller of your personal data is Empass Learning Private Ltd registered at G-72, Second Floor, South City-II, Gurugram - 122018, Haryana, INDIA (an MCA registered company with CIN U72500HR2017PTC070286 and known as Empass).

When we refer in this policy to 'you', we are referring to a customer of our services, or a person visiting and or using our website, mobile apps.
If you are a contact on our list and have not yet used any services offered by Empass and would like to cease receiving emails from us, please unsubscribe directly using the unsubscribe link in the email message, or contact the customer directly.
We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. We will make readily available to customers information about our policies and practices relating to the management of personal information.
We will only retain personal information as long as necessary for the fulfillment of those purposes. We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.



WHAT INFORMATION DO WE COLLECT?

We collect information from you when you register on our site, mobile apps, subscribe to our newsletter, login with your social media accounts or fill out an online form.
When registering on our mobile app or our website, as appropriate, you may be asked to enter your name, e-mail address, demographic information, mailing address, mobile and telephone number, employment information and credit card information.
Like most websites, we use cookies and/or web beacons to enhance your experience, gather general visitor information, and track visits to our Service.


WHAT DO WE USE YOUR INFORMATION FOR?

Any information we collect from you may be used in one of the following ways:
  • To personalize your Empass experience. This information helps us to better respond to your individual requirements.
  • To improve our mobile apps and/or websites. We continually strive to improve our offerings based on the information and feedback we receive from you.
  • To improve our customer service levels. Your information helps us to respond quickly and consistently to any of your service requests and support needs.
  • To process transactions that are carried out on our/our partner websites. We confirm that your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever without your consent, other than for the express purpose of delivering the requested service.
  • To send periodic emails, mobile notifications on your email address and mobile number you provide for registration, will only be used to send you information and updates pertaining to the service you requested
  • If you decide to opt-in to our mailing list, you will receive email that may include company news, updates, related product or service info, etc.


Should you decide, at any time after subscription, that you would like to unsubscribe from receiving future emails or app updates, we have included a detailed unsubscribe instructors at the bottom of each email.
With the usage of the Empass website, mobile apps on iOS, Android or other devices, it is explicitly understood that the best method of usage for any mobile app is performed over a Wi-Fi connection. Although you may use the app with your mobile data plan, your wireless carrier may charge you fees if your mobile data plan is exceeded because of your use of the app(s) when not on Wi-Fi. No matter which method you use to connect to our mobile app and platform, the apps and services we provided come with the disclaimer of "use at your own risk" and services are provided "as-is."

With respect to capturing your demographic information and/or text, voice, video responses on mobile or web apps as well as through contact forms or contest forms in the app or website, Empass Learning will NOT sell your demographic information to third parties or use your personally identifiable information for any other purpose for what the information is intended when it is requested.

Any personally identifiable information (PII) you submit through our web site(s), or mobile apps, are used solely for assessments, quizzes, contests and digital promotion purposes.

On Contact Us forms or request for demo forms, personally identifiable information is only used internally to disseminate your message to the correct department so that the message you submit to reaches the proper destination. For personally identifiable information you submit via the mobile apps or our online web site(s), the demographic information captured is only stored internally or visible to clients who sponsor the specific contests, learning courses and job opportunities to you under a paid and contracted relationship with Empass Learning.

On registration you agree to:
  • Making your profile information searchable to clients of Empass who offer assessments, contests or learning courses to view the participant performance and details.
  • Additionally, other clients might be in a commercial relationship with us by way of sponsorship or subscription services and might contact you via email, telephone and/or post.
  • You will automatically receive transactional and promotional contacts/mails that could include contest information, job alerts matching your performance on our platform and learning recommendations by mobile, email or calls.
You may remove yourself from the promotional mailer, email and mobile database and make yourself non-searchable by writing to us on play@empass.mobi

HOW DO WE PROTECT YOUR INFORMATION?
We implement variety of security measures to maintain the safety of your personal information when you register, play a game, buy a product or service from our mobile apps or websites to safeguard your personal information.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted before being passed onto any Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.

After a transaction, your private information (credit cards, social security numbers, financials, etc.) will remain secure and not be shared or used anywhere without your permission.


PAYMENT INFORMATION

When using our paid service, you will be asked for financial details such as credit/debit card information. Our payment processor, Razorpay, carries out the processing of these payments. We do not store any credit or debit card information on our servers. Razorpay Software Pvt. Ltd. has been validated for Payment Card Industry Data Security Standard (PCI DSS) 3.2 compliance by ControlCase. Their security assurances and Privacy policy is available on their website (www.razorpay.com)

We might use other payment providers in future for international currency payments and the chosen provider will undergo rigorous checks to ensure that the security of your information and money transacted is handled professionally and suitably.


RETARGETING

Our website uses retargeted advertising provided by Facebook and Google. As a result of this retargeting, you may see ads for our services on other sites such as Facebook. This happens in one of two ways:

One way is that our retargeting provider will read a cookie that is already in your browser, or they will place an anonymous cookie or 'pixel' in your browser when you visit our site. This can only happen if your browser is set to let it happen - you can control your settings in your browser to stop this.

The other method of retargeting is to use your email address to match Empass ads to you when you browse other sites. This involves us sharing your email address with Facebook and Google. This form of retargeting is generally used to update you on new functionality added to the Empass platform.

Conversely, we also use Facebook to ensure that we don't present some Empass ads to our existing customers. Again, this involves our sharing your email address with Facebook.


LOCATION OF YOUR DATA

Your PII and data is stored on the secure servers of Amazon Web Services ("AWS"). We don't, under any circumstances, sell or share your data. If someone complains or contacts us, only then will we respond to that person. Only you, and our authorised employees, have access to view your marketing lists.

You may export (download) your PII data from Empass at any time. We'll only ever use and disclose the information in your data for the reasons listed in this section or in the section entitled "How we use your personal information" above.

We will rarely use or disclose the information in your personally identifiable data to send our own informational and promotional content. We may also be required to disclose it to law enforcement or regulatory bodies. We will only do so if legally required.

We may conduct analysis on your use of the service and the results generated by your emails sent by means of the service. This analysis is conducted solely on an aggregated and anonymised basis.



DO WE USE COOKIES?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

We use cookies to help us remember and process the information on your dashboard, understand and save your preferences for future visits, keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experience and tools in the future. We may contract third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

If you prefer, you can choose to have your computer want you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if your turn your cookies off, some of our services may not function properly.

Cookies and other Tracking technologies may record information such as Internet domain and host names; Internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our Web site and your Web experience. We may also analyze information that does not contain Personal Information for trends and statistics.



THIRD PARTY LINKS

Our service provides you with links to other, third party, sites. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Third parties provide certain services available on Empass Learning's mobile apps and websites on its behalf. Empass Learning may provide information, including Personal Information that it collects on the Web or through its mobile apps to third-party service providers to help us deliver programs, products, information, and services. Empass Learning also works with service providers to maintain its Website, message services and email campaign lists. Empass Learning will take reasonable steps to ensure that these third-party service providers are obligated to protect Personal Information on its behalf.



INTEGRATIONS AMAZON SES and Other 3rd PARTIES

Our service integrates with your AWS (Amazon Web Services) account. Please see the AWS Privacy Policy and Terms and Conditions of Service to review their practices and processes regarding the usage, storage and disclosure of any data used in relation to their service.

We can additionally integrate Empass with other third party apps, websites or other services and will ensure that the privacy and security of your data is never compromised.



RETENTION OF YOUR PERSONAL INFORMATION

The periods for which we keep your information depend on why your information was collected and what we use it for. We will not keep your personal information for longer than necessary for our business purposes or for legal requirements.

Some account information will be held for 6 years from your last sign in or use of the service. Logs of your use of the services will be deleted within 12 months of your last sign in or use of the service.

We will keep your contact information, emails and lists for 12 months after your last sign in or use of the service, in case you decide to use our services again. We may contact you about our services during this time (unless you have asked us not to contact you for marketing purposes).



LEGAL BASIS FOR PROCESSING

We are required to state the legal basis on which we undertake processing of your personal information. We will only use your information where:
  • We have your consent to do so; or
  • We need to process the personal information to perform services for you under our terms and conditions of service.
  • We have a legitimate interest in engaging in the provision of our Empass service and in offering products and services of value to you.
Any consent you provide may be withdrawn at any time by emailing us.


YOUR RIGHTS

You have the right to request access to personal data that we may process about you.
You have the right to require us to correct any inaccuracies in your data, free of charge. If you wish to exercise this right, you should:
  • put your request in an email to us;
  • provide us with enough information to identify you (e.g. username or email address); and
  • specify the information that is incorrect and what it should be replaced with.


You can access, correct, update or request deletion of your personal information at any time, either through your online account or by contacting us.

Deletion of data will be carried out on the understanding that removal of some information (e.g. email address) during an active membership term may negatively affect your ability to use the Empass service.

We cannot delete any invoices, as these are kept for tax purposes.

You can request that we restrict processing of your personal information, object to processing of your information or request portability of your personal information. For these requests please contact us. We will comply with your request where your rights have been exercised in accordance with applicable laws.

If we have collected and processed your personal information with your consent, then you can withdraw that consent at any time. To be clear, we may still continue to process your data if we have a different legal basis for doing so (for example, if we are required by law to do so, or we need to do so for the purposes of fulfilling our obligations to you under our terms and conditions of service).

You also have the right to ask us to stop processing your personal data for direct marketing purposes. You can do this through your Empass dashboard or via email. If you wish to exercise this right via email, you should:
  • put your request in writing (an email with a header that says 'Unsubscribe' is acceptable);
  • provide us with enough information to identify you (e.g email address); and
  • if your objection is not to direct marketing in general, but to direct marketing by a particular channel (e.g., email or telephone), please specify the channel you are objecting to.



YOUR CONSENT

By using this Website and our mobile apps, you consent to the terms of our Online and mobile data privacy policy and to Empass Learning's processing of personal data for the purposes given above as well as those explained Empass Learning collects personal information on the web as well as mobile.


CHILDREN'S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

We do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.


ONLINE PRIVACY POLICY ONLY

This online privacy policy applies only to information collected through our website and mobile apps and not to any information collected offline.


YOUR CONSENT

By using our site, you consent to our website and mobile app privacy policy.


CHANGES TO OUR PRIVACY POLICY

If we decide to change our privacy policy, we will post those changes to this page, and/or update the Privacy Policy modification date below. This policy was last modified on May 21, 2018. You can review the most current version of the Privacy Policy at any time at www.empass.mobi/privacypolicy


For questions about the Privacy Policy please email us on play@empass.mobi

           


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