Grade5 Privacy Policy
Crowderia (Pvt) Ltd (hereinafter referred to as "CROWDERIA", "we", "us" or "our") is a platform provider. The Grade5 platform will be distributed as a website and mobile apps ("PLATFORM"). The platform is called Grade5, The PLATFORM helps young people to educate themselves by doing online tests and exams. CROWDERIA is the legal entity owning the legal rights for the Grade5 PLATFORM.
This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the PLATFORM or Services to you, and you should stop accessing the PLATFORM and deactivate your Grade5 account. You can find out more about how to deactivate your Grade5 account at www.grade5.lk
DEFINITIONS
Where the definition of a term does not appear in this Privacy Policy it shall be given its definition as outlined in our Terms of Service.
"Aggregated Information" means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.
"Data Controller" means Crowderia (Pvt) Ltd, the company responsible for the use and processing of Personal Information.
"Personal Information" means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
Within Grade5 we process personal data for those customers and users who use our services.
This is Grade5 Privacy Policy, which has been produced for the purpose of clarifying CROWDERIA`S position as regards privacy issues and the processing of personal data. We safeguard the privacy of our customers and users and comply with international legislation that aims to protect individuals. Our objective is to maintain a high level of protection for personal privacy.
This Privacy Policy applies to all services, including but not limited to websites, tablets and mobile applications, which are provided by Grade5. Certain services provided by Grade5 may be subject to special terms and conditions concerning the processing of personal data, of which you will be notified when you use the service in question.
WHAT TYPES OF INFORMATION DOES Grade5 GATHER ABOUT ITS USERS?
1. Information that you give us
We receive, store and process information that you make available to us when accessing or using our PLATFORM and Services. Examples include when you:
-fill in any form on the PLATFORM, such as when you register or update the details of your user account, or when you supply ID verification information;
-access or use the PLATFORM, pay for the service, book or pay for any associated services that may be available, post comments or reviews, or communicate with other users;
-link your account on a third party site (e.g. Facebook, Google) to your Grade5 account, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorized by you; and
-communicate with Grade5.
2. Mobile Data
When you use certain features of the PLATFORM, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g., IP address, post code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the PLATFORM or specific features of the PLATFORM). If you access the PLATFORM through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer's instructions for further details.
3. Log Data
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the PLATFORM, regardless of whether you are registered with Grade5 or logged in to your Grade5 account, such as your IP Address, the date and time you access or use the PLATFORM, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.
4. Cookies and other Tracking Technologies
Grade5 uses cookies and other similar technologies, such as mobile application identifiers, on the PLATFORM. We may also allow our business partners to use their cookies and other tracking technologies on the PLATFORM. As a result, when you access or use the PLATFORM, you will provide or make available certain information to us and to our business partners.
While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a "Do Not Track" signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Grade5 services on third party PLATFORM`S such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.
We may, either directly or through third party companies and individuals we engage to provide services to us, also continue to track your behavior on our own PLATFORM for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the PLATFORM and pay for your activities on the PLATFORM. We may also, either directly or through third party companies and individuals we engage to provide services to us, track your behavior on our own PLATFORM to market and advertise our services to you on the PLATFORM and third party websites. Third parties that use cookies and other tracking technologies to deliver targeted advertisements on our PLATFORM and/or third party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups. You may also be able to control advertising cookies provided by publishers, for example Google's Ad Preference Manager (https://www.google.com/settings/ads/onweb/). Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the PLATFORM – it just will not be tailored to your interests.
Third parties may not collect information about users' online activities on the PLATFORM except as described in this policy and our Cookie Policy.
5. Third-party social plugins
Our PLATFORM may use social plugins that are provided and operated by third-party companies, such as Facebook's Like Button.
As a result of this, you may send to the third-party company the information that you are viewing on a certain part of our PLATFORM. If you are not logged into your account with the third-party company, then the third party may not know your identity. If you are logged into your account with the third-party company, then the third party may be able to link information about your visit to our PLATFORM to your account with them. Similarly, your interactions with the social plugins may be recorded by the third party.
Please refer to the third party's privacy policy to find out more about its data practices, such as what data is collected about you and how the third party uses such data.
HOW Grade5 USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE
We use, store and process Information about you for the following general purposes:
-to enable you to access and use the PLATFORM;
-to operate, protect, improve and optimize the PLATFORM, Grade5'S business, and our users' experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and for advertising and marketing;
-to help create and maintain a trusted and safer environment on the PLATFORM and Services, such as fraud detection and prevention, conducting investigations and risk assessments, verifying the address of your listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases;
-to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
-where we have your consent, to send you marketing and promotional messages and other information that may be of interest to you, including information about Grade5 or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the "Account" section) when you login to your Grade5 account;
-to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by CROWDERIA or our business partners; and
-to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
HOW CROWDERIA USES AND PROCESSES USER COMMUNICATIONS
We may, either directly or through third party companies and individuals we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the PLATFORM for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the PLATFORM, you consent that CROWDERIA, in its sole discretion, may, either directly or through third party companies and individuals we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.
WHEN Grade5 DISCLOSES OR SHARES PERSONAL INFORMATION, AND TO WHOM
We may transfer, store, use and process your information, including any Personal Information, to countries outside of Sri Lanka. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
Your Personal Information may be disclosed as follows:
-Parts of your public profile page that contain some Personal Information may be displayed in other parts of the PLATFORM to other users for marketing purposes or to the extent necessary to operate and manage referral and rewards programs.
-The PLATFORM allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the PLATFORM. If you change your settings or the information on your public profile or public Listing pages, third-party search engines may not update their databases quickly or at all. We do not control the practices of third-party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.
-When you submit a request to purchase additional services, your full name and your phone number may become visible to the receiver.
-You may link your account on a third party social networking site to your Grade5 account. We refer to a person's contacts on these third party sites as "Friends".
When you create this linkage:
-some of the information you provide to us from the linking of your accounts may be published on your Grade5 account profile;
-your activities on the PLATFORM may be displayed to your Friends on the PLATFORM and/or that third party site;
-other Grade5 users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
-other CROWDERIA users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s); and
-the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes.
The publication and display of information that you provide to Grade5 through this linkage is subject to your settings and authorizations on the PLATFORM and the third party site.
We may distribute parts of the PLATFORM (including your Listing) for display on sites operated by Grade5's business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner's site, information from your public profile page may also be displayed.
We may allow our related entities such as our subsidiaries, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy.
We may also engage third party companies and individuals, who may be located outside of Sri Lanka, to provide services to us, including but not limited to technology services and services to help verify your identification, to conduct checks against databases such as public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, and to facilitate the payments or reimbursements you request. We may provide Personal Information about you to these third parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. We will ensure that such third parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.
You acknowledge, consent and agree that Grade5 may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (a) respond to claims asserted against Grade5; (b) to comply with legal process (for example, subpoenas and warrants); (c) to enforce and administer our agreements with users, such as the Terms of Service and this Privacy Policy); (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Grade5, its users or members of the public. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:
-providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
-based on information supplied by law enforcement, we, in our sole discretion, believe: (a) that providing notice could create a risk of injury or death to an individual or group of individuals, (b) that the case involves potential harm to minors, or (c) that harm or fraud could be directed to CROWDERIA, its Members, the PLATFORM, or Services.
We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
BUSINESS TRANSFERS BY CROWDERIA
If Grade5 undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.
HOW TO CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR CROWDERIA ACCOUNT
You may review, update, correct or delete the Personal Information in your Grade5 account. If you would like to correct your information or cancel your Grade5 account entirely, you can do so by logging into your account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the PLATFORM in association with your first name, even after your Grade5 account is cancelled.
SECURING YOUR PERSONAL INFORMATION
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.
YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
The PLATFORM will contain links to other websites not owned or controlled by CROWDERIA. Grade5 does not have any control over third party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.
Some portions of the PLATFORM may implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google's terms of use (located at www.google.com/intl/en_us/help/terms_maps.html) and Google's privacy policy (located athttp://www.google.com/privacy.html), as may be amended by Google from time to time.
SPECIAL FEATURES AND PROGRAMS
Referral service and requesting references
The PLATFORM may provide a referral service that allows you to invite your friends and contacts to use the PLATFORM. The PLATFORM may also allow you to ask your friends and contacts to write a reference for you, to be published on your Grade5 profile.
We may integrate the PLATFORM with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and Grade5 does not collect or retain the contact information that is used to send them.
You may also send invitation/request emails via the PLATFORM itself, in which case we will ask you for the contact information to which to send your invitation/request. You can type in the email addresses or other contact information manually, or you can choose to import the contacts in your address book(s). In both cases, we may use and store this information for the sole purposes of allowing you to send your friends and contacts an invitation or request for a reference, and for fraud detection and prevention. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins Grade5 in response to your referral.
If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.
Groups
The PLATFORM may allow registered account holders to participate in online discussion forums ("Group(s)") in selected cities.
If you join a Group, then your membership in the Group as well as some of your public information (such as your profile picture and public profile page) will be visible to users who browse the Group. If you publish postings in a Group, then your postings will be visible to such users as well. The ability to browse the Group will depend on the Group settings, and it may or may not be limited to members of that Group.
CHANGES TO THIS PRIVACY POLICY
We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the PLATFORM or by sending an email to you. We will also update the "Last Updated Date" at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.
It's important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the PLATFORM and Services to you, and your only option will be to stop accessing the PLATFORM and Services and deactivate your Grade5 account.
GOT FEEDBACK?
Your opinion matters to us! If you'd like to provide feedback to us about this Privacy Policy, please email us at info@grade5.lk.
COOKIE POLICY
CROWDERIA uses "cookies" in conjunction with the PLATFORM to obtain information. A cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. For example, a cookie could allow the PLATFORM to recognize your browser, while another could store your preferences and other information.
Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the PLATFORM may not work as intended or may not work at all without cookies.
Grade5 cookies and third party cookies
Grade5 may place our cookies on your device via the PLATFORM. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.
We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, third parties may also place cookies on your device for advertising purposes.
There are two types of cookies used on the PLATFORM, namely "persistent cookies" and "session cookies".
Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the PLATFORM.
Other technologies
The PLATFORM may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
Uses for Grade5 cookies
Grade5 uses cookies for a number of purposes, such as the following:
-to enable, facilitate and streamline the functioning of the PLATFORM across different web pages and browser sessions.
-to simplify your access to and use of the PLATFORM and make it more seamless.
-to monitor and analyze the performance, operation and effectiveness of the PLATFORM, so that we can improve and optimize it.
Uses for third party cookies
Our partners' cookies are intended to obtain information to help them provide services to Grade5. For example, third party companies and individuals we engage to provide services to us may track your behavior on our PLATFORM to market and advertise CROWDERIA listings or services to you on the PLATFORM and third party websites. Third parties that use cookies and other tracking technologies to deliver targeted advertisements on our PLATFORM and/or third party websites may offer you a way to prevent such targeted advertisements by opting-out. You may also be able to control advertising cookies provided by publishers, for example Google's Ad Preference Manager (https://www.google.com/settings/ads/onweb/). Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the PLATFORM – it just will not be tailored to your interests.
In addition, Facebook places a cookie via the PLATFORM that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the Grade5 mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.
Disabling Cookies
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser's toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the PLATFORM. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website (http://www.adobe.com/) and make changes at the Global Privacy Settings Panel (http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager02.html).
Changes to this Cookie Policy
We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the PLATFORM or by sending you an email.
It's important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the PLATFORM to you, and your only option is to stop accessing the PLATFORM and deactivate your CROWDERIA account. You can find out more about how to deactivate your Grade5 account at www.grade5.lk
Websites which are owned and controlled by Grade5 have a high level of security which aims to protect such personal data which is under CROWDERIA’s control. We take appropriate technical and organisational security measures to protect information against unauthorised access, modification, dissemination, and destruction.
CROWDERIAis responsible for the processing of personal data which takes place within CROWDERIA. CROWDERIA ensures that other companies in the Group receive clear guidelines concerning the processing of personal data and defines the purposes for which the Group will use personal data.
If you have any questions concerning this Privacy Policy or about CROWDERIAS’s processing of personal data, please contact CROWDERIA using the contact details below. You can also contact CROWDERIA’s Customer Services if the customer details which are registered about you are incorrect. You are then entitled to have the information rectified.
If you wish to receive information about CROWDERIAS’s processing of your personal data, you are also entitled, once per calendar year, to contact CROWDERIA and to receive one extract from the register, free of charge, which indicates, among other things, which data is being processed about you. The request for an extract from the register must be made in writing to CROWDERIA to the postal address below, and must be personally signed by the applicant and contain your name and personal identification number. The extracts are sent to the applicant’s population register address within one month of the date on which the application was received by CROWDERIA.
Crowderia (Pvt) Ltd
Data Protection Compliance Officer