The data controller for all data collected from you with regards to your use of the Services is Great Lakes E-Learning Services Private Limited, a private company registered in India, with the registered office at S-40, Second Floor, Vasant Square Mall, Vasant Kunj, New Delhi-110070. You can get in touch with our privacy team at firstname.lastname@example.org
1. Legal Basis for Processing Data
We process your data on the basis of the following:
- Your explicit consent for processing your data (as mentioned in Section 2 below), and for the purposes mentioned in Section 4 below;
- For the performance of contracts entered into by you for providing any of the Services; and
- Our legitimate interests, i.e. registering and administering accounts on our Services to provide you access to all content, updates and services you have purchased, and to facilitate the efficient running and operation of our business
2. What Data We Collect
We collect certain data from you directly, like the information you enter yourself, data about your participation in courses, and data from third-party platforms you connect with Great Learning. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.
2.1 Data You Provide to Us
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.
When you create an account and use the Services, including through a third-party platform, we collect the following data you provide directly:
|Account Data||In order to use certain features (like applying for a program), you need to create a user account. When you create or update your account, or provide your information via any other forms, we collect and store the data you provide, like your name, email address, password, city, age, guardian name and contact details (if required), program/courses you like to learn, IP address, work experience, industry where you work, phone number, and assign you a unique identifying number (“Account Data”).|
|Profile Data||You can also choose to provide profile information like a photo, social media profile, or other data. Your Profile Data will be publicly viewable by others.|
|Shared Content||Parts of the Services let you interact with other users or share content publicly, including by sharing your e-portfolio, sharing your testimonial, sending messages to program managers, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.|
|Program Data||When you enroll into a program, we collect certain data including which program, courses, assignments and quizzes you’ve started and completed; your exchanges with instructors, teaching assistants, and other students; and essays, answers to questions, and other items submitted to satisfy course requirements.|
|Student Payment Data||If you make payments, we collect certain data about your payment (such as your name and email id) as necessary to process your payment. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code. For security, Great Learning does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.|
|Data About Your Accounts on Other Services||
We may obtain certain information through your social media or other online accounts if they are connected to your Great Learning account. If you log in to Great Learning via LinkedIn or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, educational details, professional details, account ID number, login email address, physical address etc.
Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
The data listed above is stored by us and associated with your account.
2.2 Data We Collect through Automated Means
When you access the Services (including browsing courses), we collect certain data by automated means, including:
|System Data||Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain, and other systems data, and platform types (“System Data”).|
|Usage Data||Usage statistics about your interactions with the Services, including programs and courses accessed, time spent on pages or the Service, pages visited, features used, click data, date and time, and other data regarding your use of the Services (“Usage Data”).|
|Approximate Geographic Data||An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.|
The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.
3. How We Get Data About You
We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
3.1 Cookies and Data Collection Tools
Great Learning uses the following types of cookies:
- Preferences: cookies that remember data about your browser and preferred settings that affect the appearance and behavior of the Services (like your preferred language).
- Security: cookies used to enable you to log in and access the Services; protect against fraudulent logins; and help detect and prevent abuse or unauthorized use of your account.
- Functional: cookies that store functional settings (like the volume level you set for video playback).
- Session State: cookies that track your interactions with the Services to help us improve the Services and your browsing experience, remember your login details, and enable processing of your course purchases. These are strictly necessary for the Services to work properly, so if you disable them then certain functionalities will break or be unavailable.
Some of the third-party partners who provide certain features on our site may also use Local Storage Objects (also known as flash cookies or LSOs) to collect and store data.
We use the 3rd-party browser and mobile analytics services like Google Analytics, Hotjar, GetSiteControl, Mixpanel, Leadsquared, Wistia, YouTube and Drift on the Services. These services use Data Collection Tools to help us analyze your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data. We use this data to improve the Services, better understand how the Services perform on different devices and provide information that may be of interest to you.
3.3 Online Advertising
We use third-party advertising services like Facebook, Google’s ad services, and other ad networks and ad servers to deliver advertising about our Services on other websites and applications you use. The ads may be based on things we know about you, like your Usage Data and System Data (as detailed in Section 1), and things that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.
Depending on the types of advertising services we use, they may place cookies or other tracking technologies on your computer, phone, or other devices to collect data about your use of our Services, and may access those tracking technologies in order to serve these tailored advertisements to you. To help deliver tailored advertising, we may provide the service providers with your email address and content that you share publicly on the Services.
4. What We Use Your Data For, and How Long We Store it
4.1 How we use your data
We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity.
We use the data we collect through your use of the Services to:
- Provide and administer the Services, including to display customized content and facilitate communication with other users;
- Process your requests and orders for programs, courses, specific services, information, or features;
- Communicate with you about your account by:
- Responding to your questions and concerns;
- Sending you administrative messages and information, including messages from instructors and teaching assistants, notifications about changes to our Service, and updates to our agreements;
- Sending you information and in-app messages about your progress in courses, rewards programs, new services, new features, promotions, newsletters, and other available courses (which you can opt out of at any time);
- Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of the mobile app);
- Manage your account preferences;
- Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
- Solicit feedback from users;
- Market and administer surveys and promotions administered or sponsored by Great Learning;
- Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;
- Identify unique users across devices;
- Tailor advertisements across devices;
- Improve our Services and develop new products, services, and features;
- Analyze trends and traffic, track purchases, and track usage data;
- Advertise the Services on third-party websites and applications;
- As required or permitted by law; or
- As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.
4.2 Criterion For Determining Data Retention Period
It is not possible for us to determine a specific period for which we may retain your data. However, we will retain your data for longer than necessary, taking into account the following:
- The purpose(s) and use of your data, both now and in the future (such as whether it is necessary to continue to store that information in furtherance of our obligations under a contract with you, or to contact you in the future);
- Whether we have any legal obligation to continue processing your data (such as any record-keeping obligations imposed by any applicable law);
- Whether we have any further legal basis to continue processing your information (including your consent);
- Whether there is any relevant agreed industry practice on how long such data should be retained;
- The levels of risk and liability involved for us to continue holding the data;
- The amount of difficulty we may face to ensure the data can be kept updated and accurate; and
- Any other circumstances (such as the nature and status of Great Learning’s relationship with you).
5. Who We Share Your Data With
We share certain data about you with instructors, program managers, other students, companies performing services for us, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
- With Your Learning Consultants, Admissions and Great Learning Team: We share data that we have about you with your Learning Consultant and our Admission Team, so they can suggest the right program or course for you. This data may include things like your city, country, browser language, operating system, device settings, email id, phone number, your work experience and other work-related information, your activities on our website and learning management system.
- With Your Instructors, Evaluators, Moderators and Mentors: We share data that we have about you with instructors or teaching assistants for courses you enroll in or request information about, so they can improve their courses for you and other students. This data may include things like your city, country, browser language, operating system, device settings, email id, phone number, your work experience, and other work-related information, your activities on our website and learning management system.
- With Other Students and Instructors: Depending on your settings, your shared content, and profile data may be publicly viewable, including to other students and instructors. We may publish your name, percentage, percentile, marks and/or rank in the form of a leaderboard on your dashboard, accessible to you and your fellow batchmates, depending on your settings. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable by other users depending on your settings.
- With Students, public and other mentors: If you’re a mentor or Instructor, we share data that we have about you with students, program managers and employees of Great Learning, so they can reach out to you to clarify questions or provide services to you. This data may include things like your name, email id, phone number, professional and education details, your activities on our website and learning management system.
- With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, reward processing, data analysis, marketing, and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
- With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to Great Learning.
- With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like Clearbit or Pipl, we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 1), or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
- To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
- For Advertising: If we decide to offer advertising in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), and to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads.
For Security and Legal Compliance:We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Permitted or required by law;
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Great Learning, our users, employees, members of the public, or our Services.
- During a Change in Control: If Great Learning undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
- After Aggregation/De-identification: we can disclose or use aggregate or de-identified data for any purpose.
We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.
Great Learning takes appropriate security measures such as using HTTPS to transfer your data to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Great Learning, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately.
7. Your Rights
You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data such to to restrict our processing of your data, to erase all data we have stored about you, and the right to ask for the data to be provided to you/ported to any other service in a commonly used machine readable format.
Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.
7.1 Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services
- To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
- The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared.
- To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Union, visit the Your Online Choices site. To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page.
- To opt out of allowing Google Analytics, Hotjar, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Hotjar Opt-Out Cookie,Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Pipl Removal from Search results.
If you have any questions about your data, our use of it, or your rights, contact us at email@example.com .
7.2 Accessing, Updating and Correcting, Porting and Deleting Your Personal Data
You can access and update your personal data that Great Learning collects and maintains as follows:
- To update data you provide directly, log into your account and update your account at any time.
- To terminate your account:
- If you are a student, instructor or a mentor, write to firstname.lastname@example.org to delete your account permanently.
- To request to access, correct, port, or delete your personal data, or to restrict processing of your personal data, please email email@example.com. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we post deletion, we may retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.
7.3 Revocation of Consent
We recognise that the processing of your data may be based on your consent. In case you wish to withdraw such consent given to us for the processing of your data as identified in Section 3 above, please e-mail us at firstname.lastname@example.org. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and may need to verify your identity before implementing your request.
Further, please note that such revocation of consent shall be prospective in nature, and shall not affect the lawfulness of any data processed based on your consent given prior to revocation.
While we take all measures to protect and secure your data, we understand that you may have grievances about our use of your data, or of our data protection measures. Please feel free to reach out to us at email@example.com with any such complaints.
In case you are not satisfied with our response, you can also reach out to the national data protection authorities in your region (provided you are in the EU). The list of national data protection authorities for EU member states may be accessed here.
Please note that while we urge you to write to us for any grievances or with any complaints you may have, this does not preclude you from directly approaching the national data protection authorities mentioned above.
7.5 Our Policy Concerning Children
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Our Services are not intended for children under 13 (or under 16 in the European Economic Area), and the children under these ages may not use the Services. If we learn that we’ve collected personal data from a child under those ages without verified parental consent, we will take reasonable steps to delete it. Parents or guardians who believe that Great Learning may have collected personal data from a child under those ages can submit a request that it be removed to firstname.lastname@example.org
All users who are minors in the jurisdiction in which they reside (generally under the age of 18) may not set up an account and have a parent or a guardian open an account for them, and must have the permission of, and be directly supervised by, their parent or guardian to use the Services.
8. Jurisdiction-Specific Rules
If you live in California, you have certain rights to request information. Users outside of the United States should note that we transfer data to India and other areas outside of the European Economic Area.
8.1 Users in California
If you are a California resident, you have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to email@example.com.
Since the internet industry is still working on Do Not Track standards, solutions, and implementations, we do not currently recognize or respond to browser-initiated Do Not Track signals.
8.2 Users Outside of the U.S.
Great Lakes E-Learning Services Private Limited. is headquartered in India, and in order to provide the Services to you, we must transfer your data to India and process it there. By visiting or using our Services, you consent to the storage of your data on servers located in India. If you are using the Services from outside India, you consent to the transfer, storage, and processing of your data in and to India or other countries. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.
That data is also processed outside of Switzerland and the EEA by Great Lakes E-Learning Services Private Limited, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf, with appropriate safeguards to ensure security of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Great Learning and its processors.
9. Updates & Contact Info
When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email with any questions, concerns, or disputes.
What are cookies?
Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your activities across websites, including on Great Learning. Cookies also allow us to remember things about your visits to Great Learning, like your account ID, and to make the site easier to use.
We use both session cookies, which expire after a short time or when you close your browser, and persistent cookies, which remain stored in your browser for a set period of time. We use session cookies to identify you during a single browsing session, like when you log into Great Learning. We use persistent cookies where we need to identify you over a longer period, like when you request that we keep you signed in.
|Authentication and security||
For example, cookies help authenticate your access to Great Learning and prevent unauthorized parties from accessing your accounts
For example, cookies help us remember the program you’re interested in, so we can provide communication relevant to this program each time you visit.
|Analytics and research||
For example, cookies help us test different versions of Great Learning to see which features or content users prefer, web beacons help us determine which email messages are opened, and cookies help us see how you interact with Great Learning, like the links you click on.
For example, cookies help us show a personalized list of recommended programs on the homepage.
To learn more about targeting and advertising cookies and how you can opt out, visit www.allaboutcookies.org/manage-cookies/index.html, or if you’re located in the European Union, visit the Your Online Choices site.
Please note that where advertising technology is integrated into the Services, you may still receive advertising on other websites and applications, but it will not be tailored to your interests.
When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide its own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.
What are my privacy options?
- Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by consulting your browser’s support articles. If you decide to decline cookies, please note that you may not be able to sign in, customize, or use some interactive features in the Services.
- Flash cookies operate differently than browser cookies, so your browser’s cookie-management tools may not remove them. To learn more about how to manage Flash cookies, see Adobe’s article on managing flash cookies and Website Storage Settings panel.
- To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Union, visit the Your Online Choices site. To opt out of Google Analytics’ display advertising or customize Google Display Network ads, visit the Google Ads Settings page.
- For general information about targeting cookies and how to disable them, visit www.allaboutcookies.org.
Updates & Contact Info