Privacy Policy

1.  Introduction

Company (together with its subsidiaries, and international affiliates, hereinafter “Company “, “us,” “we,” or “our” or “the Company”) is committed to security and management of personal data, to function effectively and successfully for the benefit of our stakeholders, customers and for the community. In doing so, it is essential that people’s privacy is protected through the lawful and appropriate means for handling the personal data. Therefore, we have implemented this privacy policy (hereinafter referred to as ‘‘policy’’).

 

2.  Aim

This policy aims to protect personal data of the various stakeholders connected to our organization. This policy is aimed at providing individuals notice of the basic principles by which the company processes the personal data of individuals (“Personal Data”) who visits, uses, deals with and/or transacts through the website and includes a guest user and browser (hereinafter ‘you’, ‘user’).

 

3.  Purpose and Scope

The purpose of this policy is to describe how Company collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to website (hereinafter the “website”). This policy is also designed to provide information on how Company ensures data security, conducts data transfers and process requests from data subjects.

This policy control applies to all systems, people and processes that constitute the organization’s information systems, including board members, directors, employees and other third parties who have access to Personal Data available within Company.

The company is also committed to ensure that its employees conduct themselves in line with this, and other related, policies. Where third parties process data on behalf of Company, the Company endeavours to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.

 

4.  Types of Personal Data collected

The Personal Data that we collect about you depends on the context of your interactions with us, the products, services and features that you use, your location, and the applicable laws.

Personal Data is stored in personnel files or within the electronic records (on servers in India or other countries) of Company. The following types of Personal Data may be held by the Company, as appropriate, on relevant individuals:

  1. Personal Identification Data
    • First Name, Last name
    • Job title & Company
    • Signature
    • Photographs
  2. Identification Data
    • Social security or tax identification numbers
    • Aadhar number and PAN
  3. Financial Data
    • Bank Account information
    • Salary Information
    • Payment gateway account details
    • E-wallet account details
  4. Personal Characteristics
    • Age
    • Gender
    • Date of Birth
    • Marital Status
    • Nationality
  5. Contact Data
    • Postal address
    • Email address
    • Phone number
  6. Education and Recruitment Data
    • Educational qualification(s)
    • Working goals
    • Post-qualification experience
  7. Electronic Identification Data
    • Login credentials (If you are a registered user)
    • Visitors IP Data
    • Date and time of website visit
    • Pages visited and navigation on the website
    • Browser being used
    • County of accessing website
    • Language of the browser being used
    • Words searched for
    • Pixel tags
  8. Inquiries
    • Personal Data stated in the form – for example: Name, address, phone number, country
    • Subject of Inquiry
    • Personal details (Name on the card, billing address)
    • Payment details (card numbers, card type)
    • Recordings of calls with students and users showing interest in our
    • Information about your interactions with customer service and maintenance interactions with us.
  9. User Generated Data
    • Projects and Assignments submitted
    • Peer feedback and grading
    • Program performance data
    • Response to quizzes, standalone quizzes, exams, and surveys
    • Web Cam Recordings (during assessments related to online courses)
    • Posts made to public forums through our platform
    • Any other information necessary to ensure conformity with test/ assessment rules, area of interests
  10. Marketing Data
    • Your preferences in receiving marketing information from us
    • Your communication preferences
  11. Behavioural Data
    • Data inferred or assumed information relating to your behaviour and interests based on your online activity on our sites

We do not collect any payments information processed by third-party payment gateway providers.

 

5.  Special Categories of Personal Data

Special Category of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade unions memberships, information about your health and genetic and biometric data.

We do not collect or process any special or sensitive Personal Data.

Should we specifically require “special” or “sensitive” Personal Data in connection with one or more of the uses described below, we will request your explicit consent to use the data in accordance with this policy and/or in the ways described at the point where you were asked to disclose the data.

Other legal basis for our processing of special category data may include, as permitted by applicable law, for scientific research, for employment, social security or social protection law, for reasons of substantial public interest, or as necessary for the establishment, exercise or defense of legal claims. If you voluntarily share with us or post/upload any “special” or “sensitive” Personal Data to this website for any other reason, you consent that we may use such data in accordance with applicable law and this policy. You can contact our DPO for more information about our processing of your Personal Data.

 

6.  Sources of Data Collection

The data collected by the company comes directly from users or through their interaction with our sites.

Data Collected When You:

  1. Register for seminars, webinars, or other outreach initiatives provided by us or our
  2. Request a quote for our products and
  3. Provide feedback, complete customer surveys, or interact with our customer service
  4. View our services or visit our website
  5. Browse our
  6. Appear for assignments, exams, or assessments related to online
  7. Avail refunds, or

Data Collected from Third Parties: We may receive personal data such as access details, login credentials, or profile pictures from third-party sources. This can include information about your visits using pixel tags. Sources may include service providers, other connected networks, advertising partners, marketing affiliates, scholarship providers, analytics providers, and recruiters.

 

7.  Cookies

What Are Cookies? Cookies are text files placed on your computer to gather standard internet log information and visitor behavior data. We may use cookies or similar technologies when you visit our websites.

Third-Party Advertising Cookies: We allow third-party companies like Facebook, Google, Twitter, Quora, and Bing to place cookies on our website. These cookies enable these companies to track your activities across various websites and deliver ads that they consider relevant to you.

How Do We Use Cookies? Company uses cookies to:

  1. Recognize website users and enhance their
  2. Analyze the use and performance of our website and
  3. Improve the delivery and value of our products and

Types of Cookies We Use:

  1. Persistent Cookies: Used to improve your experience, such as by remembering your acceptance of our Cookie Policy.
  2. Session Cookies: Temporary cookies deleted when you close your browser. They help us track internet usage.
  3. Analytical/Performance Cookies: Allow us to recognize and count visitors, helping us improve website functionality.
  4. Functionality Cookies: Recognize your return visits, remembering preferences to enhance your experience.
  5. Targeting Cookies: Track your visit to our website and pages you navigate to deliver content relevant to your interests.

Managing Cookies: Most browsers let you refuse or delete cookies. Disabling cookies may impact website functionality. To manage or delete cookies, you can refer to the instructions provided by browsers like Chrome, Firefox, Opera, Internet Explorer, and Safari.

 

8.  Data Analytics

We use analytics tools to measure visitor interactions with our website content. We also use Facebook Custom Audiences to display ads based on your interactions with our websites or Facebook applications. For more information on how these services use such technologies, you can visit the respective websites of Google, Adobe, and Facebook.

If you prefer to opt out of data collection through Google Analytics, you can use the Google . You can also opt out of Facebook Custom Audiences on Facebook’s opt-out page.

 

9.  Aggregated Data

Aggregated Data refers to records stripped of personal data, combined to provide generalized, anonymous information. Your identity is not revealed in Aggregated Data. We combine personal data anonymously with other information to create Aggregated Data for internal use, planning, and marketing purposes, and for sharing with affiliates, subsidiaries, and business partners.

 

10.  Data Protection Principles

When third parties process data on our behalf, we ensure that personal data is safeguarded. Company is responsible for the processing, management, storage, and retention of all personal data, both in manual and digital form. Third parties that process your Personal Data include, our service providers, other networks connected to our service, our advertising partners, our marketing and advertising affiliates, our educational partners, scholarship providers, analytics providers, recruiters and such other third-party sources. If you require any more information in this regard you may write to the Data Processing Officer as given in Section 31 herein.

Principles for Data Processing:

  1. Processed fairly, lawfully, and
  2. Collected for specific, explicit, and legitimate
  3. Limited to what is necessary for
  4. Kept accurate and up to
  5. Retained only for as long as necessary for its
  6. Protected against unauthorized processing or damage through appropriate
  7. Complies with relevant laws and procedures for international data

11.  Legal Basis for Processing Personal Data

In certain jurisdictions, Company requires a lawful basis for processing personal data, which can vary depending on the activity. The bases we rely on include:

  1. Necessary for the negotiation, execution, or performance of
  2. Compliance with legal and regulatory
  3. Legitimate interests, such as improving our services, communicating with users, and securing systems.
  4. Protection of a user’s vital interests or those of another
  5. Processing necessary for the public
  6. Processing based on user

 

12.  Consent

We obtain user consent for certain data collection and use when required by law. Once consent is given, it is implied for any supplementary information needed for the same purpose. Express consent is obtained if a new purpose arises.

Consent may also be implied when users are given notice and a chance to opt-out, but do not exercise the opt-out option. However, users can withdraw their consent, subject to exceptions like the need to provide a service or fulfill a legal obligation. Such withdrawal of the consent shall be sent in writing to the DPO. By using our website, acknowledging our privacy policy, or voluntarily providing data, users consent to our data practices.

If users refuse or withdraw their consent, we may be unable to provide some services.

 

13.  Purpose of collecting Personal Data

We collect your Personal Data for the following purposes:

  1. To fulfill or meet the reason you provided the
  2. We use your information for managing and processing purposes, including, but not limited to, tracking attendance, progress, and completion of a Program. As part of our management and processing of the Program, we will use certain Personal Data to administer exams, projects, and other assessments for the Program. For example, as part of an exam, Company may use certain information collected from you to verify your identity or monitor your performance during the exam to confirm that you are abiding by the applicable testing rules or requirements.
  3. To send you updates about the Programs, other Company events, platform maintenance, or new services provided by Company, among other things, through itself or through third parties, via WhatsApp, email, SMS, phone call, or any other medium.
  4. Provide Chat Room
  5. To enhance the quality of our content and product
  6. Compliance with security and other mandatory policies and building
  7. Providing information to relevant external authorities for tax, social security, and other purposes as legally required.
  8. Conducting surveys to assess your satisfaction, including but not limited to its processes or policies.
  9. Setting up and maintaining accounts and subscriptions with third parties that provide information and research services or communication services.
  10. Making decisions about your continued engagement, employment, or
  11. Dealing with legal or regulatory disputes or investigations involving you, our work, or other partners, employees, workers, and contractors, including accidents at work, potential and actual negligence claims, and professional discipline matters.
  12. To monitor the use of our information and communication systems to ensure compliance with our IT and document management policies.
  13. To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software
  14. Business management and planning, including accounting, auditing, and
  15. Planning or reviewing options in relation to the operation or
  16. Keeping registers required by law or
  17. Communicating with you, for example, to respond to
  18. Enhancing the safety and security of the services and preventing fraud, or protecting our or our customers’, or your rights or property.
  19. Enforcing applicable terms and conditions and other applicable

 

14.  Advertising and Marketing

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or if you provided us with your details and expressly consented to receiving that marketing.

We may use your Personal Identification, Identity, Contact, Electronic, and User-generated Data to form a view on what we think you may want or need, or what may be of interest to you. This is how   we   decide  which   services  and   offers  may  be   relevant  for   you.

We also enter into agreements with third parties to serve Ads on our behalf across the internet, social networking sites, and blogs. These third parties may collect Personal Data about your visits to our platform and your interactions with our products and use this information to target advertisements for goods and services.

Where electronic direct marketing communications are being sent, you have the option to opt-out in each communication sent, and this choice will be recognized and adhered to by us.

 

15.  Disclosure of Personal Data

Company is a global company and may share the personal information collected or provide such access to other companies within the Company group.

Examples of third parties with whom Company may share Personal Data include:

  1. With government bodies, including tax and social security authorities, to comply with applicable laws (including employment and tax laws), to obtain licenses or approvals, and upon request during an audit or assessment.
  2. With suppliers, subcontractors, and service providers, to maintain an efficient and commercially viable business, including technology, telecom, internet providers.
  3. With professional advisers, consultants, and employment and recruitment agencies, to conduct background verification and reference checks, administer benefits and payroll, deal with disciplinary and grievance issues, and maintain emergency contact details.
  4. With our legal advisors and external auditors for legal advice and to conduct business
  5. With service providers for business continuity management and contingency planning in the event of business disruptions.
  6. With certain companies to establish a membership to participate in digital wallets, payment services, or rewards programs.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

In addition to the examples cited above, Company also shares your Personal Data with:

  • Educational Partners: Including universities, companies offering courses, external graders, and mentors, sharing Personal Identification Data, Personal Characteristics Data, Contact Data, and User-generated data to evaluate, assess progress, and report on your progress in the Program or enable them to issue a certificate upon completion.
  • Employers; Sponsors and Scholarship Providers: If you are taking a Program that is sponsored or paid for by your employer or a sponsor, or if you have availed a scholarship from a third-party scholarship provider, we may share your Personal Data and grades, evaluations, or progress in the Program with your employer/sponsor/scholarship provider. This information may be shared at any time during the Program or afterwards.
  • Service Providers: We provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf strictly on confidential terms. They provide a variety of services to us, including billing, sales, marketing, test proctoring, couriers, mentoring, recruitment consulting, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, credit facilities, payment processing, and legal services.
  • Third Parties: This may include third parties involved in providing financial services, analytics, and more, depending on the needs of Company’s business operations.

16.  Data subject rights

Some jurisdictions grant individuals specific rights concerning the processing of their Personal Data, particularly in the European Union. These rights may also be available in other jurisdictions, but their availability varies. Depending on applicable law, you may have the right to:

  1. Request access to your Personal
  2. Request correction of inaccurate, incomplete, or obsolete Personal
  3. Request deletion of your Personal
  4. Withdraw your consent to processing (effective for future processing).
  5. Object to the processing of your Personal
  6. Request restrictions on
  7. Request the transfer of your Personal Data to you or a third
  8. Opt-out of certain transfers to third
  9. Request to opt-out of automated decision-

To exercise these rights, please contact us at mayank@borderplus.co. We may need to verify your identity before fulfilling your request. Conditions for exercising these rights will vary based on applicable laws, and requests may be refused if they are repetitive, technically burdensome, risk others’ privacy, compromise ongoing investigations, or are impractical. Company does not discriminate against users for exercising their rights. You may also have the right to complain to a data protection authority.

 

17.  Our Policy on Children’s Data

Children’s data privacy is important to us, and our Sites are not intended for children. The age threshold varies by jurisdiction (e.g., 16 under GDPR, 13 in the UK, 18 in Singapore and Qatar). As a policy, we do not collect, process, store, or transfer Personal Data of children unless required by contractual obligations or law. If collection

is necessary, we will inform you, seek explicit consent, and, where applicable, parental authorization. Any children’s Personal Data collected without verified consent will be deleted promptly, subject to legal conditions.

 

18.  Data Security

Company employs technical and organizational measures, supported by privacy impact and risk assessments, to ensure a high level of security for Personal Data. Measures include policies to prevent unauthorized processing and accidental data loss or damage. Company assigns data security responsibilities, conducts risk assessments, and maintains controls to safeguard your data.

Organizational measures include:

  1. Securing confidential
  2. Avoiding unauthorized
  3. Regular data accuracy
  4. Careful use of
  5. Using screen blanking for inactive

Transporting Personal Data on portable devices requires authorization and must be encrypted. Laptops and USB drives must be kept secure. Failure to follow security rules may result in disciplinary action. Company also ensures that third-party service providers maintain similar security measures. Despite these efforts, Company cannot guarantee 100% security of Personal Data and is not liable for third-party provider breaches.

 

19.  International data transfers and users outside the geographical limits of India

Company operates primarily in India, but due to its global nature, your Personal Data may be stored on servers in other countries where Company operates. This includes transfers to service providers and third parties outside your jurisdiction. When required, we will seek express consent for these transfers. By agreeing to this policy, you consent to such transfers. We strive to ensure that similar data protection standards are maintained during such transfers.

By agreeing to this policy, you are providing Company with your explicit consent to process your personal information for the purpose(s) defined in this policy. The data protection regulations in India or such other jurisdictions mentioned herein may differ from those of your country of residence. This may also be applicable if you are in the European Economic Area (EEA). Countries your data may be transferred to may not have laws that provide the same level of protection for your personal data as laws within the EEA. Where this is the case, we will put appropriate safeguards in place to make sure that these transfers comply with European privacy law. In certain specific cases, we transfer your data outside the EEA because it is in your interest or is necessary to conclude or perform the contract, we have with you.

For international transfers, Company will comply with legal requirements, using data transfer agreements such as Standard Contractual Clauses for European data. We are committed to secure processing and will seek practical solutions if conflicts arise with public authority requirements.

 

20.  Records management

Records management involves activities to control the creation, distribution, use, maintenance, and disposal of recorded information. Effective records management ensures compliance with information laws, supports data minimization, and ensures that Personal Data is kept only as long as necessary for its original purpose.

 

21.  Organization and Responsibilities

Company maintains records of data processing in accordance with the law. The Data Protection Officer (DPO) oversees compliance with data protection principles and ensures that the Data

Processing Register is up to date. All staff members have a role in ensuring compliance with the measures outlined in the Register.

Our compliance with data protection policies is periodically reviewed internally by a designated governance group. Those handling Personal Data on behalf of Company, including employees, volunteers, and contractors, receive appropriate training and supervision.

The DPO, Governance Group, and relevant business areas regularly review data practices. When high risks to individuals’ rights are identified, a Data Protection Impact Assessment (DPIA) is conducted, and consultation with the supervisory authority may follow.

 

22.  Conflicts of Law 

This Policy is intended to comply with the laws and regulations in the place of establishment and the countries in which the company operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.

 

23.  Retention of Personal Data

We retain your Personal Data no longer than necessary for the purposes for which it was collected. The length of time to retain Personal Data depends on the purposes for which we collect and use it and/or as required to comply with applicable laws, or to establish, exercise, or defend our legal rights.

The users can exercise their rights enumerated herein. If required to extend the retention period, we shall obtain your consent. Additionally, we may dispose of the data before the retention period ends if the purpose for which it was collected is exhausted.

 

24.  Procedures

The Company has taken the following steps to protect the Personal Data of relevant stakeholders:

  • It appoints or employs employees with specific responsibilities for processing and controlling data.
  • It conducts comprehensive reviews and audits of its data protection systems and procedures, overseeing the effectiveness and integrity of all data that must be protected. There are clear lines of responsibility and accountability for these roles.
  • It provides employees with training to make them aware of the importance of protecting Personal Data and how to do so while maintaining confidentiality.
  • It can account for all Personal Data it holds, its origins, its sharing, and potential
  • It conducts risk assessments during reviews to identify vulnerabilities in its Personal Data handling and processing, taking measures to reduce risks. The procedure includes assessing the impact of both use and potential misuse of Personal Data.
  • It recognizes the importance of seeking consent for obtaining, recording, using, sharing, storing, and retaining Personal Data and regularly reviews its procedures for this, including the necessary audit trails. Consent must be freely given, specific, informed, and unambiguous, and can be withdrawn at any time.
  • It has mechanisms for detecting, reporting, and investigating suspected or actual Personal Data breaches. It reports significant breaches causing harm to individuals to the relevant authority and understands the implications of international data transfer.

 

25.  Breach Notification

Where a data breach poses a risk to individuals’ rights and freedoms, it will be reported to the relevant authority within 72 hours of awareness, possibly in multiple installments. Individuals will be directly informed if the breach poses a high risk to their rights and freedoms. If necessary, the Company will notify the public without undue delay.

 

26.  External Links on our Website

For your convenience, we may provide links to sites operated by organizations other than Company (“Third Party Sites”). We do not disclose your Personal Data to these Third-Party Sites without a lawful basis. We do not endorse and are not responsible for the privacy practices of these Third-Party Sites. Review their privacy policies to understand how they collect and use your data.

Company uses YouTube API Services to play videos. When a YouTube video is played, it communicates directly with YouTube, not Company. Users should review the Google Privacy Policy. Company does not record video watch data or related YouTube API data. We take no responsibility for the content or practices of third-party services in the Third Party Sites and encourage reviewing their terms of service before use.

 

27.  Information for California Residents

Depending on your relationship with Company, we may have collected the following categories of Personal Data in the past twelve (12) months:

  • Identifiers: Real name, alias, postal address, online identifier, IP address, email address, account name, Social Security number, driver’s license, passport number, or other similar
  • Personal Information under the California Customer Records statute: Name, signature, Social Security number, physical characteristics, address, telephone number, education, bank account number, and other similar information.
  • Protected classification characteristics: Age, race, national origin, citizenship, marital status, medical condition, sex, veteran status, and genetic information.
  • Commercial information: Records of products or services purchased, or other consumption histories.
  • Biometric information: Fingerprints, faceprints, iris scans, and other
  • Internet activity: Browsing history, search history, and interactions with
  • Geolocation data: Physical location or
  • Sensory data: Audio, electronic, and visual
  • Professional or employment-related information: Job history or performance
  • Non-public education information: Records directly related to a student maintained by an educational institution.
  • Inferences drawn from other Personal Information: Profiles reflecting preferences, behavior, and abilities.
  • Sensitive personal information: Social Security, driver’s license, account credentials, genetic data, and religious or philosophical beliefs.

 

28.  Use of this website and relevant terms of service:

This website is the property of Company. The applicable terms of use/terms of service/terms and conditions and the Privacy Policy govern the use of the platform and the programs offered by Company. The Privacy Policy is part of the aforesaid terms by reference. By using the website and its information, users indicate their acceptance of such terms.

 

29.  Updates to this policy:

The Privacy Policy may be updated periodically. Company will take reasonable steps to notify all Company entities, customers, business partners, and other affected data subjects by posting the revised Privacy Policy on the website and/or via email.

 

30.  Data Controller/Company Details:

The “Data Controller” refers to Company, which decides how user data is used and is responsible for holding personal information. As Company consists of different legal entities, the entity acting as the controller depends on where the personal data is collected.

 

31.  Data Protection Officer:

Company has appointed a Data Protection Officer (DPO) in compliance with applicable laws. DPO shall act as the Grievance Officer and shall address any discrepancies and grievances that you may have. In case of any unresolved concerns, you also have the right to file a complaint with the Data Protection Board of India.

The DPO can be contacted as follows: