FortunaPIX Private Limited along with its affiliate(s) (operating under the brand name LernBag) (hereinafter referred to as ‘FortunaPIX’ or ‘We’ or ‘Us’), are a digital education publisher creating long-term impact by disrupting conventional learning experiences in class and building continuity beyond class to make learning accessible, inclusive and engaging.
LernBag takes user privacy and data security very seriously. We also sincerely value Your trust. In order to deliver Our services to You and honour that trust, LernBag adheres to ethical standards in gathering, using, and safeguarding any information You provide.
When You are accessing our website, We collect personal information and other data from you from time to time, that is necessary for the purpose of providing services to you in relation to the website. The information We collect from You, along with the content that You use on Our website and the data on how You use Our websites is used for the purpose of assessing, analysing and providing a range of services that meet Your needs.
When You share information with Us, that information is treated in a secure and confidential manner. This means:
- We take full responsibility for all information You provide to Us
- We will protect Your personal information
- We will not sell Your information to a Third party
If You do not agree with the terms of this Policy, You should not use the Website or avail any of Our Services.
We reserve the right to change this Policy at any time, so please check regularly to be informed of any updates to this Policy. The date of last revision shall be reflected on the Website, in case of any changes in the Policy.
1. User Provided Information
The Website obtains the information You provide when You access and/ or register for the Services. When You register with Us, You generally provide Your name, Your organisation’s name, type of organisation, email address, mobile number, password and any other information necessary for provision of Services. The said information collected from the users could be categorized as “Personal Information” and “Sensitive Personal Information. Personal Information and Sensitive Personal Information (each as individually defined under Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (the “Data Protection Rules”)) shall collectively be referred to as “Information” in this Policy.
We may use the Information to contact You from time to time through SMS, e-mail or telephone, to provide You with the Services including but not limited to login access, status of subscriptions, reminders on expiry timelines, important information, required notices and marketing promotions. By registering Yourself, You agree to make your contact details available to Our employees, associates and partners so that You may be contacted for any information/ updates/ promotions through various means. We will ask You when We need more Information that personally identifies You (Personal Information) or allows Us to contact You as they are considered an essential part of the Services You have chosen. We also provide an option to unsubscribe from the marketing promotion communications, should You no longer wish to receive any such communication from Us. However, we recommend that You stay subscribed in order to receive latest updates about Our new product/ service offerings and latest trends in the market.
We will not differentiate between who is using the device to access the Website or Services, so long as the log in/ access credentials match with Yours. In order to make the best use of the Website/ Services and enable Your Information to be captured accurately, it is essential that You have logged in using your own credentials.
We will, at all times, provide the option to You to not provide the Personal Information or Sensitive Personal Information, which We seek from You. Further, You shall, at any time while using the Services, also have an option to withdraw Your consent given earlier to Us to use such Personal Information or Sensitive Personal Information. Such withdrawal of the consent is required to be sent in writing to Us at the contact details provided in this Policy below, at clause-16. In such event, the Company fully reserves the right not to allow further usage of the Website or provide any Services thereunder to You.
2. Automatically Collected Information
In addition, We may collect certain information automatically, including, but not limited to, the type of device You use, Your devices unique device ID, the IP address of Your device, Your operating system, the type of internet browsers You use, and information about the way You use the Website or Services. As is true of most website operators, We also collect other relevant information as per the permissions that You provide in Your internet browser settings.
3. Use of Your Personal Information
We use the collected information to analyse trends, to conduct research, to administer the Services, to learn about each user's learning patterns and movements around the Services and to gather demographic information and usage behaviour about our user base as a whole. Aggregated and individual, anonymized and non-anonymized data may periodically be transmitted to external service providers to help Us improve the Website and application, products and Our Services. We will share Your information with Third parties only in the ways that are described below in this Policy.
We may use the individual data and behaviour patterns combined with Personal Information to provide You with personalized content, and better Your learning objectives. Third parties provide certain services which We may use to analyse the data and information to personalize, drive insights and help Us better your experience or reach out to You with more value-added applications, products, information and services. However, these Third party companies do not have any independent right to share this information. We do not sell, trade or rent Your Information to any Third party unless, we have been expressly authorized by You either in writing or electronically to do so. We may at times provide aggregate statistics about Our customers, traffic patterns, and related site information to reputable Third parties, however this information when disclosed will be in an aggregate form and does not contain any of Your personally identifiable information.
We are entitled to disclose Your information in the following circumstances:
as required by law, such as to comply with a subpoena, or similar legal process;
to enforce applicable Terms, including investigation of potential violations thereof;
when We believe in good faith that disclosure is necessary to protect Our rights, protect Your safety, the safety of others, investigate fraud, address security or technical issues or respond to a government request;
with Our trusted service providers who work on Our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this Policy;
to protect against imminent harm to the rights, property or safety of the Website/ FortunaPIX or its users or the public, as required or permitted by law;
disclosure to Third party service providers like professional advisors, auditors, IT service providers etc. in order to improve the user experience and to perform behavioural analysis. It is to be noted that the information shared is in aggregated form and merely used for improving the user experience and no individual user profiling is done. These Third party service providers may combine the information collected from Us with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.
4. Access to your Personal Information
We will provide You with the means to ensure that your Personal Information is correct and current. If You have filled out a user profile, We will provide an obvious way for You to access and change Your profile from Our Website. We adopt reasonable security measures to protect Your password from being exposed or disclosed to Third parties.
5. Your Rights
You are entitled to request details of the information We hold about You and how We process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict Our processing of that information, to stop unauthorised transfers of Your Personal Information to a Third party and, in some circumstances, to have Personal Information relating to You transferred to another organisation. You may also have a right to lodge a complaint in relation to Our processing of your Personal Information with a local supervisory authority.
If You object to the processing of Personal Information, or if You have provided Your consent to processing and You later choose to withdraw it, We will respect that choice in accordance with Our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that We are unable to perform the actions necessary to achieve the purposes set out above (see ‘Use of Your Personal Information’) or that You may not be able to make use of the Services and content on the Website. Please note that even after You have chosen to withdraw Your consent, We may be able to continue to process Your Personal Information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending Our legal rights and meeting Our legal and regulatory obligations.
We must ensure that Your Personal Information is accurate and up to date. Therefore, please advise us of any changes to your information by emailing us at DPO@LernBag.com.
We send cookies (small files containing a string of characters to Your computer, thereby uniquely identifying your browser. Cookies are used to track Your preferences, help You login faster, and aggregated to determine user trends. This data is used to improve our offerings, such as providing more content in areas of greater interest to a majority of users. It is to be noted that the cookies shall not be used for any purposes other than the ones mentioned.
Most browsers are initially set up to accept cookies, but You can reset Your browser to refuse all cookies or to indicate when a cookie is being sent. Some of our features and Services may not function properly if your cookies are disabled. The cookies We use could be essential as well as optional cookies. Essential cookies are the ones that are strictly necessary for the functioning of the Website and for providing Services while optional cookies are all other cookies other than Essential cookies.
By accepting the terms of this Policy, You hereby consent to placement of cookies belonging to Us and Third parties on Your browser by Us and other Third parties.
The data We collect through cookies includes User agent information (Browser, OS and device), IP address and geographical location derived from it, page/asset requested, Time of request, Unique user id generated at the time of registration etc.
We are concerned about safeguarding the confidentiality of Your information. We provide physical, electronic and procedural safeguards to protect information we process and maintain. For example, We limit access to this information to authorized employees only who need to know that information in order to operate, develop or improve our Services/ Website and who have agreed not to disclose the information to others. Please be aware that, although We endeavour to provide reasonable security for information We process and maintain, no security system can prevent all potential security breaches.
9. How Long Do We Retain User Data?
Currently, We plan to retain user data while an account is active and for at least three years afterward. We may alter this practice according to legal and business requirements. For example, We may lengthen the retention period for some data if needed to comply with law or voluntary codes of conduct. Unless otherwise prohibited, We may shorten the retention period for some types of data if needed to free up storage space.
10. Countries your Personal Information is transferred to
In order to provide Our Services We may need to transfer Your Personal Information to locations outside the jurisdiction in which You provide it or where You are viewing the Website. Where Our Third party service providers in the course of providing services to Us process personal data outside the jurisdiction in which it is provided, Our written agreements with them will include appropriate measures, usually standard contractual clauses to ensure that your Personal Information remains protected and secure in accordance with applicable data protection laws.
11. Log information
When You access our Website, Our servers automatically record information that Your browser sends whenever You visit a website. These server logs may include information such as Your web request, internet protocol address, browser type, browser language, the date and time of Your request and one or more cookies that may uniquely identify Your browser.
12. User communications
When You send an email or other communication to Us, we may retain those communications in order to process Your inquiries, respond to Your requests and improve Our Services.
13. Changes to this Statement
14. Your Consent
We believe that, every user of Our Services/ Website must be in a position to provide an informed consent prior to providing any information required for the use of the Services/ Website. By registering with Us, You are expressly consenting to Our collection, processing, storing, disclosing and handling of Your information as set forth in this Policy now and as amended by Us from time to time. Processing Your information in any way, including, but not limited to, collecting, storing, deleting, using, combining, sharing, transferring and disclosing information, all of which activities may take place in India/ outside India. If You reside outside India, Your information will be transferred, processed and stored in accordance with the applicable data protection laws.
15. California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third parties to whom We have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the types of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to DPO@LernBag.com.
16. Contact Information
Our Data Protection Officer shall undertake all reasonable efforts to address Your grievances at the earliest possible opportunity. In case of any query/ grievance/ other legal information You may contact us at:
Data Protection Officer:
Sri Venkata Sai Complex,
House No. 1-62/33/34,
Plot No. 33 & 34,
Kavuri Hills, Madhapur,
Hyderabad – 500033, Telangana, India