A.Overview

Welcome to keywindigital.com, a website (the “Website” ) owned by Keywin Digital (“Keywin Digital”, “Us” or “We”). This privacy policy (the “Privacy Policy” ) is designed to tell you about Keywin Digital’s practices regarding collection, use, and disclosure of information that you may provide for using our services via this platform (collectively referred to as the “Services”). We take your privacy seriously and are committed to protect your right to privacy pertaining to the information submitted by you as a user of our website . We have made every effort to ensure your information is secure. We have incorporated the information that shall be collected and the utilisation thereof by Us. You can use this information to make your decisions about your privacy.

The Services on our platform 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 of Service and any other rules, policies or guidelines published on the Platform as applicable to you (collectively referred to as the “Platform Terms”), and Keywin Digital disclaims all the liabilities arising therefrom. If you have inadvertently submitted any Personal Information to Us 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 any information you have provided or uploaded on the Platform violates the Platform Terms, Keywin Digital may be required to delete such information upon informing you of the same and revoke your access to the Platform if required.

Capitalized terms used but not defined in this Policy can be found in our Terms and conditions.
If you have any questions about this Policy, please contact us at [email protected]

B.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; Keywin Digital does not validate or takes no responsibility towards information, if any, provided by you as a guest, except as otherwise required under any law, regulation, or an order of competent authority. 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 ability to receive promotional offers from Us, is optional. Keywin Digital may, in future, include other optional requests for information from you to help Us to customize the Platform to deliver personalized information to you. We may keep records of telephone calls or emails received from or made by you for making enquiries, feedback, or other purposes for the purpose of rendering Services effectively and efficiently.

C.Access by Children

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, and only your Parent (defined below) can register on the Platform on your behalf, agree to all Platform Terms and enable access to you under their guidance and supervision.

While some of our Services may require collection of a Child’s Personal Information, we do not knowingly collect such Personal Information from a Child and assume that information has been provided with consent of the Parent. If you are a Parent and you are aware that your Child has provided us with any Personal Information without your consent, please contact us at [email protected] If we become aware that we have collected Personal Information from a Child in the absence of consent of the Parent, we will take steps to remove such information from our servers.

The information in the relevant parts of this notice applies to Children as well as adults. If your Child faces any form of abuse or harassment while availing our Services, you must write to us at [email protected] so that necessary actions could be considered.

D.Information Controller

Keywin Digital 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.

E.Personal Information

“Personal Information” shall mean the information which identifies a User i.e., first and last name, identification number, email address, age, gender, location, photograph and/or phone number provided at the time of registration or any time thereafter on the Platform.

“Sensitive Personal Information” shall include
(i) passwords and financial data (except the truncated last four digits of credit/debit card),
(ii) health data,
(iii) official identifier (such as biometric data, aadhar number, social security number, driver’s license, passport, etc.,),
(iv) information about sexual life, sexual identifier, race, ethnicity, political or religious belief or affiliation,
(v) account details and passwords,
(vi) other data/information categorized as ‘sensitive personal data’ or ‘special categories of data’ under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, or General Data Protection Regulation (GDPR) (“Data Protection Laws”) and in context of this Policy or other equivalent / similar legislations.

Usage of the term ‘Personal Information’ shall include ‘Sensitive Personal Information’ as may be applicable to the context of its usage. We request you to not provide Keywin Digital with any Personal Information unless specifically requested by us. In the event you share with Keywin Digital 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.

G.Basis of Collection and Processing of Your Personal Information

 Basis for collection:

We collect and process your Personal Information based on the following legal parameters depending upon the nature of Personal Information and the purposes for which it is processed:

1. 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.


2. 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:

1. 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;


2. To comply with our legal obligations as well as to keep records of our compliance processes;


3. 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;


4. Because you have chosen to publish or display your Personal Information on a public area of the Platform, such as a comment area;


5. Because it is necessary to protect your vital interests;


6. 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 ‘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.

H.How We Use and Share the Information Collected

We use/process your information in the following manner:

1. 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.


2. 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 our 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 Keywin Digital’s or a third party's rights and property, or the safety of Keywin Digital, 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.


3. 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.


4. 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.


5. 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


6. Consent: We may otherwise use your information with your consent or at your direction.


7. 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 Keywin Digital 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 ‘Grievances’ section below, we will investigate any such complaint and take the appropriate action as per the applicable Data Protection Laws.

1. Affiliates and Subsidiaries: We may disclose information about you to our affiliates, subsidiaries 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. 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.


2. 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 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.


3. 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. 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.


4. 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 Keywin Digital’s or a third party's rights and property, or the safety of Keywin Digital, 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.

1. Business transfers: In the event Keywin Digital undergoes any merger, acquisition, or sale of company assets, in part or in full, with another company, or in the unlikely event that Keywin Digital 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.


2. Advertising and Analytics Partners: We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies.


3. 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.

I.Duration for Which Your Information is Stored

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, ratings, 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 [email protected] for any clarifications needed.

J.Your Choices

1. 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.


2. 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.


3. 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.

K.Your Rights

If you are a User, you may exercise any of these rights by using the options provided to you within the Platform upon your login. 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.

1. 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.


2. 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.


3. Right to be Forgotten: You have the right to restrict or prevent the continuing disclosure of your Personal Information under certain circumstances.


4. 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.

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.

L.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 [email protected]

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 [email protected]

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 personalize 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.

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. However, if you have purchased a course on our Platform, as per your experience you may leave a testimonial. In some cases, we may ask you for testimonials which we will display on our website, photos and videos or in our social media channels such as Facebook, YouTube, Instagram or Flickr. You should be aware that your publicly identifiable information could be used to send you promotional, unsolicited messages. We are not responsible for your personal information which you have chosen to display.

If you don't want us to feature your pictures/testimonials on our website or on our social media channels, you can write a mail to [email protected]
You can contact us if you notice that the information we are holding is incorrect or incomplete. Please write to us at [email protected]

M.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.

Further, it is hereby clarified and declared that we are a Platform based in India and GDPR legislation is not applicable to Us or the Platform.