Privacy Policy

BET PRIVACY POLICY

1. Who is Burlington English Training (India) Ltd. Pvt.? (BET)
BET sells, markets and services Burlington English educational solutions, to the Indian institutional and corporate market.
2. What is this Privacy Policy?
This privacy policy (the “Privacy Policy”), together with the terms of use, describes BET’s policies and procedures on the collection, use and disclosure of the information provided by Users and Visitors (as defined herein below) of the Website. BET shall not use the User’s information in any manner except as provided under this Privacy Policy. Every User who accesses or uses the Website shall be bound by this Privacy Policy.
3. Why this Privacy Policy?
3.1. This Privacy Policy is published pursuant to:
3.1.1. Section 43A of the Information Technology Act, 2000;
3.1.2. Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPI Rules”); and
3.1.3. Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
3.2. This Privacy Policy sets out the type of information collected from the Users, including the nature of the sensitive personal data or information, the purpose, means and modes of usage of such information and how and to whom BET shall disclose such information.
4. What is Sensitive Personal Data or Information?
4.1. In accordance with the SPI Rules, any sensitive personal data or information of a person means and includes such personal information about that person relating to:
4.1.1. Passwords;
4.1.2. Financial information such as bank accounts, credit and debit card details or other payment instrument details;
4.1.3. Physical, physiological and mental health condition;
4.1.4. Sexual orientation;
4.1.5. Medical records and history;
4.1.6. Biometric information; and
4.1.7. Information received by body corporates under lawful contract or otherwise.
4.2. It may be noted that any information that is freely available in the public domain or accessible under the Right to Information Act, 2005, or any other law will not be regarded as sensitive personal data or information.
5. Users Note
5.1. A condition of each User’s use of and access to the Website and to other services provided by BET to Users (collectively referred to as the “Services”), is his/her/its acceptance of the terms of use (“Terms of Use”), which also involves acceptance of the terms of this Privacy Policy. Any User who does not agree with any provisions of the Terms of Use or this Privacy Policy is advised not to accept the Terms of Use and may leave the Website.
5.2. While browsing the Website, a User is not required to provide personal information as set out under paragraph ‎4.1 (“Personal Information”) until and unless such User chooses to avail or sign up for any of the Services. All the information provided to BET by a User, including Personal Information, is voluntary. The User has the right to request the withdrawal of his/her/its consent at any time, in accordance with the terms of this Privacy Policy and the Terms of Use. It is the User’s duty to ensure strict caution while giving out any personally identifiable information about himself/herself/itself or his/her family members in use of any of the Services. As a condition to use the Services, you as a User agree to waive any claims against BET relating to the same, and to the extent such waiver may be ineffective, you agree to release any claims against BET relating to the same.
5.3. Users can access, modify, correct and eliminate the data about him/her/it which has been collected pursuant to his/her/its decision to become a User. Any grievances in relation to the information shared by the User with BET may be brought to the attention of BET at bet.india@burlingtonenglish.com.
5.4. Personal Information shall be collected by BET for one or more of the following reasons:
5.4.1. To identify the User, to understand his/her/its needs and resolve disputes, if any;
5.4.2. To provide ongoing service;
5.4.3. To meet legal and regulatory requirements;
5.4.4. To resolve technical issues and troubleshoot problems;
5.4.5. To keep Users apprised of BET’s promotions and offers;
5.4.6. To customize User experience;
5.4.7. To detect and protect BET from error, fraud and other criminal activities;
5.4.8. To enforce the Terms of Use; and
5.4.9. Other reasons which, prior to being put into effect, shall be communicated to the Users through an update carried out to this Privacy Policy.
5.5. Due to the communications standards on the Internet, when a User visits the Website, BET automatically receives the uniform resource locator of the site from which such User visits the Website, details of the website such User is visiting on leaving the Website, the internet protocol (“IP”) address of each User’s computer operating system, type of web browser the User is using, email patterns, and the name of the User’s internet service provider. This information is used solely to analyze overall User trends and to help BET in improving its Services. Please note that the link between the User’s IP address and the User’s personally identifiable information is not shared with third parties without such User’s permission or except when required by law or to provide or facilitate the User with the Services. Notwithstanding the above, the User acknowledges BET’s right to share some of the aggregate findings, including the Personal Information provided by the Users in an unidentifiable form, and not the specific data with advertisers, sponsors, investors, strategic partners, and others in order to help grow the business.
5.6. The Website uses temporary cookies to store certain data. BET does not store personally identifiable information in the cookies. Information collected by BET, by any means whatsoever, that does not personally identify the User as an individual (such as patterns of utilization described above) is exclusively owned by BET and may be used by BET and third party service providers for technical administration of the Website, user administration, research, development, and other purposes. Additionally, BET may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to its parent company, group companies, subsidiaries, associates, affiliates, suppliers, vendors, sister concerns and other third parties (collectively referred to as “Other Parties”).
5.7. A User may set or amend his/her/its web browsers to delete or disable cookies. If a User chooses to disable cookies on his/her/its computer or mobile telecommunication device, it may impair, degrade or restrict access to certain areas of the Website. Merely closing the web browser should ordinarily clear all temporary cookies installed by BET. However, Users are encouraged to use the “clear cookies” functionality of their browsers to ensure deletion, as BET cannot guarantee, predict or provide for the behavior of the equipment of all the Users of the Website.
5.8. BET may allow other companies or entities to serve advertisements to Users. These companies or entities include third party advertisement servers, advertisement agencies, advertisement technology vendors and research firms. BET may target some advertisements to Users that fit a certain general profile. BET does not use personally identifiable information to target advertisements to specific Users. In the course of serving advertisements or optimising the Services to its Users, BET may allow authorised third parties to place or recognise a unique cookie on the User’s browser.
5.9. BET does not exercise control over the websites displayed as search results or links from within the Services. These other sites may place their own cookies or other files on the Users’ computer, collect data or solicit Personal Information or Financial Information from the Users, for which BET shall not be held responsible or liable. BET does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does BET guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by BET of such websites, the websites’ provider, or the information on the website.
5.10. When a User visits or uses the Website, BET may access, collect, monitor and/or remotely store data in relation to the User’s location, which may also include global positioning system coordinates or similar information regarding the location of the device using which the User has visited or used the Website. The location data does not collect or share any personally identifiable information about the User.
5.11. BET may keep records of telephone calls received from and made to Users for the purpose of administration of Services, research and development, training, business intelligence, business development, or for User administration. BET may share the telephone records with third parties when required by law or when required to provide or facilitate the User with the Services.
5.12. BET may choose to conduct contests and surveys to collect relevant information about the Users’ preferences. These surveys and contests are optional and if the User chooses to respond, his/her/its responses will be kept anonymous. The demographic information that the User provides while availing or signing-up for the Services and through any surveys or contests is used to help BET improve its services to meet the needs and preferences of Users.
5.13. BET does not knowingly collect personal data from children not accompanied by their parent or guardian. In an event, a person below the age of 18 uses the Services, BET shall not be held liable or responsible for any damage or injury suffered by such person in logging into the Website and making use of the Services without being accompanied by their parent or guardian.
5.14. BET has implemented security policies, rules and technical measures, as required under applicable law including firewalls, transport layer security and other physical and electronic security measures to protect the Personal Information that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. It is expressly stated that BET shall not be responsible for any breach of security or for any action of any third parties that receive Users’ personal data or events that are beyond the reasonable control of BET including, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.
5.15. BET may be required to disclose Personal Information to governmental institutions or authorities when such disclosure is requisitioned under any law or judicial decree or when BET, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the Terms of Use.
5.16. BET may share/use Personal Information provided by Users with the Other Parties for the purposes of:
5.16.1. enabling Users to enjoy the Services; or
5.16.2. detecting and preventing identity theft, fraud or any other potentially illegal acts; or
5.16.3. monitoring User interest.
To the extent that Other Parties have access to the Personal Information, BET shall make efforts to ensure that the Other Parties treat such Personal Information at least as protectively as they treat personally identifiable information obtained from their users or members.
5.17. BET or the Other Parties may merge with or be acquired by another business entity. In such an event, BET and the Other Parties may be required to transfer the Personal Information to such merging or acquiring party, as the case may be. While sharing such Personal Information with the acquiring or merging entity, as the case may be, BET and the Other Parties shall make reasonable endeavours to ensure that the User’s Personal Information is duly protected by the acquiring or merging entity, as the case may be, by undertaking security measures prescribed under applicable laws.
5.18. BET may also disclose or transfer the personal and other information provided by Users, to any third party as a part of reorganization or a sale of the assets, division or transfer of a part or whole of the company. Any third party to which BET transfers or sells its assets will have the right to continue to use the personal and other information that Users provide to BET.
5.19. All BET employees and data processors, who have access to and are associated with the processing of Personal Information provided by Users are obliged to respect the confidentiality of every User’s Personal Information.
5.20. The User’s visit to the Website and any dispute over privacy is subject to this Privacy Policy and the Terms of Use. BET may update this Privacy Policy at any time, with or without advance notice. BET shall not be required to notify the Users of any changes made to this Privacy Policy. It is your responsibility, in such cases, to review the terms of this Privacy Policy from time to time.
5.21. All information collected from the Users by BET is maintained in electronic form on servers and/or cloud systems and shall be accessible by certain employees of BET. The User information may also be converted to physical from time to time. Regardless of the manner of storage, BET shall make commercially reasonable endeavors to ensure that the User information is rendered confidential, and will disclose User information only in accordance with the terms of this Privacy Policy.
6. Visitors Note
6.1. No Personal Information is automatically collected from any visitors of the Website who are merely perusing or browsing the Website (“Visitor”). Nevertheless, certain provisions of this Privacy Policy are applicable to Visitors, and Visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave the Website immediately.
6.2. A User will not merely be a Visitor if the User has willingly submitted any Personal Information (including phone numbers, email addresses, responses to surveys, etc.) to BET through any means, including email, telephone calls, telephonic messaging or while availing or signing-up for the Services. All such Visitors will be deemed to be, and will be treated as, Users for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy shall apply to the User.
6.3. If you, as a Visitor, have inadvertently browsed any other pages of the Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is obtained, stored or used, merely quitting the Website should ordinarily clear all temporary cookies installed by BET. All Visitors, however, are encouraged to use the “clear cookies” functionality on their browsers to ensure such clearing or deletion, as BET cannot guarantee, predict or provide for the behavior of the equipment of all the Visitors of the Website.
6.4. If you are accessing the Website from outside India, it is solely your responsibility to ensure that your access does not breach or violate any local or national law applicable in the place from where you are making the access, for the time being in force.
7. Opt-Out Policy
7.1. The third party service providers with whom BET may share Personal Information or Financial Information provided by Users are not permitted to market their own services or send promotional e-mails or engage in promotional communication with the Users. BET provides all Users with the opportunity to opt-out of receiving non-essential, promotional, or marketing-related communication from itself or its partners. These settings can be found on the Website.
7.2. If a User wishes to remove his/her/its contact information from all BET’s lists and newsletters, the User can click on the “unsubscribe” link or follow the instructions in each e-mail message. Alternatively, the User can contact BET at nanda.k@burlingtonenglish.com. BET reserves the right to limit membership based on availability of contact information. All Users will be notified by email prior to any actions taken.

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