In addition to
our Terms and Conditions, Adv Ins of Medskills FZC also referred as "AIMS" respects your privacy
and is committed to protecting it. This Privacy Policy (the "Policy")
explains the types of information collected by AIMS when you use the platform
(as defined in Terms and Conditions
that references this Policy, how we collect, use, share and store
such information collected and also explains the rationale for collection of
such information, the privacy rights and choices you have regarding your
information submitted to us when you use the Services.
For ease of
reference, use of the terms "Adv Ins of Medskills FZC
also referred as "AIMS", "we", "us, and/or "our" refer to Adv Ins of Medskills FZC " a company incorporated in SRTIP Freezone,
UAE and all of its affiliates which have license to offer Services. Similarly,
use of the terms "you", "yours" and/or "User(s)" refer to all users of the
Platform and includes all Learners and Content Providers (as more particularly
defined under our Terms and Conditions).
The Services are governed by this Policy, Terms and Conditions ,
and any other rules, policies or guidelines published on the Platform as
applicable to you. Please read this Policy carefully prior to accessing our
Platform and using the Services. By accessing and using the Platform, providing
your Personal Information (defined below), or by otherwise signalling your
agreement when the option is presented to you, you consent to the collection,
use, disclosure, sharing and storing of information described in this Policy, Terms and Conditions and
any other rules, policies or guidelines published on the Platform as applicable
to you (collectively referred to as the"Platform
Terms"), and AIMS disclaims all the liabilities arising therefrom.
If you have inadvertently submitted any Personal Information to AIMS prior
to reading this Policy statements set out herein, or you do not agree with the
way your Personal Information is collected, stored, or used, then you may
access, modify and/or delete your Personal Information in accordance with this
Policy (refer to the sections about Your Choices and Your Rights).
If you have any
questions about this Policy, please contact us at official@studyataims.com.
To deliver our
educational services efficiently, AIMS utilizes a third-party Learning
Management System (LMS) powered by EDMINGLE, a platform developed and
maintained by Ascorb Technologies Pvt.
Ltd.
Ascorb Technologies may process
certain user data solely for the purpose of platform functionality and support,
under strict data protection agreements.
APPLICABILITY
This Policy
applies to all Users of the Platform.
ACCESS
You may be
allowed to access and view the Platform as a guest and without creating an
account on the Platform or providing any Personal Information. We may allow you
to avail certain services without the need for your registration, but you may
be required to submit certain Personal Information and other information to
avail such services. However, to have access to all the features and benefits
on our Platform, you are required to first create an account on our Platform.
To create an account, you are required to provide certain Personal Information
as may be required during the time of registration and all other information
requested on the registration page, including the information to receive
promotional offers from AIMS (which may be optional). AIMS may, in future,
include other optional requests for information from you to help AIMS customize
the Platform to deliver personalized information to you. AIMS may keep records
of communication or emails received from or made by you for making enquiries,
feedback, or other purposes for the purpose of rendering Services effectively
and efficiently.
USE OF THE
PLATFORM/SERVICES BY CHILDREN
As stated in our
Terms and Conditions, to register on the Platform you must meet the 'Age
Requirements' (as defined in our Terms and Conditions). If you are a "Minor" or "Child" i.e.,
an individual who does not meet the Age Requirements, then you may not register
on the Platform.
CONTROLLERS
AIMS is the
controller of Personal Information that it collects and processes in connection
with the use of the Platform and the provision of the Services on the Platform.
The kind of Personal Information we collect in connection with such use is
detailed below.
PERSONAL
INFORMATION
"Personal
Information" shall mean the information which
identifies a User i.e., first and last name, email address, age, gender,
location, photograph, official identifier (such as biometric data, aadhar number, social security number, driver"s license,
passport, etc.,), and/or phone number and any other information categorized as
"personal data" in context of this Policy
We request you to not provide AIMS with any Personal Information unless
specifically requested by us. In the event you share with AIMS any Personal
Information without us having specifically requested for the same, then we bear
no liability in respect of such Personal Information provided by you.
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, phone/mobile
number and
image/photograph (for user profile)
- 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 national
identification document "like driver"s license, passport,
your entity details such as name, MOU/AOA, certificate of incorporation,
list of directors/partners, 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 AIMS, either on
the Platform or otherwise, or when you otherwise communicate with us via
form, e-form, email, phone, or otherwise.
- KYC information to be provided
Learners of selected Subscriptions: Learners
may be required to submit their KYC information and documentation,
including but not limited to national id documents or passport, for the
purpose of authenticating and verifying the identity of the Learner in
order for you to access Services, including the content made available as
a part of the Subscriptions. All KYC information and documentation are
collected, processed and stored in accordance with applicable laws.
- 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 our Cookies 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, 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 FOR
COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION:
- Basis for collection:
We collect and divrocess your Personal Information based on the following
legal parameters depending upon the nature of Personal Information and the
purposes for which it is processed:
- 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.
Where the processing of your Personal Information is based on your consent, you
have the right to withdraw your consent at any point in time in accordance with
this Policy. Please note that should the withdrawal of consent result in us not
being able to continue offering our Services to you, we reserve the right to
withdraw or cease from offering our Services to you upon your consent
withdrawal. You may withdraw consent by contacting us with a written request to
the contact details provided in the "Privacy Grievances" section
below. Upon receipt of your request to withdraw your consent, the consequences
of withdrawal may be communicated to you. Upon your agreement to the same, your
request for withdrawal will be processed.
HOW WE USE
AND SHARE THE INFORMATION COLLECTED
- We use/process your information
in the following manner:
- To provide Services on our
Platform: We use your information as
collected by us to allow you to access the Platform and the Services
offered therein, including without limitation to set-up and maintain your
account, provide customer service, fulfil purchases through the Platform,
verify User information and to resolve any glitches with our Platform.
The legal basis for this processing is consent or, where applicable, our
legitimate interests in the proper administration of our Platform, and/or
the performance of a contract between you and us.
- To improve our Platform and
maintain safety: We use your information
to improve and customize the Platform and Services offered by us,
including providing automatic updates to newer versions of Platform and
creating new features based on the Platform usage analysis. Further, we
also use your information to prevent, detect, investigate, and take
measures against criminal activity, fraud, misuse of or damage to our
Platform or network, and other threats and violations to AIMS or a third
party's rights and property, or the safety of AIMS, its users, or others.
The legal basis for this processing is consent or, where applicable, our
legitimate interests in the proper administration of our Platform, and/or
the performance of a contract between you and us.
- To market our Platform and
communicate with You: We will use your
information to develop a more targeted marketing of our Platform, to
communicate with you about our offers, new products, services or even
receive your feedback on the Platform. The legal basis for this
processing is consent or, where applicable, our legitimate interests in
the proper administration of our Platform, and/or the performance of a
contract between you and us.
- To establish, exercise, or
defend legal claims: We may process any
Personal Information identified in this Policy when necessary for
establishing, exercising, or defending legal claims, whether in court,
administrative, or other proceedings. The legal basis for this processing
is our legitimate interest in the protection and assertion of our legal
rights, your legal rights, and the legal rights of others.
- To manage risk and obtain
professional advice: We may process any
of the Personal Information identified in this Policy to manage risk or
obtain professional advice. The legal basis for this processing is our
legitimate interest in the proper protection of our business and
Platform.
- Consent: We may otherwise use your information with your consent
or at your direction.
- To Better Understand Our
Users: We may use information we gather
to determine which areas of the Services are most frequently visited to
understand how to enhance the Services.
- We share the information collected
as per terms of this Policy only in the manner specified hereinbelow. We
do not sell or otherwise disclose Personal Information we collect about
you for monetary or other valuable consideration. Further, only authorized
representatives of AIMS and on a need-to-know basis use any information
received from you and as consented by you. In the event of any identified
unauthorized use or disclosure of information or upon your complaint as
stated under the "Privacy Grievances" section below, we
will investigate any such complaint and take the appropriate action.
- Affiliates: We may disclose information about you to our affiliates,
and other businesses under the same control and ownership, and their
respective officers, directors, employees, accountants, attorneys, or
agents, who need the information to help us provide the Services or
process the information on our behalf. or those who offer similar
products and offerings. We require our affiliate, subsidiaries and other
businesses under the same control and ownership to follow this Privacy
Policy for any Personal Information that we share with them. Further, if
you have availed any Service that is offered by AIMS in collaboration,
then we may share your Personal Information with the relevant affiliates,
who may also communicate with you regarding certain other
products/services offered by them separately via email, phone, SMS and/or
such other mode of communication; you will always have an option to opt
out of receiving some or all of such promotional communications through
the unsubscribe link in the email or such other option that may be
communicated to you (if received).
- Third-party vendors/service
providers including integrated services on the Platform: We may share information about you with third-party
vendors or service providers (including consultants, payment processors,
and learning management services providers (i.e., Ascorb
Technologies Pvt. Ltd having a brand EDMINGLE) other
service providers and integrated services) who need the information to
provide their support services to us or you, or to provide their services
to you on our behalf either directly or through the Platform. 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. Such third-party vendors are not allowed to use
the information for any purpose other than what it was provided for, and
they are required to process and use the information in accordance with
this Privacy Policy.
- Third-party platforms to
facilitate the additional offerings: We
may share information about you with third-party platforms that are used
to create interactive forums between Content Providers and Learners to
enable the Learners a more conducive environment to extend their
learning. The information shared with these platforms are limited to the
information required to facilitate your participation in the forums and
is based on your consent through the Platform or otherwise. However, the
privacy practices of these platforms are independent of this Policy, and
we suggest that you read through the privacy policies and terms and
condition of the platforms relevant to you prior to consenting to being a
part of any forums made available on these third-party platforms.
- Legal Disclosures: We may disclose information about you in response to a
court order, or other governmental request. Without limitation to the
foregoing, we reserve the right to disclose such information where we
believe in good faith that such disclosure is necessary to:
- comply with applicable laws,
regulations, court orders, government and law enforcement agencies"
requests;
- protect and defend AIMS"s or a
third party's rights and property, or the safety of AIMS, our users, our
employees, or others; or
- prevent, detect, investigate
and take measures against criminal activity, fraud and misuse or
unauthorized use of our Platform and/or to enforce our Terms and
Conditions 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.
- Business transfers: In the event AIMS undergoes any merger, acquisition, or sale
of company assets, in part or in full, with another company, or in the
unlikely event that AIMS goes out of business or enters bankruptcy, user
information would likely be one of the assets that is transferred or
acquired by a third party. If any of these events were to happen, this
Privacy Policy would continue to apply to your information and the party
receiving your information may continue to use your information, but only
consistent with this Privacy Policy.
- Advertising and Analytics
Partners: We may share usage data with
third-party advertisers, advertisement networks, and analytics providers
through cookies and other similar technologies.
- With Your Consent: We may share and disclose information with your consent or at
your direction.
Your information
may be shared for reasons not described in this Policy,
however, we will seek your consent before we do the same or share information
upon your direction.
DURATION FOR
WHICH YOUR INFORMATION IS STORED ON THE PLATFORM
Mostly, when you
delete any of the information provided by you or when you delete your account,
on the Platform, the same will be deleted from our servers too. However, in
certain cases, we will retain your information for as long as it is required
for us to retain for the purposes stated hereinabove, including for the purpose
of complying with legal obligation or business compliances.
Further, please
note that we may not be able to delete all communications or photos, files, or
other documents publicly made available by you on the Platform (for example:
comments, feedback, etc.), however, we shall anonymize your Personal
Information in such a way that you can no longer be identified as an individual
in association with such information made available by you on the Platform. We
will never disclose aggregated or de- identified information in a manner that
could identify you as an individual.
Note: If you
wish to exercise any of your rights (as specified in "Your
Rights" section below) to access, modify and delete any or all information
stored about you, then you may do so by using the options provided within the
Platform. You can always write to us at official@studyataims.com for
any clarifications needed.
YOUR CHOICES
- Limit the information You
provide: You always have an option to
choose the information you provide to us, including the option to update
or delete your information. However, please note that lack of certain
information may not allow you the access to the Platform or any of its
features, in part or in full.
- Limit the communications You
receive from us: Further, you will also
have the option to choose what kind of communication you would like to
receive from us and whether you would like to receive such communication
at all or not. However, there may be certain communications that are
required for legal or security purposes, including changes to various
legal agreements, that you may not be able to limit.
- Reject Cookies and other
similar technologies: You may reject or
remove cookies from your web browser; you will always have the option to
change the default settings on your web browser if the same is set to
"accept cookies". However, please note that some Services offered on the
Platform may not function or be available to you, when the cookies are
rejected, removed, or disabled.
YOUR RIGHTS
In general, all
Users have the rights specified herein this section. If
however, you are facing any issues or require any clarifications, you can
always write to us at the address noted in the "Grievances" section
below, and we will address your concerns to the extent required by the
applicable law.
- Right to Confirmation and
Access: You have the right to get
confirmation and access to your Personal Information that is with us along
with other supporting information.
- Right to Correction: You have
the right to ask us to rectify your Personal Information that is with us
that you think is inaccurate. You also have the right to ask us to update
your Personal Information that you think is incomplete or out-of-date.
- Right to be Forgotten: You
have the right to restrict or prevent the continuing disclosure of your
Personal Information under certain circumstances.
- Right to Erasure: If you wish
to withdraw/remove your Personal Information from our Platform, you have
the right to request erasure of your Personal Information from our
Platform. However, please note that such erasure will remove all your
Personal Information from our Platform (except as specifically stated in
this Policy) and may result in deletion of your account on the Platform
permanently, and the same will not be retrievable.
- Right to Nominate: You have
the right to nominate any other person who shall exercise your rights
under the applicable data privacy laws, in the event of your death or
incapacitation.
Remember, you
are entitled to exercise your rights as stated above only with respect to your
information, including Personal Information, and not that of other Users.
Further, when we receive any requests or queries over email or physically to
the address specified in the "Grievances" section below, then, as per
the applicable Data Protection Laws, we may need to ask you a few additional
information to verify your identity in association with the Platform and the
request received.
INFORMATION
SECURITY
- We work to protect the security of
your information during transmission by using Transport Layer Security
(TLS) or Secure Sockets Layer (SSL) software (depending on your
browser/Supported Device), which encrypts information you input in
addition to maintaining security of your information as required under
applicable laws.
- We maintain electronic, and
procedural safeguards in connection with the collection, storage, and
disclosure of Personal Information (including Sensitive Personal
Information). Our security procedures mean that we may occasionally
request proof of identity before we disclose Personal Information to you
that belongs to you.
- However, no form or method of data
storage or transmission system is fully secure, and we cannot guarantee
that security provided by such system(s) is absolute and that your
information will not be accessed, disclosed, or destroyed in the event of
a breach of any of our security measures.
- It is important for you to protect
your account against unauthorized access to or use of your password and to
your computer and if you have any reason to believe that your password has
become known to anyone else, or if the password is being, or is likely to
be, used in an unauthorized manner, you must immediately change your
password or inform us, so that we are able to help you stop or prevent
such unauthorized access. Be sure to sign off when you finish using a
shared computer.
- All KYC information collected in
accordance with this Policy are fully encrypted and cannot be accessed by
any person other than the designated authority in AIMS.
- We try and ensure that the third
parties who provide services to us under appropriate contracts take
appropriate security measures to protect Personal Information in line with
our policies.
PROMOTIONAL
COMMUNICATIONS
You will always have
the option to opt out of receiving some or all of our promotional
communications through the setting provided within the Platform upon your
login, by using the unsubscribe link in any email communications sent to you or
by emailing official@studyataims.com
If you opt out of
promotional communications, we may still send you transactional communications,
such as service announcements, administrative and legal notices, and
information about your account, without offering you the opportunity to opt out
of these communications. If you no longer wish to use our Platform or receive
any communications from us (except for those that are legally required), then
you may delete your account by using the option enabled within the Platform or
by writing to us at official@studyataims.com .
Please note that
opting out of promotional email communications only affects future
communications from us. If we have already provided your information to a third
party (as stated in this Policy) before you changed your preferences or updated
your information, you may have to change your preferences directly with that
third party.
We do not sell your Personal Information to third parties, and we do not use
your name or name of your company in marketing statements without your consent.
INTEREST-BASED
ADS
On unaffiliated
sites, AIMS may display interest-based advertising using information you make
available to us when you interact with our Platform and Services.
Interest-based ads, also sometimes referred to as personalised or targeted ads,
are displayed to you based on information from activities such as registering
with our Platform, visiting sites that contain AIMS content or 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. 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.
MODIFICATION
TO PRIVACY POLICY
Our business
changes constantly and our Policy may change from time to time. We may, at our
discretion (unless required by applicable laws to mandatorily do so), email
periodic reminders of our notices and conditions, unless you have instructed us
not to, but we encourage you to check our Platform frequently to see the recent
changes. Unless stated otherwise, our current Policy applies to all information
that we have about you and your account. We stand behind the promises we make,
however, and will not materially change our policies and practices making them
less protective of customer information collected in the past without your
consent.
PRIVACY
GRIEVANCES
If you have any
questions about this Policy, wish to exercise your rights or have concerns
about privacy of your data or any privacy related grievances, please register
your complaint with a thorough description via email to official@studyataims.com addressed
to our grievance officer Mr. Mohammed Ibrahim Ali"