INTRODUCTION

EdCast Asia Private Limited (“we”, “our”, “us”, “EdCast”), as contracted, has developed the FSP Platform (as defined below) for implementing the FutureSkills Prime Program (the “FSP Program,” or “FutureSkills Prime Program”) under the aegis of the National Association of Software and Service Companies (“NASSCOM”) in collaboration with relevant authorities of the Government of India (“GOI”) for authorized subscribers (as defined below), to have access to and certification under the FutureSkills Prime Program, the terms of which are described in the subscriber terms of service (“Terms of Service”).

We at EdCast, are committed to protecting the privacy and security of its users (“you”, “your”, “user(s)”, or “subscriber(s)”). Your privacy is important and maintaining your trust is paramount to us. This Privacy Policy (“Privacy Policy”) explains how we collect, use, process, disclose, and safeguard your information when you access and use the Services of the FSP Program platform through the website located at: https://learn.futureskillsprime.in and/or the FSP Program mobile app, respectively (collectively referred to as the “FSP Platform” or “Platform”), which shall be incorporated into and subject to the Terms of Service of the Platform and shall be read harmoniously and in conjunction.

The FSP Platform and Services are primarily available for use and download, within India only.

We strictly adhere to the requirements of the data protection laws established in India and this Privacy Policy is published in accordance with the following provisions, as the same may be amended/substituted from time to time:

• Section 43A of the Information Technology Act, 2000 (“IT Act”);
• Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SDPI Rules”); and
• Rule 3 of the Information Technology (Intermediary Guidelines) Rules, 2011.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Platform and Services, you agree to accept all the terms contained in this Privacy Policy and acknowledge and agree with the practices described herein. If you do not agree with the terms of this Privacy Policy, please do not access and use, the Platform and Services.

This Privacy Policy describes our privacy practices for all websites, products and services that are linked to it. However, this Privacy Policy does not apply to those partners that have their own privacy policy. In such situations, we recommend that you read the privacy policy on the applicable website. Any capitalised terms not defined hereunder shall hold the same definition as provided under the Terms of Service.

IF YOU ARE UNDER THE AGE OF 18, YOU MAY ONLY USE THE FSP PLATFORM WITH THE CONSENT OF YOUR PARENT OR LEGAL GUARDIAN.

If you have any questions regarding this Privacy Policy, please send us an email at: support@futureskillsprime.in.

WHAT INFORMATION DO WE COLLECT?

We collect Personal Information (as defined below) from you when you register or set up account with on the Platform. When you start using the Services, we ask you to provide certain information as part of the registration process, and in the course of your interface with the FSP Platform. We will collect this information through multiple means and in various places through the Services, including but not limited to, account registration forms, contact us forms, or when you otherwise interact with EdCast, including at customer support.

This Privacy Policy applies to:

• Information that you may provide to us voluntarily while registering on the Platform for using the Services, including but not limited to, mobile number, email address, password, date of birth, gender, address details, employment status. We may also ask you to provide your financial information, including but not limited to, billing address, bank account details, credit/debit card details to process your payment related details and payment method data to process payments for the Services (“Personal Information”). Certain additional information about yourself on a case to case basis. Further, when you visit the Platform, we may log certain non-personal information such as your IP address, cookie information, browser type, mobile operating system, manufacturer and model of your mobile device, geolocation, preferred language, access time and time spent. We will also collect information about the pages you view within our sites and other actions you take while using the FSP Platform (“Non-Personal Information”). We receive and store Non-Personal Information, by the use of the data collection devices such as ‘cookies’ on certain pages of the FSP Platform, in order to help and analyse our webpage flow, track user trends, measure promotional effectiveness, demographic studies and promote trust and safety. This Non-Personal Information is compiled and analysed by EdCast on an aggregated basis and not individually, in a manner that does not specifically identify you.
• Any information that is freely available, accessible in the public domain, furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information.
• All Personal Information and Non-Personal Information shall be deemed to be disclosed willingly and without any coercion. No liability of any form pertaining to the authenticity/genuineness/misrepresentation/fraud/negligence, etc. of the Personal Information provided by you, shall lie on EdCast, NASSCOM and/or GOI, nor will they be in any way responsible to verify any information obtained from you.

HOW DO WE USE YOUR INFORMATION?

We use the Personal Information and Non-Personal Information provided by you for the purposes described below and in accordance with applicable laws:

• To create your account, verifying your identity and process your transaction(s) on the FSP Platform;
• To collect statistics about your usage of the FSP Platform and its effectiveness;
• To improve and personalise your experience of the Services and the Content, as well as customize our interactions with you to further expand the scope of the FSP Platform;
• To resolve disputes, customer support and troubleshoot problems that arise from using the Platform;
• To help promote a safe service on the FSP Platform and protect the security and integrity of the FSP Platform, the Services, and the users;
• To collect payment from you in relation to the Services and the Content;
• To inform you about online and offline offers, products, services and/or updates;
• To customise your experience on the FSP Platform or share custom marketing material with you;
• To detect, prevent and protect EdCast from any errors, frauds, and other criminal or prohibited activity on the FSP Platform;
• To enforce and inform you about our Terms of Service;
• To process and fulfil your request for Services or respond to your queries on the FSP Platform;
• To contact you;
• To allow our business partners in respect of the FSP Program to present customised messages to you;
• To communicate important notices or changes in the Services offered and/or terms governing your use of the FSP Platform; and
• For any other purpose, for which you have granted access to such information to us, based on your interaction with the FSP Platform.

You specifically agree and consent to us collecting, storing, processing, transferring, and sharing your Personal Information and Non-Personal Information for the aforementioned purposes.

We may send you text messages on your registered mobile number that you share with us. All text messages originating from us, where applicable, through our authorized third-party service providers will at all times be compliant with guidelines prescribed by the Telecom Regulatory Authority of India (“TRAI”).

TO WHOM DO WE DISCLOSE YOUR INFORMATION?

We may disclose your Personal Information and Non-Personal Information, to the extent necessary:

• To statutory and regulatory authorities to comply with applicable laws and to respond to lawful requests and due legal process;
• To NASSCOM and/or GOI, as may be necessary for implementation of the FutureSkills Prime Program;
• To protect the rights, property and safety of NASSCOM, GOI, EdCast, our business and Services partners, Content partners and the users, including to enforce the Terms of Service;
• To third-party service partners, including business partners, service providers, authorized payment gateways, payment processors, etc. for the purpose of billing and collection, providingcontent, products, customer support etc. with respect to the FSP Program;
• To third parties to market their products/services/campaigns/programmes, subject to whether users have consented to these disclosures;

To fulfil the purpose for which the user provided such information. We will only disclose Personal Information pursuant to as described in this Privacy Policy or with the prior written consent of the user.

THIRD-PARTY WEBLINKS, APPS AND PLUGINS

Please note that the Platform may link you to third-party websites/apps/plugins (“Third-Party Sites”), that may collect your personal information, for which EdCast, NASSCOM and/or GOI are not in any manner responsible for the security of such Third-Party Sites or their privacy practices or content. Such Third-Party Sites may have their own privacy policies governing their storage and retention of your information that you may be subject to. This Privacy Policy does not govern any information provided to, stored on, or used by such Third-Party Sites or third-party providers and we recommend that you review the applicable privacy policy when you enter a Third-Party Site. You agree and acknowledge that EdCast, NASSCOM and/or GOI are not in any manner liable for the information published by any Third-Party Site.

We take care to allow your Personal Information and Non-Personal Information to be accessed only by those who really need it in order to perform their tasks and duties and to third parties who have a legitimate purpose for accessing it and with your consent. Your Personal Information and Non-Personal Information will be transferred only to such Third-Party Sites that ensure the same level of data protection that is mandated under the IT Act and the SDPI Rules, as the same may be amended/substituted from time to time.

• EdCast’s use of information received through a Linked Network, e.g. such as Google APIs will adhere to Google API Services User Data Policy including the Limited Use requirements, which can found at: https://developers.google.com/terms/api-services-user-data-policy.
• EdCast’s use of information received through a Linked Network such as LinkedIn APIs will adhere to LinkedIn Terms of Use, which can found at: https://legal.linkedin.com/api-terms-of-use.

HOW DO WE RETAIN YOUR INFORMATION?

We may store and retain your Personal Information and Non-Personal Information, to the extent necessary:

• To carry out the Services and provide Content for the user on the FSP Platform. Generally, this means, we will keep your Personal Information and Non-Personal Information as long as your account is active or as needed to provide our Services;
• Retain and use the information collected as necessary to comply with our legal obligations, resolve disputes or for other business purposes;
• Retain your Non-Personal Information after you cancel/ deactivate/ unsubscribe your account with us, as our business practice; and
• Where we have no continuing legitimate business need to process your Non-Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Non-Personal Information has been stored in backup archives), then we will securely store such data and isolate it from any further processing until deletion is possible.

HOW DO WE SECURE YOUR DATA?

We are dedicated to guarding the security of your information and the Platform has several industry-standard security technologies and procedures devised to help protect your data from unauthorized access, use, destruction or disclosure, including technical and organizational security measures to protect the security of your personal data both online and offline including the implementation of access controls, implementation of firewalls, security and penetration tests, secure servers, network intrusion detection and use of anti-virus and anti-malware software.

Please note that no system is completely secure and so while we strive to protect your Personal Information and Non-Personal Information, we cannot guarantee that unauthorized access, hacking, data loss or a data breach of our security measures will never occur. It is further clarified that you have and so long as you access and/or use the FSP Platform (directly or indirectly), continue to have the obligation to ensure that you, at all times, take adequate physical, managerial, and technical measures, at your end and on your behalf, to preserve the integrity and security of your information, including but not limited to, the Personal Information and Non-Personal Information provided by you.

You also expressly consent and agree to the sharing of your Personal Information and payment related information, to the extent necessary, with third-party service providers, including payment gateways and payment processors, to process and manage your payment related information. Such payment information, while transmitted through the Platform, shall be secured with industry-standard encryption technology offered by the third-party service providers. EdCast cannot guarantee that transmissions of your payment related information or Personal Information will always be secure or that unauthorized third parties will not be able to overcome the security measures taken by EdCast or the third-party service providers. EdCast thus assumes no responsibility or liability for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control.

HOW DO YOU UPDATE YOUR PERSONAL DATA?

You specifically consent and agree that the Personal Information pertaining to your account on the FSP Platform shall be both accurate and current. If you wish to update your Personal Information which is inaccurate or incorrect, we shall provide self-help tools for you to directly review or update certain aspects of your Personal Information in our records. As per the existing legal regulations, specific data fields (such as name, address etc.) in your Personal Information would be locked in our systems once you enter that information in the Platform. If any part of your Personal Information changes during the course of your engagement with us and your use of the Platform, please use these self-help tools provided by us to update that Personal Information or email us at support@futureskillsprime.in.

In addition to being able to update and correct your personal data, you will also have other data protection rights, including:

• The right to withdraw your consent at any time, wherein we have collected and processed your personal data with your consent pursuant to this Privacy Policy. However, you agree that withdrawing your consent will not affect the lawfulness of any processing we carried out before your withdrawal, nor will it affect processing of your Personal Information carried out in reliance on other lawful grounds other than consent. You also agree that in case you do not provide consent or later withdraw your consent, we request you to not access the FSP Platform, the Content and/or use the Services. In such a scenario, we also reserve the right to not provide you any Services through the FSP Platform and may delete your information or de-identify it so that it is anonymous and not attributable to you.
• The right to ask for a copy of your Personal Information in a portable (machine-readable) format.
• The right to deny us from using your Personal Information for direct marketing other campaigns/programmes.
• The right to make any of the above requests by contacting us at support@futureskillsprime.in. We will respond to all requests in accordance with applicable laws.

WILL WE AMEND THE PRIVACY POLICY?

We reserve the right, at our sole discretion, to revise, change or modify this Privacy Policy from time to time and such modifications shall be binding on you only upon your acceptance. Therefore, we urge you to review the Privacy Policy periodically to ensure that you agree with our latest information on our privacy practices. We will make best efforts to inform you of any amendments by e-mail or notification in your account on the FSP Platform. However, it is your responsibility to check the Privacy Policy regularly to ensure that you agree with it and your continued use of the FSP Platform will be deemed to be your acceptance of any changes that we make.

COPYRIGHT POLICY

The contents of this website and the FSP Platform may not be reproduced partially or fully, without due permission from EdCast, as per the Copyright Act, 1957. If referred to as a part of another publication, the source must be appropriately acknowledged. The contents of this website cannot be used in any misleading or objectionable context.

GOVERNING LAW & DISPUTE RESOLUTION

The FSP Platform, the Services and Content and the use thereof by you are governed by all applicable laws within the territory of India. Any Dispute that may arise in respect of your use (directly or indirectly) of the FSP Platform and/or in respect of this Privacy Policy shall be governed under the respective provisions provided in the Terms of Service, which can be found at:

PRIVACY QUESTIONS AND GRIEVANCE REDRESSAL

If you have any questions, concerns, or suggestions regarding our Privacy Policy, please reach out to us using the contact information on our “Contact Us” page or at support@futureskillsprime.in. We will respond to all requests in accordance with applicable laws. If you have any grievance or complaint with respect to the FSP Platform, please reach out to the grievance officer, the name and contact details provided below:

Name: Geetika Ahlawat E-mail: fspgrievance@nasscom.in