- Suraasa is the data controller of your personal information.
- We collect the personal information set out in the “What Information We Collect” section of this Privacy Notice below, including account registration details such as name and email, details of content offerings you undertake, survey information (where you provide it), identity verification data, and information about your use of our site and services.
- We use your personal information for the purposes set out in the “How We Use the Information” section of this Privacy Notice below, including providing our site and Services to you, ensuring the security and performance of our site, conducting research relating to content offerings, sharing information with our Content Providers and our suppliers, direct marketing, and performing statistical analysis of the use of our site and Services.
- You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the “Updating or Deleting Your Personally Identifiable Information” section of this Privacy Notice below.
Purpose and Who We are
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you
- The right of rectification
- The right to object
- The right of restriction
- The right to data portability
- The right to withdraw consent
What Information this Privacy Notice Covers
This Privacy Notice covers information we collect from you through our website and apps. Some of our Site’s functionality can be used without revealing any Personally Identifiable Information, though for features or Services related to the Content Offerings, Personally Identifiable Information is required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, “Personally Identifiable Information “or PII (i.e., information that can be used to identify you)(may also be referred to as “personal data” or “personal information”). PII can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the PII you submit to Suraasa. Inaccurate information may affect your ability to use the Site and mobile application, the information you receive when using the Site and mobile application, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
What You Agree to by Using Our Site and mobile application
We consider that the legal bases for using your personal information as set out in this Privacy Notice are as follows:
- our use of your personal information is necessary for complying with our legal obligations; or
- use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our Site and provide our Services;
- build relationships with partners and academic institutions;
- carry out research and statistical analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
- consent, to send you certain communications or where you submit certain information to us.
Which legal basis applies to a specific processing activity will depend on the type of personal information processed and the context in which it is processed.
If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to delete your account and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our Services to you.
What Information We Collect
- PII provided directly by you or via third parties. We collect PII that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site and mobile application. We may use the PII that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other Suraasa events, and send you email messages about Site maintenance or updates.
- Account Registration. If you register for an account on our Site, you may be required to provide us with PII such as your name and email address.
- Updates. Suraasa may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with PII such as your name and email address.
- Participation in Content Offerings. Suraasa offers users the opportunity to participate in Content Offerings on or through the Site and mobile applications. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.
If you participate in a Content Offering, we may collect from you certain content, including and not limited to, assignments you submit, instructor feedback. We also collect course data, such as student responses to video quizzes, standalone quizzes, exams, and surveys. You should not include any PII or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate or submit such assignments, exams, or surveys.
- Identity Verification. Suraasa may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with PII such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document. Additionally, if you apply for financial aid in connection with these Services, you may be required to provide information regarding your income.
- Communications with Suraasa. We may receive PII when you send us an email message or otherwise contact us.
- Third Party Sites. We may receive PII when you access or log-in to a third party site, g., Gmail, Linkedin, from our Sites. This may include the text and/or images of your PII available from the third party site.
- Surveys. We may receive PII when you provide information in response to a survey operated by us or a Content Provider.
- Third Party Credit Card Processing. Suraasa provides you with the ability to pay for Content Offerings and other Services using a credit card through a third party payment processing service provider. Please note that our service provider – not Suraasa – collects and processes your credit card information.
How We Use the Information
- Information relating to your use of our Site.We use information relating to your use of the Site and mobile application to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site and mobile application. We may also use this information to ensure the security of our Services, the Site and mobile application.
- PII provided directly by you or via third parties. Except as set forth in this Privacy Notice or as specifically agreed to by you, Suraasa will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Privacy Notice, we may disclose and otherwise use PII as described below.
- Providing the Site, mobile application and our Services. We use PII which you provide to us in order to allow you to access and use the Site (and mobile application) and in order to provide any information, products, or services that you request from us.
- Technical support and security. We may use PII to provide technical support to you, where required, and to ensure the security of our Services and the Site(and mobile application).
- Updates. We use PII collected when you sign-up for our various email or update services to send you the messages in connection with the Site (and mobile application) or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Forums. You should not post any PII or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post Personally Identifiable Information, such PII may be collected during your use of the Forums. We may publish this information via extensions of our Platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain PII in future versions of the Content Offerings and to enhance future Content Offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the Content Provider, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using PII
- Participation in Content Offerings. We use the PII that we collect from you when you participate in a Content Offering through the Site (and mobile application) for processing purposes, including but not limited to tracking attendance, progress, online classrooms, assignments and completion of a Course. We may also share your PII and your performance in a given Content Offering internally within the organization or with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Identity Verification. For Services that require identity verification, we may use the PII that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This Service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after the successful verification of your profile information.
- Communications with or from Suraasa. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Notice. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.
- We may share your PII with Content Providers of Suraasa so that Content Providers may share information about their products and services that may be of interest to you where they are legally entitled to do so.
- Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our Content Providers so that our Content Providers may use the data for research related to online education.
- Disclosure to Suraasa Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our Services to you. Our Contractors may have limited access to your PII in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings. Access to your PII by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
- Disclosure to Acquirers. Suraasa may disclose and/or transfer your PII to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of Suraasa to which your PII
- e-Readers. If we receive any PII related to the extent to which you use designated e-Readers to access Suraasa materials, we may archive it, and use it for research, business, or other purposes.
We share certain data about you with instructors, companies performing services for us, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
- With Your Instructors:We share data that we have about you (except your email address) with instructors or teaching assistants for courses you enroll in or request information about, so they can improve their courses for you and other students. This data may include things like your city, country, browser language, operating system, device settings, the site that brought you to Suraasa, and your activities on Suraasa. If we collect additional data about you (like age or gender), we may share that too. We will not share your email address with instructors or teaching assistants. We also enable our instructors to implement Google Analytics on their course pages to track sources of traffic to their courses and optimize their course pages.
- With Service Providers, Contractors, and Agents:We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
- With Business Partners:We have agreements with other websites and platforms to distribute our Services and drive traffic to Suraasa.
- With Analytics and Data Enrichment Services:As part of our use of third-party analytics tools like Google Analytics, we share certain contact information, Account Data, System Data, Usage Data , or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
- To Administer Promotions and Surveys:we may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
- For Advertising:If we decide to offer advertising in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools, and to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and undertake web analytics. Advertisers may also share with us the data they collect about you.
- For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Permitted or required by law;
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Suraasa, our users, employees, members of the public, or our Services.
- During a Change in Control: If Suraasa undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
- After Aggregation/De-identification: we can disclose or use aggregate or de-identified data for any purpose.
We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.
Suraasa takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Suraasa, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact [email protected] with any concerns.
You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Users who believe we’ve unintentionally collected personal data about them should contact us for help deleting that information.
- To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account.
- Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
- The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared.
If you have any questions about your data, our use of it, or your rights, contact us at [email protected].
Updating or Deleting your Personally Identifiable Information
You have certain rights in relation to your Personally Identifiable Information. You can access your PII and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us, and request that we delete or provide you with a copy of your personal data by logging into the Site and visiting your user account page.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via [email protected]. If you reside or are located in the EEA, you have the right to request that we:
- provide access to any PII we hold about you;
- prevent the processing of your PII for direct-marketing purposes;
- update any PII which is out of date or incorrect;
- delete any PII which we are holding about you;
- restrict the way that we process your Personally Identifiable Information;
- provide your PII to a third party provider of services; or
- provide you with a copy of any PII which we hold about you. We try to answer every email promptly where possible and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain PII may be exempt from such requests in certain circumstances, which may include if we need to keep processing your PII to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Updates & Contact Info
When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email or postal mail with any questions, concerns, or disputes.