- INFORMATION WE COLLECT AND RECEIVE
- Personal Information Collected from You
The data that we collect from you may contain ‘sensitive personal data or information’ or ‘personal information’ as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (Data Protection Rules). The personal information which DESTA will collect, store, use, process, and transfer may include but is not restricted to: name, gender, date of birth, bank account details, home address, email IDs, phone-numbers and other contact information of the User. With your consent, we may also collect documents that may serve as proof of identity and address, the details of your income and expenditure and personal information through surveys conducted by us. We may extract any and all identifiers from these documents and surveys, and use them for the Purposes mentioned below, in accordance with law. You are not required to provide your Aadhaar number for the use of DESTA Platform and the submission of your Aadhaar number is entirely voluntary.
- Other Personal or Sensitive Personal Information You Provide
- Account creation information: Users provide information such as an email address and password, including by way of logging in to an existing social networking service such as their Google account.
- Billing and other information: For purchasing courses through the DESTA Platform, we and/or third party vendors may collect and store your information on our behalf, may pass some of your information to us. We may also collect this information ourselves and pass some of this information on to them for processing. We will act on your behalf to enable you to provide your information to our partner. This information includes the information contained in your demographic identity details such as your name, date of birth, phone number(s), address(es), type of residence, profession and nature of employment, information in relation to your bank account, and your photograph.
- Payment Information: To enable ourselves and/or our third party payment services to collect any payments or repayments or other fees, including through auto-debits, we will need to collect the financial information you provide for this purpose including your credit card number, your debit card number, your bank account number, bank IFSC code, your UPI handle, payment wallet information and net-banking details. The information we collect would depend on the payment method that you use. We may pass this information on to our third-party payment services vendors or these entities may also directly collect this information from you.
- DESTA Platform information: DESTA may directly or through its third-party vendors collect user information such as SMS, contacts and location data from the device on which DESTA Platform is being used or installed. This also includes information collected by DESTA about how you are accessing and using the DESTA Platform, which will include administrative and support communications with us and information about the purchases made through the DESTA Platform. We may access certain aspects of your device to enable you to use the DESTA Platform. For instance, we may access the camera so that you can upload a photo for verification purposes, we may access your device’s storage so that you can store your documents and upload them to the DESTA Platform and we may access the list of contacts on your phone to autofill certain details on the DESTA Platform.
- Other apps: With your permission, the DESTA Platform may read and collect your SMS data from your device. Further, we may also collect information about the apps installed on your device, including their name, date of installation, and period of use for the purposes of carrying out a fraud check. However, no in-app data will be collected from these other apps.
- Account information: With your permission, we may collect information about your other accounts on the device including your social media accounts and your contact information from these accounts. We may also collect your phone number and email address to contact you. You may also receive SMSs, emails, phone calls, etc., in connection with the DESTA Platform.
- Log data: We collect information that your browser or mobile device sends whenever you visit or use the DESTA Platform. This log data may include your Internet protocol address, the address of the web page you visited before using the DESTA Platform, your browser type and settings, the date and time of your use of the DESTA Platform, information about your browser configuration and plug-ins, language preferences, and cookie data.
- Device information: We may collect information about the device you are using the DESTA Platform on, including IMEI number of the device or any other device ID, information about your SIM card, operating system, device settings, application IDs, unique device identifiers, running apps and crash data. We may also collect network information about your device such as your WiFi and Bluetooth connections, your network connectivity and your access to any network.
- Geo-location information: We will collect your geo-location data from your device with your permission along with network-based location information about your Wi-Fi and IP addresses received from your browser or device.
- Third party data: DESTA may also receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which IP addresses go with which pin codes, or it might be more specific information, such as about how well an online marketing or email campaign performed.
The information above would be collected and retained by the following entity:
DESTA Research LLP
We will not retain any sensitive personal data or information for longer than is required for the purpose for which such data or information was collected, or may lawfully be used, or is otherwise required under any other law for the time being in force. We may retain anonymized data for as long as is required.
Some cookies are associated with your account and personal information in order to remember that you are logged in and which accounts you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things.
- PURPOSE OF COLLECTION
In addition to the purposes mentioned in Part A.b above, DESTA may process information including sensitive personal data or information concerning you both internally and externally (so far as reasonably necessary) for the purposes mentioned below (the purposes in Part A.b above and contained below together Purposes).
You have the option to refrain from disclosing your sensitive personal data or information to DESTA. You will also have the option of withdrawing consent previously provided to DESTA. However, exercising this option will hamper DESTA’s ability to provide you with any or all of the features of the DESTA Platform.
We use personal information of Users for the following purposes:
- General Purposes: DESTA will access and use your data as reasonably necessary and in accordance with your instructions to (a) provide, maintain and improve the DESTA Platform; (b) prevent or address service, security, technical issues, or at your request in connection with support matters; (c) act in a manner required by law, and (d) act in the manner expressly permitted in writing by you.
- To improve DESTA Platform: We carry out research and analyse trends to better understand how Users are using the DESTA Platform and improve them. We may use your information to expand our services and business.
- We use your data to provide you with better experience or provide you with customised products or services or to reach out to you with more value added applications, products, information and services. We may use your data so that we can offer you custom and personalised services or communications where such options are available.
- Marketing Purposes: We may use the information provided by you to deliver targeted advertising, newsletters and other promotional information (including but not limited to exclusive offers, recommendations, upcoming or existing products and services) about us to you.
- To communicate with you by:
- Responding to your requests: If you contact us with a problem or question, we will use your information to respond.
- Billing and account management: We use account data to administer accounts and keep track of billing and payments. We may use your account related information and other information available to us to process defaults.
- Communicating with you: We often need to contact you for invoicing, account management and similar reasons. We may also use your contact information (with us) for our own marketing or advertising purposes. You can opt out of these at any time.
- Investigating and preventing bad things from happening: We work hard to keep the DESTA Platform secure and to prevent abuse and fraud.
- Analysing and ensuring that great things do happen: We work hard to make our products intelligent; and any information from you, that we can use to make the DESTA Platform serve you better, we want to and will.
- As required by law: We use information collected from you to comply with, as well as to enable third party vendors to comply with, obligations under law.
- YOUR CHOICES
- Your Data
You provide us with instructions on what to do with your data. You have many choices and control over your data. For example, you may provision or deprovision access to the DESTA Platform, enable or disable third party integrations, manage permissions, change retention and export settings and transfer or assign your data.
- Access to Personal Data or Information
You will have the right, upon request, to access and review the personal information provided by you and held by DESTA. Upon discovering that the information provided is inaccurate or deficient in any manner, you will have the right to request suitable changes or amendments to such information, which may be provided by DESTA, when feasible.
- Other Choices
In addition, your mobile device may provide you with choices around how and whether location or other data is collected and shared. DESTA does not control these choices, or default settings, which are offered by makers of your mobile device’s operating system.
- SHARING AND DISCLOSURE
DESTA will not publish or disclose your personal information without your prior consent, unless it is required to do so in order to facilitate use of the DESTA Platform, or for the Purposes (as indicated in Part B), or if mandated by law, or if you have previously provided your consent. DESTA may disclose personal information with its partners, employees, officers, agents, consultants, business associates, contractors, attorneys, etc., on a need to know basis for the Purposes.
DESTA will disclose any sensitive personal data and information if there is a legal requirement or if it is ordered to do so by a court of competent jurisdiction or to any government agency if required by law for the purposes of verification of identity, or for prevention, detection, or investigation of crime (including cyber incidents), or for prosecution or punishment of offences.
You understand and agree that any portion of the information containing personal data relating to minors provided by you shall be deemed to be given with the consent of the minor’s legal guardian. Such consent is deemed to be provided by your registration with us.
We do not sell, trade or share your information to any third party (except subsidiaries/affiliates of DESTA for related offerings) unless, we have been expressly authorised by you either in writing or electronically to do so.
- SHARING OF INFORMATION BY THE USER
We shall not be responsible for any information or data leak, breach or otherwise, caused due to the following actions :
- Other Third Parties: We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.
DESTA may transfer personal information pertaining to you to third parties for the Purposes. You are expressly notified that the transfer may also be to foreign jurisdictions where your personal information may be processed by third-party service providers and vendors, or our group companies, in relation to the Purposes (as indicated in Part B).
DESTA ensures the confidentiality and security of the personal information and sensitive personal data and information provided by you by implementing comprehensive information security practices and standards as mandated by the Data Protection Rules.
- CHILDREN’S PRIVACY AND PARENTAL CONTROLS
DESTA Platform is not intended for persons under the age of 13, and we have no intention of collecting or soliciting Personal Information from persons under the age of 13. If you are not 13 or older, you are not authorised to use the DESTA Platform.
If you become aware of any data we have collected from children under age 13, please contact our authorised officer whose name and address are as follows:
- GOVERNING LAW
- GRIEVANCE OFFICER