Privacy Policy

1. INTRODUCTION

We at TURNKEY INSIGHTS (I) PRIVATE LIMITED (“Turnkey”, “We”, “Us”, “Our”) respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy explains our practices with regard to the collection, handling, storing, disclosing and otherwise using any information that we collect from you, directly or indirectly (“Information”), including Personal Information and SPD and describes your rights to access, correct, or restrict our use of your personal data.

In pursuance of our obligation under Section 43A of the Information Technology Act 2000 (hereinafter the “IT Act”) and Rule 4 of the Information Technology Rules, 2011 (reasonable security practices and procedures and sensitive personal data or information, and Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011, we present this Privacy Policy to all users who may use any of our Services.

This Information is obtained by Turnkey, its group companies and Turnkey Affiliates in relation to our services offered on our website: www.turnkeylearning.com

This Privacy Policy is concerned with Information relating to Turnkey’s services, and therefore, should be read along with the “Terms of Use” available on www.turnkeylearning.com/terms-of-service. The Terms of Use is the contract that allows you to access the services from us.

By accessing and/or using the Website and/or Services that we offer, you accept the terms of this Privacy Policy. If you do not agree with any or all of the contents of this Privacy Policy, please do not access and/or use the services. To clarify, users who subscribe to Turnkey’s services must attain the age of majority under Law in their respective jurisdiction. Individuals who are under the relevant age of majority may utilize the services only under the supervision and approval of their parents and/or legal guardian.

We request you to review the Privacy Policy from time-to-time. If you continue to use the Services after any Privacy Policy amendments, we will reasonably infer this as your acceptance of such revised Privacy Policy. Further, Turnkey retains the right at any time to deny or suspend access to all, or any part of, the service to anyone who Turnkey reasonably believes has violated any provision of this Privacy Policy.

Words capitalized in this Privacy Policy but not separately defined shall have the meaning ascribed to such words in the Terms of Use.

2. HOW TO CONTACT US

We have a customer support team that will address your grievances through email, chat and voice call. For queries to be addressed through email, users can reach out to Sirisha Ramesh. The chat and voice call details are as follows: 1-800-103-8627

For data related issues, users can contact our IT Head/Security officer at:

dataprotection@turnkeylearning.com

Users can also contact our respective Grievance Officer for any kind of grievance related to the content, features, offers, subscription and/or payment related queries. Our Grievance Officer can be reached at:

grievances@turnkeylearning.com

3. INFORMATION COLLECTED FROM YOU

We collect the following Information about You, such as: -

(a) Non-Personal Information: You can access Our Website without disclosing any Personal Information, although the Services, in whole or part, require You to provide your personal Information. If you choose not to use Our Services, then the only Information collected will be ‘Non-Personal Information’ i.e. the Information that cannot be used to identify You. Non-Personal Information may include the last web pages you have visited.

(b) Anonymized Information: We collect anonymous Information from You when you access Our Website to monitor traffic and fix bugs. For example, we collect information like web requests, the data sent in response to such requests, the internet protocol address, the browser type, the browser language, and a timestamp for the request.

(c) Personally Identifiable Information: We also collect through our Website, or through third-party platforms being hosted by us, Personal Information or SPD that you provide to us when you create an Account for any educational programs or Course(s), participate in our public forums, avail our chat room services, send you emails, call you, participate in online events such as live lectures, webinars etc. and/or receive other services on or through our Website or through any our Educational Partners’ platform. This Information may include, among other things, your name, billing address, email address, contact number, tax identification numbers, login credentials (in the case of registered users), educational qualification(s), salary Information, working goals, post-qualification experience, current organization, and photographs. We collect demographic Information such as your gender, socio-economic status, and other similar personal Information. We may also collect your bank account Information. Apart from the aforementioned, we do not collect any of your financial Information, and all payments are processed by third-party payment gateway providers.

(c.1) Turnkey directly collects Information when you:

  • create a Turnkey Account and fill the Application Form;
  • enroll and participate in online courses;
  • send email messages to Turnkey (including messages to learner support);
  • participate in user surveys; and
  • participate in public forums, webinars, and other interactive experiences on the Turnkey’s Website.

(c.2) Information You give us: We collect, Personal Information and/or SPD and/or such other Information such as first and last name, gender, e-mail, contact number, professional title, company name, educational institution or organization name, and password. This includes Information provided to Turnkey in the course of routine interactions or provided in response to an email from Turnkey.

In order for you to use certain features of the Services, such as enrolling for a Course, You are required to register for an Account, and fill out an application form for that Course, and in that case, We will collect and store any registration Information You provided to Us, such as name, contact Information, e-mail address, educational background, work experience, current organization, password, Your date of birth, and age, and we will assign You a unique identifying number (“Registration Information”).

(c.3) Information we collect automatically

  • Your Device Information: Log Information, hardware model, operating system version, unique device identifiers, and IP Information including geographical location Information, and usage Information.
  • Aggregated Information: We may use cookies and web beacons to collect Information such as URL that you just came from, which URL you would go to next, your computer browsing Information, your IP address, other Information associated with your interaction with the Website. This Information is collected and analyzed on an aggregated basis so as to render the Services in an efficient manner to you.
  • Your Demographic Information

(c.4) Information Collected by Third Parties: Turnkey, or its Educational Partners and third-party service providers, may, for instance, collect certain Information from you in conjunction with assignments, exams and other assessments related to the Course. For instance, for pedagogical purposes, Turnkey’s Educational Partners (or its third-party service providers) may collect certain Personal Information or SPD from you to:

  • verify or authenticate your identity or submissions made by you, such as a signature for a test or an assignment log, a photograph or a recording of you (e.g., using a digital camera) or Information pertaining to your account or any document in connection with your account, or
  • review your performance throughout the Course, (e.g., confirming that you are not using prohibited resources during an exam). Turnkey may also collect Information from its Educational Partners about your performance or your progress, such as quiz/exam scores, grades, assignment evaluations, teacher evaluations and any other evaluations necessary, in connection with the Course.

We may receive Information about you if you use any of the other platforms we host or any other platform in connection with the Services. In this case, the Information may be analyzed internally and aggregated with the data collected on the Website and via Services. We also work closely with third parties including, Educational Partners, marketing partners, sales affiliates, third party technical/advertising networks, analytics providers, and search Information providers, and may receive Information about you from such sources. We may also receive your Information from your employers, educational institution or scholarship providers, where your Course is partly or fully sponsored by such a third-party. The third-party sponsoring your participation in the Courses may provide us your Information, subject to our agreement with them and, therefore, the third-party sponsor may be the controller with respect to such data.

(c.5) Information we collect from third parties: We may receive your Information when you access or log in to a third-party site, e.g., Facebook, WhatsApp from our Website or when you respond to our Ads on such third-party platforms. This may include some of your Personal Information or SPD available from the third-party site. Please note that the Information we obtain from such third-party platforms is often dependent on their privacy policies and/or on your preferences as to what Information you have consented to share with them, so and further.

We enter into arrangements with third parties to serve Ads on our behalf across the Internet for e.g. Google search engine, social networking sites, such as Facebook, Instagram and LinkedIn. They may collect or store Information about your visits to our Website and your interaction with our Services. They may also use Information about your visits to our Educational Partner’s platforms and to other websites to target advertisements for goods and services or for any other purpose. This Information is collected through the use of industry standard technology used by most major websites. Such third parties are not permitted by Turnkey to sell or share your Personal Information as part of this process. If such third parties sell or share the Personal Information as part of the process, Turnkey’s liability shall be limited to providing you with reasonable assistance in any action you may choose to take against such third parties, solely at your cost and expense.

We have third-party sales and marketing affiliates who may collect your Information through one of the various channels owned by them and share this Information with us, based on your interest in our Courses.

Turnkey may also recommend, in the event you require any financial assistance, to certain third-party credit facility providers to pay for a Course. Should you chose to avail such credit facilities offered by third party credit providers, then, any Information you provide to them shall be governed by their terms and conditions read with their privacy policy and other policies and it is expressly stated that Turnkey does not manage, control or regulate such third party service providers.

4. PURPOSE / USE OF INFORMATION

The collected Information, including Personal Information and/or SPD, will be used for the following purposes only:

Turnkey, or the case maybe, its Education Partners’ may also seek your consent for additional uses of Information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

5. DISCLOSURE OF INFORMATION

Please note that any Personal Information that is voluntarily displayed by you on the Website may be used by third parties for unsolicited purposes. Please note that Turnkey shall not be liable for such unsolicited use by third parties of your Personal Information that has been voluntarily displayed by you.

Turnkey requires the third parties to abide by this Privacy Policy and applicable laws; handle Personal Information in a confidential manner and maintain adequate security; and use Personal Information only as needed to fulfill the relevant purpose(s).

6. INFORMATION STORAGE

We and the third parties obtaining your Information retain your Information in a manner that identifies you only for the time period necessary for fulfilling the purposes mentioned under this Policy.

Turnkey stores Information, including Personal Information, on its own servers and also on servers of companies that Turnkey engages to provide services. Each Educational Partner also stores Information, including Personal Information, on its own servers and/or on servers of companies that the Turnkey engages to provide services. In each case, Information may be stored in the countries where Turnkey or such party operates from.

7. COOKIES

Cookies are small pieces of Information saved by your browser onto your computer or other device used to access the Website and/or Services. Cookies are used to record various aspects of your visit and to assist Turnkey to provide you with a better experience. We may use cookies to help us ascertain the usage pattern of a user and allows us to serve you in an efficient and better way, and to personalize your experience at Our Website or while using our Services. These cookies do not retain your Personal Information.

8. YOUR RIGHTS

9. SECURITY OF YOUR INFORMATION

10. DISCLAIMER

We cannot ensure that all of your private communications and other Personal Information and/or SPD (including sensitive Information like demographic Information and contact Information) will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your Personal Information will always remain private. As a user of the Website or Services, you understand and agree that you assume all responsibility and risk for your use of the Website or Services, the internet generally, and the documents you post or access and for your conduct on and off the Website.

11. GRIEVANCE MECHANISM

Should you have questions about this Privacy Policy, you may contact, the Data Protection Officer appointed by us in accordance with the provisions of IT Act and SPDI Rules at dataprotection@turnkeylearning.com. You may also write to us at: Turnkey Insights (I) Pvt. Ltd, No. 23, U Block, 10th Street, Anna Nagar, Chennai 600 040.