This Privacy Policy (the "Privacy Policy") is a binding agreement between you and Winford School of English and its affiliates and subsidiaries ("Winford", “Winford School of English”, "we" or "us" or "our"). Winford School of English is a web and mobile based platform which offers curated and specially designed and scripted courses aimed at strengthening foundational skills and building competencies geared towards achieving professional success through its website, https://winfordschoolofenglish.com/ (or any successor site) and its related sub-domains, sites, mobile applications and tools accessed through a mobile device, mobile application, computer or any other device ("Website"). The words "you" or "your" or "User" as used herein, refer to all individuals and/or entities browsing, accessing or using the Website or services for any reason.
By using, accessing, browsing our Website and/or using our services you agree that you have read the Privacy Policy and understood the purpose for which your Personal Information is being collected, stored and processed and how the same shall be used. You hereby provide us with your express consent to such purpose and use. By signing up you further represent that you are 18 years of age or older than the age prescribed in your country of residence for a child.
1. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE OR ACCESS THE WEBSITE AND/OR OUR SERVICES.
This Privacy Policy describes the information including Personal Information, that we collect from you and what may happen to that information. This Privacy Policy DOES NOT apply to information that you provide to, or that is collected by, any third-party, such as social networks that you use which are not in connection with our services.
This Privacy Policy is incorporated into and subject to the provisions of the Terms of Use and the terms not defined here, have the meanings ascribed to them in the Terms of Use. This Privacy Policy and Terms of Use are effective upon your accessing or using the Website and/or use of our services. We encourage you to read the terms of the Privacy Policy and the Terms of Use in their entirety before you use the Website or our services.
For the purposes of this Policy, "Personal Information" shall mean any personally identifiable information relating to an identified or identifiable individual, including data that identifies an individual or that could be used to identify, locate, track, or contact an individual. Personal Information includes both directly identifiable information, and indirectly identifiable information such as date of birth, unique mobile or wearable device identifier, information that could be used to identify a household, telephone number, key-coded data or online identifiers, such as IP addresses, and includes any data that constitutes "personal data" under the Data Protection Law (as defined hereinafter). It shall also include information including, but not limited to:
All the Personal Information as mentioned above is collected, stored, and processed as per the Indian Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 or any other applicable data protection, data security or privacy law ("Data Protection Law"). Personal Information of the Users residing outside India is collected stored and processed as per the data protection laws in their respective jurisdictions such as EU General Data Protection Regulation 2016/679 (the "GDPR") to the extent possible in consonance with the Indian Data Protection Laws as mentioned above.
2. Information Collection
2.1 Information You Provide Us
Personal Information as defined above is collected by us when you browse or use our Website and when you register as a user to subscribe to our services. We collect, process and store your Personal Information, to provide a safe, efficient and customized experience to our Users accessing the Website. You can browse through the Website without giving any Personal Information about yourself or by creating an account to avail of our services on the Website. These services shall include but not be limited to providing the Users with online courses, participate in public forums, sign-up for email, calls and SMS, WhatsApp updates, purchase our services. To register and create an account ("Account"), you may be required to provide us with your contact and identity information and other Personal Information as indicated on the Website and complete the registration process. Where possible, we indicate which fields are mandatorily required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature on the Website, unless we require it so. Your Account Personal Information is protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your mobile phone and browser by signing off after you have finished accessing your Account. We advise you to not share login credentials/Account information with anyone to avoid unauthorized access.
2.2 Information Automatically Collected/ Acquired Information
Location Information and IP Address:
When you access the Website, your IP ("Internet Protocol") address is recorded by us. This method ensures smooth operations and protection against attacks and requires the user's IP address to be saved for the duration of the session. We may be able to determine from an IP address a User's Internet Service Provider and the geographic location of his or her point of connectivity.
Device Information:
We collect information about the apps, browsers, and devices you use to access our Website, which helps us provide features like automatic service updates. The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number.
Behavioural Information:
We may automatically track, collect and aggregate certain information about you based upon your behaviour on our Website or while accessing our services. We may use such information to do internal research on our Users' demographics, interests, and behaviour to better understand, protect and serve our Users. This information is compiled and analysed on an aggregated basis.
Cookies: The Website may use cookies and tracking technology depending on the features offered. We urge you to consult our cookie policy, available on our Website, to understand the cookies processed by us. Usage of a cookie is in no way linked to any personally identifiable information on our Website. Some of our business partners may use cookies on our Website. However, we have no access to or control over these cookies. Aggregate cookie and tracking information may be shared with third parties. By accepting this Privacy Policy as well as the cookie policy, you confirm your consent to Winford School of English's use of cookies and other such technologies. If you do not wish to accept cookies from our Website, you may configure your web browser so that it does not accept cookies; however, you may lose certain functions available on our Website.
You agree, if you send us personal correspondence, such as emails, calls, SMSs (including WhatsApp messages) or letters, or if other users or third parties send us correspondence about your activities or postings on the Website, we may collect and/or store such information.
2.3 Third-Party Tools
We may use certain third-party web analytics services on the Website such as Google Analytics or tools offered by Facebook and/or LinkedIn. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us for various functions such as analyse how visitors use the Website, tracking user behaviour for marketing purposes, for provision of embedded services etc. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the Website. These analytic services may use the data collected to contextualize and personalize the marketing materials of their own advertising network. Please note that third parties (including, for example, advertising networks and providers of external services) may also use cookies, over which we have no control.
3. Use of your Personal Information
3.1 Provide, Customize, Maintain and Improve our Services
We are the sole owners of your Personal Information collected on this Website. We only have access to and/or collect Personal Information that you give us or that is collected while accessing our Website, using our services or via e-mail or other direct contact from you. We will not sell or rent this information to anyone. We will use your Personal Information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside our organization, unless otherwise specified in this Privacy Policy and/or other than as necessary to fulfil your request.
We may use your Personal Information and other information we obtain from your current and past activities on the Website to: resolve disputes; troubleshoot problems; measure your interest in the services provided by us, inform you about our products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce the Terms of Use; provide technical support; and as otherwise described to you at the time of collection. At times, we may look across multiple Users to identify problems or resolve disputes, and in particular we may examine your Personal Information to identify Users using multiple User IDs or aliases. We may compare and review your Personal Information for errors, omissions and for accuracy. Unless you ask us not to, we may contact you via e-mail, calls, SMSs, WhatsApp Messages etc in the future to tell you about specials, new products or services, or changes to this Privacy Policy.
3.2 Participation in Online Courses, Public Forums and Signing-Up for Updates
We use the Personal Information as provided by you for processing purposes, including but not limited to that of following attendance, progress, and completion of your online course. We may also share details regarding your performance in a given online course with the instructor/instructors or other designated individuals who assisted you in such course. This will help us modify, alter and operate the online course conveniently. We may also collect student generated content in the form of various assignments, peer-grading feedback, responses related to the course data in the form of exams, surveys etc. We may collect or/and store such information as provided by you.
Winford School of English may offer public forums. We may require your Personal information if you wish to participate and share your thoughts on these forums. Please keep in mind that such posts as shared by you will be available on our Website and/or any related application, platform. We may collect and/or store such information as provided by you on these forums. We may also provide you with updates by either posting such updates on the Website or through letters, emails, calls, SMS, WhatsApp etc.
3.3 Communicate with You
We may use your Personal Information to contact you, send mailers and deliver information to you that, in some cases, are targeted to your interests, such as targeted administrative notices, services offerings, and communications relevant to your use of the Website. We may let you know about upcoming changes or improvements to our services. By accepting the Terms of Use and Privacy Policy, you expressly agree to receive this information. If you do not wish to receive these communications, we encourage you to opt out of the receipt of certain communications in your profile. You may make changes to your profile at any time.
3.4 Personal Information to be Transferred
You agree that this Personal Information may be transferred within that country, wherever our servers are located, depending on the type of information and how it is stored by us. Our collection, storage and use of your Personal Information will at all times continue to be governed by this Privacy Policy.
3.5 Sharing Information other than Personal Information
We shall share information such as forum discussions and survey related demographic data with our trusted partners for the purpose of conducting research on online education. Such research findings shall be typically reported at the aggregate level. We shall ensure that none of your Personal Information is imparted with during such research findings without your explicit consent.
4. Disclosure of your Personal Information
4.1 We do not rent, sell, or share your Personal Information with other people (save with your consent) or non-affiliated companies except to provide our products or services, or under the following circumstances:
All your activity on our Website from the time you logon until you logoff is encrypted with a SSL certificate to ensure it remains private. We neither capture nor store your credit/debit card information.
4.2 Further, you agree that we may share your Personal Information for the following activities:
Advertisements:
When you access the Website, or enter Personal Information on the Website, such Personal Information is used by us in accordance with the terms of this Privacy Policy. We may also aggregate (gather up data across all Accounts) information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for other marketing and promotional purposes. We don’t share Personal Information that personally identifies you with advertisers, such as your name or contact information, unless you ask us to.
Services Offered on the Website by Third Parties:
The Website may provide links to third-party sites. Please note that when you click on one of these links, you are entering another application/website over which Winford School of English has no control and will bear no responsibility. The information provided by you for such purposes is simultaneously collected by the Website and the respective third party. Such information provided by you is only processed for the purposes of the legitimate interests pursued by the third party. This information is utilized by the third party in accordance with its privacy policy and the terms of the offer. Because we do not control the privacy practices of these third parties, you should evaluate their practices before deciding to use their services. You agree that we shall not be liable for any breach of your privacy of Personal Information or loss incurred by your use of these applications/websites.
Posting to Public Forums:
Please remember that if you post any of your Personal Information in public forums of the Website, such information may be collected and used by others over whom we have no control. You are to please note that these posts may be made available in the public domain.
5. Access or Change your Personal Information
5.1 You may review, correct, update or change your Account information at any time. To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Information.
5.2 We may retain Personal Information for as long as it is necessary. It may be archived as long as we believe that the purpose for which it was used still exists or as necessary for our legitimate business interests or for complying with legal obligations or for a period as mentioned in the applicable Data Protection Laws.
5.3 There will be some residual information that shall remain with us within our logs, database and other records. Such residual information may or may not include Personal Information. Please also note that we shall retain your Personal Information if we require the same for complying with a legal obligation.
6. Data Protection
We endeavour to safeguard the User's Personal Information to ensure that the same is kept private. We shall not share any Personal Information with any third parties except as otherwise provided in this Privacy Policy. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of User's Personal Information at any time. Winford School of English will adopt physical, technical, and organizational measures to ensure the security of the User's Personal Information. This includes the prevention of loss or damage, unauthorized alteration, access or processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment.
7. Changes to this Privacy Policy
We reserve the right to update, change or modify this Privacy Policy at any time. The amendment to this Privacy Policy shall come to effect from the time of such update, change or modification. We, therefore, encourage you to check and read this Privacy Policy from time to time to familiarize yourself with such updates.
8. Contact Us
In the event you have any complaints about the Website, its contents or anything related thereto or if you wish to make a complaint regarding any violation of the provisions of the Privacy Policy, you may send a written complaint to the Grievance Officer, who shall redress the complaint within one (1) month from the date of receipt of the complaint. Our contact details are as follows.
Grievance Officer: Ms. Srijita Chatterjee
Email Id: support@winfordschoolofenglish
Address: 1 Sarat Bose Road, Gitanjali Apartment, Kolkata 700065.