Privacy Policy

  1. Introduction


Qualify Learn (together with its subsidiaries and international affiliates, hereinafter “Qualify Learn,” “us,” “we,” “our,” or “the Company”) is committed to the security and management of personal data, to function effectively and successfully for the benefit of our stakeholders, customers, and the community. In doing so, it is essential that individuals’ privacy is protected through lawful and appropriate means of handling personal data. Therefore, we have implemented this privacy policy (hereinafter referred to as the “Policy”).

 

  1. Aim


This policy aims to protect the personal data of various stakeholders connected to our organization. It is intended to provide individuals with notice of the basic principles by which the company processes the personal data (“Personal Data”) of individuals who visit, use, deal with, or transact through the website, including guest users and browsers (hereinafter referred to as ‘you’ or ‘user’).

  1. Purpose and Scope


The purpose of this policy is to describe how Qualify Learn collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to https://www.qualifylearn.com/ (hereinafter the “website”). This policy also provides details on how Qualify Learn ensures data security, conducts data transfers, and processes requests from data subjects.

This policy applies to all systems, people, and processes that constitute the organization’s information systems, including board members, directors, employees, and third parties who have access to Personal Data available within Qualify Learn.

The company is also committed to ensuring that its employees conduct themselves in line with this, and other related policies. Where third parties process data on behalf of Qualify Learn, the company endeavours to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.

Qualify Learn offers curated and specially designed higher education and industry-relevant certification programs online (hereinafter individually or collectively referred to as “Program”). This Privacy Policy applies to all our services unless specified otherwise.

 

  1. Types of Personal Data Collected


The Personal Data we collect about you depends on the context of your interactions with us, the products, services, and features you use, your location, and applicable laws.

Personal Data is stored in personnel files or within the electronic records (on servers in India or other countries) of Qualify Learn. The following types of Personal Data may be held by the Company, as appropriate, on relevant individuals:

  1. Personal Identification Data
  • First Name, Last Name
  • Job Title & Company
  • Signature
  • Photographs
  1. Identification Data
  • Social Security or Tax Identification Numbers
  • Aadhar Number and PAN
  1. Financial Data
  • Bank Account Information
  • Salary Information
  • Payment Gateway Account Details
  • E-wallet Account Details
  1. Personal Characteristics
  • Age
  • Gender
  • Date of Birth
  • Marital Status
  • Nationality
  1. Contact Data
  • Postal Address
  • Email Address
  • Phone Number
  1. Education and Recruitment Data
  • Educational Qualifications
  • Working Goals
  • Post-Qualification Experience
  1. Electronic Identification Data
  • Login Credentials (If you are a registered user)
  • Visitor’s IP Data
  • Date and Time of Website Visit
  • Pages Visited and Navigation on the Website
  • Browser Being Used
  • Country of Accessing the Website
  • Language of the Browser Being Used
  • Words Searched For
  • Pixel Tags
  1. Inquiries
  • Personal Data stated in the form – for example: Name, Address, Phone Number, Country
  • Subject of Inquiry
  • Personal Details (Name on the Card, Billing Address)
  • Payment Details (Card Numbers, Card Type)
  • Recordings of Calls with Students and Users Showing Interest in Our Program
  • Information About Your Interactions with Customer Service and Maintenance Interactions with Us
  1. User-Generated Data
  • Projects and Assignments Submitted
  • Peer Feedback and Grading
  • Program Performance Data
  • Responses to Quizzes, Standalone Quizzes, Exams, and Surveys
  • Webcam Recordings (During Assessments Related to Online Courses)
  • Posts Made to Public Forums Through Our Platform
  • Any Other Information Necessary to Ensure Conformity with Test/Assessment Rules, Areas of Interest
  1. Marketing Data
  • Your Preferences in Receiving Marketing Information from Us
  • Your Communication Preferences
  1. Behavioural Data

 

 

 

  1. Special Categories of Personal Data


Special categories of Personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, health information, and genetic and biometric data.

We do not collect or process any special or sensitive Personal Data.

Should we specifically require “special” or “sensitive” Personal Data in connection with one or more of the uses described below, we will request your explicit consent to use the data in accordance with this policy and/or in the manner described at the point where you were asked to disclose the data.

Other legal bases for our processing of special category data may include, as permitted by applicable law, scientific research, employment, social security or social protection law, reasons of substantial public interest, or as necessary for the establishment, exercise, or defense of legal claims. If you voluntarily share with us or post/upload any “special” or “sensitive” Personal Data on this website for any other reason, you consent to our use of such data in accordance with applicable law and this policy. You can contact our Data Protection Officer (DPO) for more information about our processing of your Personal Data.

  1. Sources of Data Collection


The data collected by the company is derived directly from the data provided by the user or from your use of our sites.

Data is collected when you:

  • Register for various seminars, webinars, or other outreach initiatives made available by us or through our Educational Partners’ offline activities.
  • View online ads from various platforms (e.g., Facebook, Instagram, Google, Twitter, etc.).
  • Register on any of our job portals.
  • Request a quote for the various products and services offered by us.
  • Place feedback, complete any customer surveys, or interact with our customer services online.
  • View our services or visit our website pages on the internet.
  • Browse our website.
  • Appear for assignments, exams, or other assessments related to online courses.
  • Avail of scholarships, refunds, and referrals.

 

 

 

Data Collected from Third Parties


We may receive Personal Data such as access or login details, profile pictures, or other information relevant to your Personal Data that is available through third-party platforms.

We also receive information about your visits to our platform and other websites through the use of pixel tags.

Third parties from whom we receive your Personal Data may include service providers, networks connected to our service, advertising partners, marketing and advertising affiliates, educational partners, scholarship providers, analytics providers, recruiters, and other third-party sources.

 

  1. Cookies

 


Cookies are small text files placed on your device to collect standard Internet log information and visitor behaviour details. When you visit our websites, we may automatically gather information from you through cookies or similar technologies.

Additionally, we may allow third-party advertising companies (such as Facebook, Google, Twitter, Quora, and Bing) to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display ads and record your interactions, allowing them to show ads tailored to your preferences as you browse the Internet. These cookies store information about the content you are browsing, along with an identifier linked to your device or IP address.

 

How Do We Use Cookies?
Qualify Learn uses cookies in various ways to enhance your experience on our website, including:

  • User Recognition: To recognize our website users and improve the overall experience when interacting with our platform.
  • Performance Analysis: We utilize cookies to analyze the usage and performance of our website and services.
  • Service Improvement: Cookies help enhance the delivery and value of the various services and products we offer.

What Types of Cookies Do We Use?
Our website uses several types of cookies, including:

  • Persistent Cookies: These cookies improve your experience on our sites by remembering your acceptance of our Cookie Policy, which removes the initial cookie message you see when using our sites.
  • Session Cookies: Temporary cookies that are deleted from your device when your web browser closes. We use session cookies to help track internet usage as described above.
  • Analytical/Performance Cookies: These cookies allow us to recognize and count the number of visitors, as well as see how they navigate around our website. This helps us improve site functionality to ensure users find what they need.
  • Functionality Cookies: These cookies recognize you when you return to the website, allowing us to customize content for you and remember your preferences and interests.
  • Targeting Cookies: These cookies record your visits to our website, the pages viewed, and the links clicked. This information helps us provide content relevant to your interests.

How to Manage Cookies?
Most browsers allow you to refuse or delete cookies. The methods for doing so can vary by browser and version. Disabling certain cookies may impact your experience and limit some features of the website.

If you wish to remove previously stored cookies, you can do so manually at any time. However, this will not prevent the site from placing further cookies on your device unless you adjust your browser settings as described above.

For up-to-date information about blocking and deleting cookies, please refer to the following links:

Please note that these opt-out mechanisms rely on cookies to remember your preferences. If you delete your cookies, switch devices, or change browsers, you will need to repeat the opt-out process. Additionally, opting out of interest-based ads will not stop all ads; it will only stop personalized ads based on your interests.

 

  1. Data Analytics
    We utilize analytics tools and information providers to assess how visitors engage with the content on our website. Additionally, we employ Facebook Custom Audiences to request Facebook to display ads customized based on your interactions with our website or Facebook applications and to gauge your engagement with those ads. For further details on how these services utilize such technologies, please refer to the websites of Google, Adobe, and Facebook.

If you prefer not to have data related to your visits to our website collected through Google Analytics, you can opt out by installing the Google Analytics opt-out browser add-on. You can also opt out of Facebook Custom Audiences by visiting Facebook’s opt-out page.

  1. Aggregated Data
    “Aggregated Data” refers to records that have been anonymized by removing Personal Data and combining or manipulating the data to provide generalized, anonymous insights. Your identity and personal information are not contained within Aggregated Data. We aggregate your Personal Data anonymously with other information to generate Aggregated Data for internal and commercial purposes, as well as for sharing with affiliates, subsidiaries, and business partners for planning and marketing strategies.
  2. Data Protection Principles
    When third parties process data on behalf of Qualify Learn, we strive to obtain assurances that your Personal Data will be consistently protected. We acknowledge our accountability for the processing, management, regulation, storage, and retention of all Personal Data, whether in manual records or on computers.

All Personal Data collected and held by the Company will:

  • Be processed fairly, lawfully, and transparently.
  • Be collected for specific, explicit, and legitimate purposes.
  • Be adequate, relevant, and limited to what is necessary for processing purposes.
  • Be kept accurate and up to date, with reasonable efforts made to rectify or erase inaccurate data promptly.
  • Not be retained longer than necessary for its intended purpose.
  • Be processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage, through appropriate technical and organizational measures.
  • Comply with applicable laws and procedures for the international transfer of Personal Data.

 

  1. Legal Basis for Processing Your Personal Data
    Certain jurisdictions mandate that we establish a lawful basis for processing your Personal Data.

When applicable, the lawful basis that Qualify Learn relies on may vary depending on the specific processing activity involved.

Qualify Learn utilizes the following lawful bases for processing Personal Data, as permitted under applicable law:

  • Processing necessary for the negotiation, execution, or performance of contracts.
  • Processing required to comply with legal and regulatory obligations.
  • Processing in pursuit of our legitimate interests, which include conducting legitimate business activities (e.g., enhancing our products and services, communicating with you, securing our systems, and other legitimate interests).
  • Processing necessary to protect the vital interests of a user or another individual.
  • Processing necessary for public interest.
  • Processing based on your consent.
  1. Consent
    We may seek your consent to collect and utilize certain types of Personal Data when legally required.

Once consent is obtained, Qualify Learn has the individual’s implied consent to collect any additional information through inbound/outbound calls, promotional emails, SMS, WhatsApp, etc., necessary for fulfilling the stated purposes. If a new use for your information is identified, express consent will be sought.

Implied consent may also be granted when users are provided with notice and a reasonable opportunity to opt out of their personal information being used for marketing purposes, and they do not opt out.

Individuals can withhold or withdraw their consent for Qualify Learn to utilize their personal information in specific manners, subject to certain exceptions (e.g., when personal information is essential for providing services or when withdrawing consent frustrates legal obligations).

By using this website, acknowledging this privacy policy, or voluntarily providing us with your Personal Data, you consent to the collection, storage, and processing of your Personal Data in accordance with this privacy policy and our Terms of Service.

If you refuse or withdraw your consent, or choose not to provide any required Personal Data, we may be unable to deliver the services available on our platform.

  1. Purpose of Collecting Personal Data
    We collect your Personal Data for the following purposes:
  • To fulfil or meet the reason you provided the information.
  • To manage and process your information, including tracking attendance, progress, and completion of a Program. This includes using certain Personal Data to administer exams, projects, and assessments for the Program. For instance, during exams, Qualify Learn may utilize collected information to verify your identity or monitor performance to ensure adherence to testing rules.
  • To send you updates regarding Programs, Learning Saint events, platform maintenance, and new services via WhatsApp, email, SMS, phone call, or other mediums, either directly or through third parties.
  • To provide Chat Room services.
  • To enhance the quality of our content and product offerings.
  • To ensure compliance with security policies and building access requirements.
  • To provide information to relevant external authorities for tax, social security, and other legal obligations.
  • To conduct surveys assessing your satisfaction with our processes or policies.
  • To establish and maintain accounts and subscriptions with third-party services that provide information and communication services.
  • To make decisions regarding your continued engagement, employment, or membership.
  • To handle legal or regulatory disputes or investigations involving you, our operations, or our partners, employees, or contractors, including matters related to workplace accidents, negligence claims, and professional discipline.
  • To monitor the use of our information and communication systems to ensure compliance with IT and document management policies.
  • To maintain network and information security, preventing unauthorized access and malicious software distribution.
  • For business management and planning, including accounting, auditing, and insurance.
  • To explore or review operational or management options.
  • To maintain required legal or regulatory registers.
  • To communicate with you, including responding to inquiries.
  • To enhance the safety and security of our services, preventing fraud, and protecting our rights and those of our customers.
  • To enforce applicable terms, conditions, and policies.

 

  1. Advertising and Marketing
    At Qualify Learn, we prioritize your choices regarding the use of your Personal Data, especially in relation to marketing and advertising. You will receive marketing communications from us if you have requested information or provided your details with explicit consent to receive such marketing.

We may utilize your Personal Identification, Identity, Contact, Electronic, and User-generated Data to assess what services or offers may be of interest to you. This helps us tailor our marketing strategies and enhance your experience.

We also collaborate with third parties to display ads on our behalf across the internet, social networking sites, and blogs. These third parties may gather Personal Data regarding your visits to our platform and interactions with our offerings, using this information to target advertisements for goods and services.

You will always have the option to opt out of electronic direct marketing communications in each message we send, and we will respect your choice.

  1. Disclosure of Personal Data
    Qualify Learn is a global entity and may share personal information collected with other companies within the Qualify Learn group.

Examples of third parties with whom Qualify Learn may share Personal Data include:

  • Government Authorities: Sharing personal data with governmental bodies, including tax and social security authorities, to comply with applicable laws (including employment and tax laws), obtain licenses or approvals, and provide information during audits.
  • Suppliers and Service Providers: We may share data with suppliers, subcontractors, and service providers to maintain operational efficiency, including technology and internet providers.
  • Professional Advisors: We may share information with legal advisors, auditors, and consultants for legal advice and business audits.
  • Service Providers for Business Continuity: We may share data for business continuity management and contingency planning in case of disruptions.
  • Digital Wallet and Payment Services: We may share your data with certain companies to establish memberships for digital wallets, payment services, or rewards programs.

We require all third parties to maintain the security of your Personal Data and to treat it in accordance with the law. We do not permit third-party service providers to use your Personal Data for their own purposes; they may only process your data for specified purposes and in accordance with our instructions.

In addition to the above, Qualify Learn may share your Personal Data with:

Recipients

Category(ies) of Personal Data we share

Why we share it

Location(s)

Educational Partners

·        University or company offering the course

·        External graders

·        Mentors

·        Personal Identification Data

·        Personal Characteristics Data

·        Contact Data

·        User generated data

·        Evaluate and assess your progress and performance in the Program

·        report on your progress in the Program

·        enable them to issue a certificate to you on completion of the Program

Global

Employers; Sponsors and Scholarship Providers

·        Personal Identification Data

·        Personal Characteristics Data

·        Contact Data

·        User generated data

If you are taking a Program that is sponsored or paid for by your employer or a sponsor, or if you have availed a scholarship from a third-party scholarship provider, we may share your Personal Data and grades, evaluations or progress

Global

  

in the Program with your employer/sponsor/scholarship provider. This information may be shared at any time during the Program or afterwards.

 

Service Providers

·        Personal Identification Data

·        Personal Characteristics Data

·        Contact Data

·        User generated data

·        Financial Data

·        Electronic Identification Data

·        Data generated from inquires

·        Marketing Data

We provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf strictly on confidential terms. They provide a variety of services to us, including billing, sales, marketing, test proctoring, couriers, mentoring, recruitment consulting, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, credit facilities, payment processing and legal services

Global

Third Parties

·        Personal Identification Data

·        Personal Characteristics Data

·        Contact Data

·        User generated data

·        Financial Data

·        Electronic

·        we share certain Personal Data and materials with third parties including, but not limited to, service providers

Global

 

Identification Data

·        Data generated from inquires

·        Marketing Data

·        Education and Recruitment Data

·        Behavioural Data

such as Facebook or WhatsApp in order to provide you services that you have requested or services that Learning Saint provides in conjunction with the Programs

·        to arrange and provide networking activities to previous, current or potential students of Learning Saint

·        may share information that can be used to directly contact you with third-party business partners, such as companies that may be offering products or services or other opportunities that may be of interest to you.

 
  

·        To third party business partners

 

Recruitment Service providers

·        Recruitment agency

·        Potential employers

·        Personal Identification Data

·        Personal Characteristics Data

·        Contact Data

·        User generated data

·        Education and Recruitment Data

If you opt for any of our recruitment services or if you participate in any of our recruitment activities, we will be sharing your information with recruiters and potential employers.

Global

Associate and Business Transfers

·        Personal Identification Data

·        Personal Characteristics Data

·        Contact Data

·        User generated data

We share your Personal Data with our associates for business purposes.

Learning Saint may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganisation of all or substantially all of the equity, business or assets of Learning Saint to which your Personal

Global

  

Data relates

 

 

 

 

 

  1. Data Subject Rights
    In certain jurisdictions, individuals are granted specific rights regarding the processing of their Personal Data. This is particularly true for individuals located in the European Union, although similar rights may exist in other jurisdictions. These rights may not be universally applicable and depend on the context. Depending on the applicable law, you may have the right to:
  • Request access to your Personal Data.
  • Request correction of your Personal Data if it is inaccurate, incomplete, or outdated.
  • Request deletion of your Personal Data.
  • Withdraw your consent for processing, applicable only to future processing activities.
  • Object to the processing of your Personal Data.
  • Request restrictions on the processing of your Personal Data.
  • Request the transfer of your Personal Data to you or a third party.
  • Opt-out of certain transfers to third parties.

To exercise any rights you believe you may be entitled to under applicable law, please contact us at dpo@qualifylearn.com. We may need to verify your identity before fulfilling your request.

Please note that the conditions regarding the exercise of these rights may vary, as data privacy rights differ across countries. Our responses and the handling of requests will depend on the applicable laws. We may refuse requests that are excessively repetitive, require disproportionate effort, risk the privacy of others, compromise ongoing investigations, or are impractical. We are committed to treating you fairly and will not discriminate against you for exercising any of these rights.

You may also have the right to lodge a complaint with a data protection authority regarding our processing of your Personal Data. For further information, please reach out to your local data protection authority.

  1. Our Policy on Children’s Data
    The privacy of children’s data is important to us. Our sites are not intended for children, and the definition of a child varies across jurisdictions. For instance, under GDPR, a child is defined as someone aged 16 years or younger, while in the United Kingdom, the age is 13. In Singapore and Qatar, the valid age for providing consent is 18 years.

As a general policy, Qualify Learn does not engage in the collection, processing, storage, use, dissemination, or transfer of Personal Data of children.

If the collection of such data becomes necessary for fulfilling our contractual obligations or is mandated by law, we will notify you promptly, outlining the purpose and reason for such collection, and will seek your explicit consent, as well as parental authorization when applicable, prior to processing the data.

We will take appropriate steps to delete any Personal Data of children collected without verified parental consent as soon as we become aware of its existence, in accordance with applicable laws.

  1. Data Security
    Qualify Learn is committed to implementing appropriate technical and organizational measures, supported by privacy impact assessments, to ensure a high level of security for Personal Data and to maintain a secure environment for information stored both manually and electronically.

We employ various security measures designed to prevent unlawful or unauthorized processing of Personal Data and to protect against accidental loss or damage. Our security management policies and procedures aim to prevent, detect, contain, and address violations related to the confidentiality, integrity, availability, or security of your Personal Information. These policies assign specific responsibilities for data security and include a risk management program with periodic assessments.

As part of our organizational security measures, employees at Qualify Learn are required to:

  • Ensure that all confidential files or written information are stored securely and accessible only to those who have a legitimate need to access them.
  • Regularly check the accuracy of data entered into our systems.
  • Use provided passwords cautiously and avoid sharing them unless absolutely necessary.
  • Use screen blanking to protect Personal Data displayed on screens when not in use.
  • Avoid storing or transporting Personal Data on laptops, USB sticks, or similar devices unless authorized. If necessary, ensure that data on such devices is protected through encryption.

Non-compliance with these data security policies may result in disciplinary action, including dismissal, depending on the severity of the breach.

We also take steps to ensure that our service providers, contractors, and other third parties maintain similar levels of data protection when processing your Personal Data. While we strive to ensure the security of your Personal Data, please be aware that 100% security cannot be guaranteed, and Qualify Learn shall not be liable for any misuse or loss of Personal Data by third-party cloud service providers.

 

  1. International Data Transfers
    Our website is primarily operated and managed on servers located within India. However, due to the global nature of Qualify Learn, your Personal Data may also be stored on third-party data servers located in other countries where Qualify Learn provides its products and services.

Qualify Learn engages subcontractors, service providers, and other third parties to facilitate our products and services, and your Personal Data may be transferred to the servers of these entities. Depending on the location of our service providers, your information, including Personal Data, may be stored on computers situated outside of your state, province, country, or other governmental jurisdictions, where the data protection laws may differ from those applicable to your location.

Furthermore, your Personal Data may be shared and disclosed among various Qualify Learn group companies when such transfers are necessary for legitimate business purposes.

Where required by applicable law, we will seek your express consent for such transfers. In all other cases, by consenting to this policy, you also provide consent for Qualify Learn to transfer your Personal Data to affiliated companies, service providers, or any third-party entity in various locations around the world. We take steps to ensure that a level of data protection similar to that outlined in this policy is afforded to Personal Data transferred internationally.

When transferring your Personal Information across borders, we will comply with applicable legal requirements. If necessary, we will enter into a data transfer agreement with the recipient of the Personal Information, which may include Standard Contractual Clauses for European Personal Data. In other applicable cases, we shall enter into separate Data Processing Agreements with third parties, service providers, contractors, and other recipients of Personal Data. Additionally, we ensure that transfers of Personal Data to any public authority are not excessive, disproportionate, or indiscriminate, adhering to what is necessary in a democratic society. In cases of conflict between these measures and public authority requirements, we will seek a practical solution that fulfills the purpose of this policy.

We are committed to taking all reasonable steps to ensure that your data is treated securely and in accordance with our data privacy and security standards.

  1. Records Management
    Records management encompasses the activities necessary for systematically controlling the creation, distribution, use, maintenance, and disposition of recorded information that serves as evidence of business activities and transactions. Compliance with information law is unachievable without robust records management policies and practices. Good records management not only enhances record quality but also ensures that Personal Data is retained only for as long as necessary for its original purpose, supporting data minimization.
  2. Organization and Responsibilities
    Qualify Learn will maintain records of data processing as required by applicable laws.

The Data Protection Officer (DPO) is specifically responsible for overseeing data protection and ensuring compliance with relevant legislation and data protection principles. The DPO will ensure that the Data Processing Register is kept current and demonstrates adherence to data protection principles across our activities. Individual staff members are obligated to contribute to ensuring that the measures outlined in the Register are accurately reflected in our practices.

Our compliance with relevant policies and regulatory requirements concerning data protection will be periodically monitored by a designated governance group. All employees, volunteers, consultants, partners, and other parties handling Personal Data on behalf of Qualify Learn will receive appropriate training and supervision as needed.

The collection, storage, use, and sharing of Personal Data will be regularly reviewed by the DPO, the Governance Group, and any relevant business areas. We will adhere to applicable codes of conduct as identified and deemed appropriate.

If a processing activity poses a high risk to individual rights and freedoms, we will first conduct a Data Protection Impact Assessment (DPIA) and consult with the relevant supervisory authority before proceeding, if necessary.

  1. Conflicts of Law
    This policy is designed to comply with the laws and regulations of the jurisdictions in which Qualify Learn operates. In the event of any conflict between this policy and applicable laws and regulations, the latter shall prevail.
  2. Retention of Personal Data
    We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected. The duration for retaining Personal Data depends on the purposes for which we collect and use it, as well as any applicable legal requirements for establishing, exercising, or defending our legal rights.

Users can exercise the rights enumerated herein. If an extension of the retention period is required, we will obtain your consent for the same. Additionally, we may dispose of data prior to the end of the retention period if the purpose for which it was collected has been fulfilled.

 

  1. Procedures
    Qualify Learn has implemented the following measures to protect the Personal Data of relevant stakeholders, which it holds or to which it has access:
  • Appointment of Responsible Employees: Specific employees are appointed with designated responsibilities for:
    • Processing and controlling data
    • Comprehensive reviewing and auditing of data protection systems and procedures
    • Overseeing the effectiveness and integrity of all data that must be protected.
  • Clear Accountability: There are established lines of responsibility and accountability for these various roles.
  • Employee Training: Qualify Learn provides employees with information and training to raise awareness about the importance of protecting Personal Data, teaching them how to safeguard this information and understand how to treat it confidentially.
  • Data Accountability: The organization maintains a record of all Personal Data it holds, including its sources, sharing practices, and potential future sharing.
  • Risk Assessments: Regular risk assessments are conducted to identify any vulnerabilities in Personal Data handling and processing, and measures are taken to mitigate the risks of mishandling and potential data security breaches. This procedure includes assessing the impact of both the use and potential misuse of Personal Data within the organization.
  • Consent Management: Qualify Learn recognizes the importance of seeking individuals’ consent for obtaining, recording, using, sharing, storing, and retaining their Personal Data. Procedures for doing so are regularly reviewed, including the audit trails necessary for all consent decisions. The organization understands that consent must be freely given, specific, informed, and unambiguous, and will seek consent on a specific and individual basis when appropriate. Full information will be provided regarding the activities for which consent is sought, and individuals have the absolute right to withdraw their consent at any time without hindrance.
  • Breach Detection and Reporting: Qualify Learn has established mechanisms for detecting, reporting, and investigating suspected or actual Personal Data breaches, including security breaches. The organization is aware of its obligation to report significant breaches that may cause substantial harm to affected individuals to the relevant supervisory authority, along with understanding the potential consequences.
  • International Data Transfers: The organization is aware of the implications of transferring Personal Data internationally.
  1. Breach Notification
    In the event of a data breach that is likely to pose a risk to the rights and freedoms of individuals, Qualify Learn will report the breach to the relevant supervisory authority within 72 hours of becoming aware of it. Such notifications may occur in more than one instalment. Affected individuals will be informed directly if the breach is likely to result in a high risk to their rights and freedoms. If the breach warrants public notification, Qualify Learn will do so without undue delay.
  2. External Links on Our Website
    For your convenience, Qualify Learn may provide links to websites operated by organizations other than Qualify Learn (“Third Party Sites”) that may be of interest to you. We do not disclose your Personal Data to these Third Party Sites unless we have a lawful basis for doing so. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, we encourage you to review the privacy policy posted on that website to understand how it collects and uses your Personal Data.

 

  1. Information for California Residents
    If you are a California resident, please be aware that, depending on your relationship with Qualify Learn, we may have collected the following categories of Personal Data within the last twelve (12) months:

Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.

Protected classification characteristics under California or federal law.

Age, race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Biometric information.

Genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Geolocation data.

Physical location or movements.

Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information

Professional or employment-related information.

Current or past job history or performance evaluations.

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Inferences drawn from other Personal Information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

Sensitive personal Information

Consumers Social Security, driver’s license, identification card, passport number, a consumer’s account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, genetic data, contents of consumer’s mail, email or text messages, consumers racial or ethnic origin, religious or philosophical beliefs, or union membership and their genetic data

 

 

For more information on the types of Personal Data we collect, including the sources from which we receive information, please refer to the section on Types of Personal Data Collected. We collect and utilize these categories of personal information for the business purposes outlined in the Purpose of Collecting Data section, including to provide and manage our platforms effectively.

Qualify Learn does not engage in the sale of Personal Data as defined under the California Consumer Privacy Act (CCPA). In the case of advertising technology activities, such as those disclosed in the Advertising and Marketing & Data Analytics section, we will comply with applicable laws regarding such activities. If you are a California consumer and wish to opt out of the sale of your Personal Data, please visit the “Do Not Sell My Personal Information” page on our site homepage to exercise your rights and learn more about how to opt out.

You may also submit requests to us at dpo@qualifylearn.com.

We collaborate with various entities to assist with our daily operations and manage our platforms. Please review the section on Disclosure of Your Personal Data for more details about the parties with whom we have shared your Personal Data.

We will not discriminate against you for exercising any of your rights under the CCPA. In the future, we may choose to offer certain financial incentives permitted by the CCPA that could lead to different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your Personal Data and will include written terms that describe the material aspects of the program.

 

  1. Use of This Website and Our Terms of Service

This website is the property of Qualify Learn. Our Terms of Use and this Privacy Policy collectively govern the use of the platform and the programs offered by Qualify Learn. This Privacy Policy is incorporated by reference into the Terms. By using this website and the information provided herein, you indicate your acceptance of these Terms of Use.

  1. Updates to This Policy

We may update our Privacy Policy periodically. We will take reasonable steps to inform all Qualify Learn entities, customers, business partners, and other affected data subjects about these revisions by posting the updated Privacy Policy on this page and/or via email.

  1. Data Controller / Company Details

The “Data Controller” (i.e., Qualify Learn) refers to the entity responsible for making decisions regarding how your data is used and for determining how it holds personal information about you.

As Qualify Learn comprises various legal entities, the entity acting as the data controller for your information will depend on the context in which your Personal Data is collected.

  1. Data Protection Officer

In compliance with applicable laws and regulations, Qualify Learn has appointed a Data Protection Officer, who can be reached at the following details:

Email Address: dpo@qualifylearn.com