Privacy Policy

Last Updated: January 2025

1. Introduction

Octa Learning (together with its subsidiaries and international affiliates, hereinafter "Octa Learning", "us", "we", or "our" or "the Company") is committed to the security and management of personal data, to function effectively and successfully for the benefit of our stakeholders, customers and the community. In doing so, it is essential that people's privacy is protected through lawful and appropriate means for handling personal data. Therefore, we have implemented this privacy policy (hereinafter referred to as the "Policy").

2. Aim

This Policy aims to protect personal data of the various stakeholders connected to our organization. It is aimed at providing individuals notice of the basic principles by which the Company processes the personal data of individuals ("Personal Data") who visit, use, deal with and/or transact through the website and includes a guest user and browser (hereinafter "you", "user").

3. Purpose and Scope

The purpose of this Policy is to describe how Octa Learning collects, uses and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us (hereinafter the "Website"). This Policy is also designed to provide information on how Octa Learning ensures data security, conducts data transfers and processes requests from data subjects.

This Policy applies to all systems, people and processes that constitute the organization's information systems, including board members, directors, employees and other third parties who have access to Personal Data processed by Octa Learning.

The Company is also committed to ensuring that its employees conduct themselves in line with this, and other related, policies. Where third parties process data on behalf of Octa Learning, we endeavour to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.

Octa Learning offers curated and specially designed higher education and industry-relevant certification programs online (hereinafter individually or collectively referred to as "Program(s)"). This Privacy Policy applies to all our services unless specified otherwise.

4. Types of Personal Data Collected

The Personal Data that we collect about you depends on the context of your interactions with us, the products, services and features that you use, your location and the applicable laws.

Personal Data is stored in personnel files or within electronic records on servers in India or other countries of Octa Learning. The following types of Personal Data may be held by the Company (as appropriate) on relevant individuals:

A. Personal Identification Data

  • First name, last name
  • Job title and company
  • Signature
  • Photographs

B. Identification Data

  • Social security or tax identification numbers
  • Aadhaar number and PAN (where applicable)

C. Financial Data

  • Bank account information
  • Salary or stipend information (where relevant)
  • Payment gateway account details
  • E-wallet account details

D. Personal Characteristics

  • Age
  • Gender
  • Date of birth
  • Marital status
  • Nationality

E. Contact Data

  • Postal address
  • Email address
  • Phone number

F. Education and Recruitment Data

  • Educational qualification(s)
  • Working goals or career aspirations
  • Post-qualification experience

G. Electronic Identification Data

  • Login credentials (if you are a registered user)
  • Visitor IP data
  • Date and time of website visit
  • Pages visited and navigation on the website
  • Browser being used
  • Country of accessing website
  • Language of the browser being used
  • Words searched for
  • Pixel tags or similar technologies

H. Inquiries

  • Personal data stated in forms – for example: name, address, phone number, country
  • Subject of inquiry
  • Personal details (name on the card, billing address) for payments
  • Payment details (card numbers, card type)
  • Recordings of calls with students and users showing interest in our Programs
  • Information about your interactions with customer service and maintenance interactions with us

I. User Generated Data

  • Projects and assignments submitted
  • Peer feedback and grading
  • Program performance data
  • Responses to quizzes, exams and surveys
  • Webcam recordings (during assessments related to online courses), where applicable

J. Marketing Data

  • Your preferences in receiving marketing information
  • Your communication preferences

K. Behavioural Data

  • Data inferred or assumed relating to your behaviour and interests based on your online activity on our sites

We do not collect any payment card information processed by third-party payment gateway providers; such details are handled directly by those providers.

5. Special Categories of Personal Data

Special Category of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, and information about your health, as well as genetic and biometric data.

We do not knowingly collect or process any special or sensitive Personal Data unless it is strictly necessary and lawful to do so, and where required we will obtain your explicit consent.

6. Sources of Data Collection

The data collected by the Company is derived directly from data provided by you or by use of our sites, as well as from certain third parties as described below.

Data Collected When You:

  • Register for seminars, webinars or outreach initiatives made available by us or our educational partners.
  • View online ads from various platforms such as Facebook, Instagram, Google, Twitter, etc.
  • Register in any of our job portals.
  • Request a quote for various products and services offered by us.
  • Place feedback, complete any customer surveys or interact with our customer services online.
  • View our services or visit our website pages.

Data Collected from Third Parties

We may receive personal data such as access or login details, profile pictures or other information in relation to your Personal Data which may be available with such third parties. We also receive information about your visits to our platform and to other websites using pixel tags, cookies and similar technologies.

7. Cookies

Cookies are text files placed on your computer or device to collect standard internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technologies.

We may also allow third-party advertising companies (such as Facebook, Google, Twitter, Quora, Bing and others) to place cookies on our website to track your activity across sites where they display ads and record your activities, so they can show ads that they consider relevant to you as you browse the internet.

How Do We Use Cookies?

  • To recognize our website user and enhance user experience when interacting with our website.
  • To help us analyze the use and performance of our website and services.
  • To improve the delivery and value of various services and products offered by us.

What Types of Cookies Do We Use?

We may use the following types of cookies:

  • Persistent Cookies: To improve your experience on our sites – for example, storing your acceptance of our cookie policy.
  • Session Cookies: Temporary cookies that are deleted from your device when your web browser closes.
  • Analytical/Performance Cookies: To recognize and count the number of visitors and see how visitors move around our website.

How to Manage Cookies?

Most browsers allow you to refuse to accept cookies and to delete cookies. Methods for doing so vary from browser to browser and version to version. Disabling some cookies may negatively impact the availability or functionality of some features.

You can usually find up-to-date information about blocking and deleting cookies via your browser's support pages.

8. Data Analytics

We use analytics tools and search information providers to measure how visitors interact with content on our website. These tools help us understand and improve the performance and user experience of our websites and services.

9. Aggregated Data

"Aggregated Data" means records that have been stripped of Personal Data and have been combined to provide generalized, anonymous information. Your identity and personal information are not available in Aggregated Data. We may use Aggregated Data for internal and commercial use and for sharing with affiliates, subsidiaries and partners for planning and marketing purposes.

10. Data Protection Principles

Where third parties process data on behalf of Octa Learning, we endeavour to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.

All Personal Data obtained and held by the Company will:

  • Be processed fairly, lawfully and in a transparent manner
  • Be collected for specified, explicit and legitimate purposes
  • Be adequate, relevant and limited to what is necessary for the purposes of processing
  • Be kept accurate and up to date, with reasonable steps taken to rectify or erase inaccurate data without delay
  • Not be kept for longer than is necessary for its given purpose
  • Be processed in a manner that ensures appropriate security of Personal Data using appropriate technical and organizational measures
  • Comply with relevant laws and procedures for international transfer of Personal Data where applicable

11. Legal Basis for Processing Your Personal Data

Certain jurisdictions require that we have a lawful basis to justify our processing of your Personal Data. The lawful basis used by Octa Learning may differ depending on the type of data and purpose.

Octa Learning relies upon the following lawful bases to process Personal Data, as permitted under applicable law:

  • Processing necessary for the negotiation, execution or performance of contracts
  • Processing to comply with legal and regulatory obligations
  • Processing in furtherance of our legitimate interests (including improving our products and services, communicating with you, securing our systems and similar interests)
  • Processing necessary to protect vital interests of you or another natural person
  • Processing necessary for public interest
  • Processing based on your consent

12. Consent

We may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law. Once consent is obtained, we will rely on it for the purposes described at the time you provided it.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, if you refuse or withdraw consent, we may not be able to provide you with certain services.

13. Purpose of Collecting Personal Data

We collect your Personal Data for the following purposes:

  • To fulfill or meet the reason you provided the information
  • To manage and process Programs, including tracking attendance, progress and completion
  • To administer exams, projects and other assessments for Programs
  • To send you updates about Programs, events, maintenance and new services offered by Octa Learning
  • To provide chat or support services
  • To enhance the quality of our content, offerings and customer experience
  • To comply with security, legal and other mandatory policies and requirements
  • To provide information to relevant authorities as legally required
  • To conduct surveys and gather feedback to improve our services

14. Advertising and Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. You may receive marketing communications from us if you have requested information or consented to receive such communications.

We may use your Personal Identification, Contact, Electronic and User Generated Data to form a view on what we think you may want or need, or what may be of interest to you, and we use this to decide which services and offers may be relevant.

Where electronic direct marketing communications are being sent, you will have the option to opt-out in each communication, and this choice will be recognized and adhered to by us.

15. Disclosure of Personal Data

Octa Learning is a global organization and may share Personal Data or provide access to such data to other companies within the Octa Learning group or with certain third parties as described below, always in accordance with applicable law.

Examples of recipients with whom Octa Learning may share Personal Data include, but are not limited to:

  • Government bodies and agencies, including tax and social security authorities, to comply with applicable laws and requests
  • Suppliers, subcontractors and service providers who support our operations (technology, telecom, payment, mentoring, analytics, marketing, etc.)
  • Professional advisers, consultants and recruitment agencies
  • Our legal advisers and auditors for legal advice and audits
  • Business continuity and contingency planning service providers
  • Certain companies in order to establish a membership or participation in digital wallets, payment services or rewards programs
RecipientsCategory(ies) of Personal Data We ShareWhy We Share ItLocation(s)
Educational partners, universities or companies offering the course, external graders, mentors
  • Personal Identification Data
  • Personal Characteristics Data
  • Contact Data
  • User Generated Data
  • Evaluate and assess your progress and performance in the Program
  • Report on your progress in the Program and enable them to issue certificates on completion
Global
Employers, sponsors and scholarship providers
  • Personal Identification Data
  • Personal Characteristics Data
  • Contact Data
  • User Generated Data
  • Where your Program is sponsored, to share details of your enrolment, performance and completion
Global
Service providers (operations, maintenance, technology, payment, analytics, marketing, customer support, etc.)
  • Personal Identification Data
  • Personal Characteristics Data
  • Contact Data
  • User Generated Data
  • Financial Data
  • Electronic Identification Data
  • Data generated from inquiries
  • Marketing Data
  • To provide various services including billing, analytics, support, fraud prevention and platform operations
Global
Third parties (for networking, marketing, and community activities)
  • Identification Data
  • Data generated from inquiries
  • Marketing Data
  • Education and Recruitment Data
  • Behavioural Data
  • To provide you services you have requested (e.g. networking or community activities)
  • To arrange networking activities with previous, current or potential students
  • To share information that can be used to contact you about third-party services that may interest you
Global
Recruitment service providers, recruitment agencies and potential employers
  • Personal Identification Data
  • Personal Characteristics Data
  • Contact Data
  • User Generated Data
  • Education and Recruitment Data
  • If you opt-in to recruitment services, to share relevant information with recruiters and potential employers
Global
Associates and in case of business transfers (e.g. sale, merger, reorganisation)
  • Personal Identification Data
  • Personal Characteristics Data
  • Contact Data
  • User Generated Data
  • To enable continuation of services in case of corporate restructuring or business transfer, in accordance with applicable law
Global

Whenever we share your Personal Data with third parties, we require them to maintain appropriate security and confidentiality and to process your data only for the purposes specified by Octa Learning and in accordance with applicable data protection laws.