We will use and process the personal data collected over this website as set out in this policy. Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.
1.1 The following summary provides you with a quick overview of the processing activities undertaken on our website. You will find more detailed information under the indicated sections below.
- When you visit our website without setting up an account, only limited personal data will be processed to provide you with the website itself (see section 3).
- When you register for one of our online services (e.g., discussion forums, online activities, degree certificate programs, blogs, media portals or journal services) or subscribe to our newsletter, further personal data, including your name, email address, contact number, contact address, and other relevant information, will be collected and processed for the function, support and development of such services.
- Furthermore, your personal data will be used to provide you with information relating to our services and for statistical analysis that helps us to improve our website. Additionally, we may share your personal data with third-party content to improve your website experience.
- Your personal data may be disclosed to third parties that might be located outside your country of residence, where different data protection standards may potentially apply.
- We have implemented adequate safeguards to secure your personal data and retain your personal data only as long as necessary.
- ‘Akshardham’ Centre for Applied Research in Social Harmony.
- ‘Personal Data’ refers to any information relating to a natural person who can be identified, directly or indirectly, by reference to an identifier such as a name, email address, identification number, location data or an online identifier.
- ‘Processing’ refers to any operation performed on Personal Data, such as collection, recording, organisation, structuring, storage, analysis, adaptation, transfer or any kind of disclosure or other use.
- Intellectual Property (IP): Intellectual Property is a category of property that includes intangible creations of the human intellect. Intellectual Property includes but is not limited to text, course materials, photographs, video, audio and graphics, goods, designs, information, applications, software, music, audio files, articles, directories, guides, trademarks, service marks, trade names, trade dresses, copyrights, logos, domain names, code, and patents.
- ‘Third-Party’: refers to any individual, organisation, sole proprietor, association, partnership, company, corporation, subsidiary, affiliate, or a combination thereof, including joint venture or any other entity.
3.1 When you visit our website for informational reasons, i.e., without registering for any of our services and without providing us with Personal Data in any other form, we may automatically collect additional information about you which will contain, only in limited cases, Personal Data and which is automatically recognised by our server. This collected information includes:
- the website from which you have been directed;
- the date and time of your requests;
- your device type, screen resolution and browser version;
- your internet service provider, location and IP address;
- information on your operating system, including your language settings; and
- information on the offers you have visited on our website.
3.2 We use such information only to provide an effective service (e.g., to adapt our website to your device’s needs or allow you to use our website effectively) and to collect broad demographic information for anonymised, aggregated use.
4.1 Our website offers a media portal, access to online activities, degree certificate programs, digital content, the option to obtain newsletters and special author and trainer services. You may be asked to set up an account to use these services. With regard to the registration of an account and its subsequent use, we process:
- Information (such as, your legal name and email address) that is provided during registration;
- Data in connection with an account sign-in facility (e.g., log-in and password details);
- Communications sent by you (e.g., via e-mail or website communication forms).
4.2 Other data processing processes (e.g., purchasing a publication or a course) may be undertaken by us whenever you complete transactions using our website.
4.3 We will process the Personal Data you provide to:
- Identify you at sign-in
- Provide you with the services and information offered through the website
- Administer your account
- Process fees and payments
- Communicate with you
4.4 Using your Personal Data for behavioural profiling is done in the legitimate interest to improve your experience of using the website.
4.5 In the absence of exceptions within the specific services mentioned below, your Personal Data is retained for as long as your user account is used. After the deletion of your account, your Personal Data will be blocked and erased. Statutory storage obligations or the need for legal actions that may arise from misconduct within the services or payment problems can lead to a longer retention of your Personal Data.
4.6 Using your Personal Data for behavioural profiling is done in the legitimate interest to improve your experience of using the website.
To use the following services, you must set up an account. Your account retains your Personal Data for future interactions and other activities.
AARSH reserves the right to charge fees for access to portions of the website or any associated IP. This includes but is not limited to AARSH’s subscription services, courses, online activities, degree certificate programs, audio streaming/downloads or video viewing/downloads. AARSH allows you to pay for such services using a credit card or other methods through a third-party payment processing service provider. Please note that our service provider, not AARSH, collects and processes your financial information. By subscribing to our services and making payment, you expressly agree for the payment service provider to Process your Personal Data, including any financial information.
Course and Activity Services
If you desire to participate in any course or activity, you will be asked to provide us with certain information necessary to conduct such a course or activity. This information may include but is not limited to your legal name, email address and basic personal information.
If you participate in a course or activity, we may collect certain user-generated content, such as the assignments or responses you submit. We also collect course data, such as responses to quizzes, exams and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, quizzes, exams, or surveys, except when required.
We use Personal Data that we collect from you when you participate in a course or activity through the website for processing purposes, including but not limited to tracking attendance, progress and completion of a course or activity
We need your log-in data to identify you, provide the stored results, to provide certain save functionalities and a better user experience for the website.
To use the following services, you must set up an account. Your account retains your Personal Data for future interactions and other activities.
6.1 You can subscribe to our newsletter or mailing list service with your email address, which provides you with the latest news about events and services if you consent to receive such newsletters. These communications may also contain topic-specific advertisements. Your email address and relevant contact information will be retained when you subscribe to these services.
6.2 You may freely unsubscribe from these services at any time by following the instructions provided.
6.3 At the time of signing up to the programme, you accept that we will use this as your consent to be able to monitor your engagement with our programme and any communications sent across to you.
7.1 We do not use your Personal Data for automated decision-making that produces legal effects concerning you or similarly significantly affects you.8. Education and Research by AARSH
8.1 Our researchers, research collaborators and service providers may collect, use and share your Personal Data as part of a research study in which you have agreed to participate as a research subject, or in which your existing data are used.
8.2 Personal Data is collected for research purposes, as a research subject, you will be provided with consent and/or authorization form relating to the specific research project that explains the types of data collected and the purposes for which such data will be processed and shared.
8.3 We and our third-party vendors collect your Personal Data when you apply or register for online education offerings. We and they also collect Personal Data when you participate in online activities, programs and activities. In some cases, our collection of Personal Data from you in connection with online education activities takes place as part of a “hybrid” program in which you also may participate in person, or as part of remote learning occurring in a course or program that is ordinarily conducted in person.
The Personal Data collected by us, or on our behalf, are used for the primary purposes of providing you with online education, and, if applicable, evaluating your qualification for related certificates or credit. In such a case, the description of the collection and use of your Personal Data provided in the consent and or authorization form will replace the information provided here. The Personal Data collected by our researchers, research collaborators and service providers, or on their behalf, are used for the primary purposes of furthering the particular research project and more generally for supporting research and understanding in fields of academic study.
Examples of Personal Data that may be collected for research purposes are listed below. Of course, a single research study will rarely collect all of these types of data. If you have questions about the processing of your data in connection with a research study, you should contact the AARSH email below, who are conducting the research or the contact persons named in any consent form you signed when you joined the study. We may process your Personal Data for research in accordance with the purposes of the particular research projects, and also:
- To further research and understanding in fields of academic study;
- To enrol you in a particular research study as a research subject;
- To administer the study;
- To make reports to project funders and other project participants;
- To satisfy legal compliance requirements; or
8.4 The legal basis for us processing your Personal Data for the purposes described above on the basis of our legitimate interests (for example, conducting research); to process transactions requested by you and meet our contractual obligations (e.g., paying faculty, employees, research collaborators and research subjects); as necessary for compliance with a legal obligation (for example, to report adverse events to regulatory authorities; as necessary for the performance of tasks we carry out in the public interest (for example, to further research and understanding in fields of academic study); where processing is necessary for scientific or historical research purposes and performed consistent with required data protection safeguards; or on the basis of your consent, where applicable.
9.1 This website may use online advertising services to present you with ads that meet your interests. Respective advertisement is labelled with the provider’s name, e.g., “Google-Ad”. Such service helps us to improve our website. To effectively present advertisements that aggregate your experience with our website, we collect statistical information about you that the advertisement provider will process. This processing represents our legitimate interest to improve your website experience and promoting our products and services.10. Cookies, Web-beacons and other Tracking Technologies
10.1 Service Providers (“Providers”) will be automatically informed about your visit on our website. A web beacon is used to place a cookie on your computer for such a purpose.
10.2 Please note that we neither have control of the extent of Personal Data collected by the respective plug-in provider(s) nor do we know the processing’s purpose or the period your Personal Data will be retained. Depending on the Provider, your Personal Data may be transferred to and processed in other countries for further information about the potential risks of a cross border data transfer.
10.3 A Provider may disclose your Personal Data to its business partners, third parties or authorities.
10.4 You can prevent the installation of such cookies, web-beacons and other tracking technologies
- by a respective setting of your browser that blocks the installation of third-party cookies,
- by deactivating the provider’s interest-related advertising under the link mentioned in the provider details,
- by generally blocking cookies under, e.g. http://www.google.com/settings/ads/plugin
- or using applicable tracker blocking services.
10.5 The Providers’ privacy policies provide further information about the processing of your Personal Data in the their course of operation. You may acquire additional information with regards to your rights and settings concerning privacy by reviewing these policies.
For statistical analyses, we use web analytics services to collect information about the use of this site.
General Tracking Information
Our website uses tools to collect information, such as:
- your device and browser information (operating system information, Mobile device identifier, mobile operating system, etc.);
- your IP address;
- the page(s) you access;
- your URL click stream (the chronological order of our internet sites you visited);
- your geographic location;
- your time of visit and duration of visit;
- the referring site, application, or service from which you visited our website.
We only use this information to determine the most helpful information you are looking for and improve and optimise this website.
Depending on the Provider, the information generated about your use of the website may be transferred to and processed in other countries for further details on the potential risks of a cross border data transfer. Our website uses tools to collect the IP address assigned to you on the date and time you visited this site. The provider will use this information to evaluate your use of the website, compile reports on website activities, and provide other services relating to the website and internet use to us.
The use of these tools represent our legitimate interest in our website’s traffic to improve the user’s experience and optimise the website.
12.1 In this section, AARSH has set out the purposes for which we may process Personal Data and the legal bases of the processing.
- Operations - We may process your data to operate our website, the processing and fulfilment of orders, provide our services, supply our goods, generate invoices, bills and other payment-related documentation. The legal basis for this processing is our legitimate interests, namely the proper administration of our website services.
- Publications - We may process data to publish such data on our website and elsewhere through our services by your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
- Relationships and Communications - We may process contact data, account data, transaction data and communication data to manage our relationships, communicating with you (excluding sharing for direct marketing) by email, SMS, post, fax and or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
- Direct Marketing - We may process contact data, account data and transaction data to create, target, and send direct marketing communications by email, SMS, post and fax and contact by telephone. The legal basis for this processing is our legitimate interests, namely promoting our website and its services and communicating marketing messages and offers to our website visitors and service users.
- Research and Analysis - We may process usage data and transaction data to research and analyse the use of our website and services and research and analyse other interactions with our business. The legal basis for this processing is legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally. Further details are specified in Appendix 1.
- Record Keeping - We may process your Personal Data to create and maintain our databases, backup copies of our databases, and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our website and services in accordance with this policy.
- Security - We may process your Personal Data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and activities, and the protection of others.
- Insurance and Risk Management - We may process your Personal Data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and obtain professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our website and services against risks.
- Legal Claims - We may process your Personal Data where necessary to establish, exercise or defend legal claims, whether in court proceedings or an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- Legal Compliance and Vital Interests - We may also process your Personal Data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
13.1 We may potentially use third-party products and or/services for integration with AARSH’s services, including but not limited to social media plug-ins such as Facebook, YouTube, Google+, Twitter or services such as Vimeo (collectively, “Third-Party Services”).
13.2 Third-Party Services allows you to communicate with such products and post likes or comments from our website. Third-Party Services enable direct communication between your device and the third-party provider’s servers, allowing the provider to communicate with you and collect information about you browsing our website.
13.3 Third-Party Services may collect Personal Data whether you have an account with the provider or not. We try to use Third-Party Services that share our high standards and respect for privacy. However, we are not responsible for the content or privacy practices employed by Third-Party Services. We do not control the privacy policies of other websites, and this Policy does not apply to the privacy practices of different websites. Please note that we neither have control of the extent of Personal Data collected by the respective Third-Party Services nor do we know the processing’s purpose or the period your Personal Data will be retained.
13.4 AARSH does not review, approve, monitor, endorse, warrant, or make any representations with respect to Third-Party Services. Your access and or use of all such Third-Party Services is at your own risk. We will not be responsible for any of your Personal Data collected by such Third-Party Services. You should use discretion and caution while disclosing your Personal Data to such Third-Party Services.
13.5 We may disclose your data for indemnity purposes or to our advisors insofar as reasonably necessary to obtain or maintain insurance coverage, manage risks, and obtain professional advice.
13.6 Our payment services provider, Razorpay or any other payment services provider as may be appointed by us, may handle financial transactions relating to our website and services. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider’s privacy policies and practices at https://razorpay.com/privacy/.
13.7 In addition to the specific disclosures of Personal Data set out in this section, we may disclose your Personal Data where such disclosure is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or vital interests of another natural person. We may also disclose your Personal Data where such disclosure is necessary to establish, exercise, or defend legal claims, whether in court proceedings or an administrative or out-of-court procedure
13.8 Further information about the processing of your Personal Data in the provider’s course of operation is provided via. their respective privacy policies.14. Information Sharing
14.1 Your Personal Data will only be disclosed to a third party, including but not limited to BAPS Swaminarayan Sanstha and or its volunteers to the extent necessary to fulfil our contractual relationship (if at all) and or to provide better guidance and help to the persons enrolled with the Website for various online activities, and services and/or for any other legitimate reasons.
14.2 We may disclose anonymous aggregate statistics about users of the website to describe our services to prospective partners, advertisers and other reputable third parties and for other lawful purposes.
14.3 If you participate in an activity such as homework, quizzes, exams, projects, assignments, courses, online activities, diplomas and events through the website, we may also disclose your Personal Data general data (including content submission and your performance in any given activity) and demographic data with activity administrators, who are involved in the creation, modification, or operation of the activity, and our affiliated partners.
14.4 Information sharing will be based on data processing agreements. Therefore, our contractors will only use your Personal Data to the extent necessary to perform their functions and will be contractually bound to process your Personal Data in compliance with our requests.
14.5 In the event that we undergo re-organisation, any Personal Data we hold about you may be transferred to that re-organized entity or third party in compliance with applicable laws.
14.6 We may disclose your Personal Data if required to do so by law or in response to a court order or direction of any authority or if, in our good faith judgment, such legal disclosure is reasonably necessary to comply with legal processes or respond to any claims.15. Cross Border Data Transfers
15.1 Within the scope of our information sharing activities set out above, your Personal Data may be transferred to other countries with different data protection standards from your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement and regulatory agencies.16. International Transfers of Your Personal Data
16.1 In this section, we provide information about the circumstances in which your Personal Data may be transferred to a third country under India, UK and EU data protection laws, which will serve as standard terms across other jurisdictions save as to say anything local laws which are jurisdiction-specific will prevail.
16.2 The hosting facilities for our website are situated in India, UK and the United States. The competent data protection authorities have made an adequate determination concerning the data protection laws of each of these jurisdictions. Transfers to each of these jurisdictions will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, information which you may obtain by contacting: [email protected]
16.3 You acknowledge that Personal Data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such Personal Data by others.
17.1 We will store the information you provide, once received, in commercially reasonably secure operating environments that are not accessible by the public. We will store the information you provide in compliance with applicable laws, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“Sensitive Personal Data Rules”) issued under the Information Technology Act, 2000 (“IT Act”), for such time as is necessary to respond to your requests or provide you services you are/have enrolled in.18. Security
18.1 We will take all reasonable efforts to ensure the confidentiality of Personal Data, uploaded information, etc. and make reasonable efforts to ensure that the information received from you is not misused.
18.2 We have security measures to protect against the loss, misuse and alteration of Personal Data under our control and in accordance with the applicable laws. Our security and privacy policies are periodically reviewed and enhanced as necessary to ensure that only authorised personnel have access to our users’ Personal Data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we conduct reasonable efforts to prevent it.
18.3 You understand, agree and acknowledge that submitting information over the internet is never entirely secure. We cannot guarantee the security of the information you submit. Our website, whilst it is in transit over the internet, and any submission is at your own risk. Therefore, your posting of Personal Data information on this website constitutes your acceptance of this risk. By posting information, you waive any right to seek legal relief from this website due to any misuse, loss or inadvertent disclosure of your data.19. Data Retention
19.1 We strive to keep our processing activities concerning your Personal Data as limited as possible. In the absence of specific retention periods set out in this policy, your Personal Data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements. These may include retention periods mandated by legal, contractual, or similar obligations; for resolving, preserving, enforcing, or defending our legal and contractual rights; needed to maintain adequate and accurate financial records or how you access, update, or delete your data, etc.
Users located in the following jurisdictions:
- United Kingdom; and
- European Union
(each an “Additional Jurisdiction” and together, the “Additional Jurisdiction”).
If you are located within any specific jurisdictions and require further information about how we process and manage your data, please contact: [email protected]
Your principal rights under data protection law are:
- the right to access - you can ask for copies of your Personal Data;
- the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete Personal Data;
- the right to erasure - You have a right to request your stored Personal Data be erased, this will however mean that you will not be able to use any of the services and will be required to re-enrol onto future services and activities providing consent.
- the right to complain to a supervisory authority - you can complain about our processing of your data; and
- the right to withdraw consent - to the extent that the legal basis of our processing of your Personal Data, you can withdraw that consent. In such circumstances you will be withdrawn from all services and activities in its entirety. Please note any fees paid in respect of such services are non-refundable.
When contacting us, the information you provide will be collected and processed to handle your request.22. Consent and Amendments to this Policy
By accessing, browsing, and using our website, you acknowledged that you have read, understood, and consented to be bound by this Policy. We reserve the right to change, modify, add, or remove portions of this Policy from time to time. We encourage you to regularly visit the website and review this Policy to make sure you know of any changes to this Policy.
22.1 Grievance Officer
In accordance with the Sensitive Personal Data Rules, as prescribed under the IT Act, the contact details of the Grievance Officer is provided below:
Name: Ravi Dabgar
Email: [email protected]
If you have questions or concerns regarding your privacy, or would like to be removed from our mailing lists or change your preferences about the information you receive from us, or would like to delete or amend your personal information, please contact AARSH directly at: [email protected]
22.2 Governing Law and Jurisdiction
22.3 Changes to this Policy
22.4 Effective Date
The Effective Date of this Policy is 31 May 2022.
The United Kingdom and the European Union
These Disclosures also provide information about the collection, use, processing and sharing of data about individuals in the United Kingdom.
In these Disclosures,
- ‘GDPR’ means the European Union’s General Data Protection Regulation, as adopted in the United Kingdom following their departure from the European Union;
- ‘Personal Data’ means information relating to an identified or identifiable individual; an identifiable individual can be identified, directly or indirectly, by use of an identifier or factor specific to that individual; and
- ‘GDPR Processing Activities’ means the collection, use, processing or sharing of Personal Data when those activities are within the scope of the GDPR.
These disclosures apply only to Personal Data in GDPR Processing Activities. These Disclosures apply to GDPR Processing Activities, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).
A. How We Collect and Use Personal Data
We collect several categories of Personal Data in circumstances that may involve GDPR Processing Activities, including data you provide, data collected automatically (potentially including location data), and data we obtain from third party sources.
We use the Personal Data that we collect to carry on various institutional and educational activities. As described in more detail below, we rely on several legal bases to lawfully process your Personal Data.
The ways in which we collect and use your data vary depending on the relationship between you and us. The following sections of these Disclosures describe how we collect and use Personal Data in various circumstances that may involve GDPR Processing Activities.
1. Personal Data We Collect
Websites and Mobile Applications
As is true of most digital platforms, we obtain certain data automatically when you use one of our websites or mobile applications, such as your IP address, browser type and device type. Certain web-forms also collect Personal Data you provide, for example, when you enter data into form fields. Suppose we also process data through our websites or mobile applications for one of the activities described below. In that case, those descriptions will provide additional information about how those data are collected and used. Our third-party vendors use this Personal Data to conduct analytics, improve our websites, respond to your requests, and provide you with relevant information.
What Personal Data Do We Collect?
We and our third-party vendors collect Personal Data through websites and mobile applications, often resulting from users volunteering their data. We and our third-party vendors may collect:
- Contact Information: for example, your name, home address, email address, phone number and social media usernames;
- Log Files: Information collected automatically when you are interacting with websites or mobile applications, for example, IP address, browser type, internet service provider, pages visited (including referring/exit pages), operating system, date/time stamp and clickstream data;
- Location Information: We may use your IP address to identify the general geographic area from which you are accessing our website. Our mobile applications may collect more precise location information about you to provide functions specified in the application, such as a map feature; and
- Mobile Device Sensor Information: Some of our mobile applications may use various sensors and components of your mobile device (for example, your camera or microphone) to collect information to provide you with additional functions and features.
What is the Purpose of Processing?
We process your Personal Data collected on our websites and mobile applications:
- To facilitate our online interactions with you, for example, by responding to your requests;
- To operate, maintain and improve our websites and mobile applications, for example, by conducting analytics to improve and manage our websites and mobile applications, analyse user trends, and create custom audience lists;
- To collect data about you and your activities online over time and across different websites and social media channels for marketing purposes, including delivering relevant marketing communications to you; or
- To engage in other activities described under “Additional Uses of Personal Data” below.