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Privacy Policy

SCOPE AND PURPOSE

NIIT Learning Solutions (Canada) Ltd. (“NIIT”, “we”, “us” and “our”) is committed to protecting your privacy and ensuring your personal information remains secure. As such, we have implemented this Privacy Policy to inform you of our practices relating to the collection, use and disclosure of personal information, including information we collect about you when you use our cloud-based learning services platform (“Services”), when you visit our platform (“Platform”) or when you contact us directly.

This Privacy Policy also explains how you can contact us if you have any questions about how we handle your personal information or how to exercise any rights you may have regarding your personal information. We strongly recommend that you take the time to read this Privacy Policy and retain it for future reference.

PERSONAL INFORMATION

In this Privacy Policy, “personal information” generally means information (regardless of its format) about an identifiable individual. This may include, for example, your name, contact information, home address, email address, job title and other information relating to your account with us (as the case may be). It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be used alone, or in combination with other available information to identify an individual is not considered to be personal information.

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT

We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected.

We may collect the following personal information depending on your interactions with NIIT: (for instance as a client or as a Platform visitor):

  • Personal identifiers, such as first and last name, email address, username (when you create an account with us) and telephone number.
  • Professional information, such as a professional title, company name/institutional affiliation, postal address, professional email address and phone number, place of business, professional licenses, certifications and courses and credentials.
  • Device information, such as Internet protocol (IP) address, browser type, mobile device ID number, operating system and pages viewed on our platform.
  • Content information, such as images, videos, comments and messages you voluntarily posted on our Platform or sent us directly or any other usage data related to your use of the Platform.
  • Credit card and payment information. We may also collect credit card and payment information from you via a third-party payment provider. We may also collect credit card information from you and subsequently provide that information to our payment provider when required to provide you with the Services as further detailed under “When Do We Share Your Personal Information” section.
  • Brokerage-issued data, such as performance data (e.g., sales made, commission etc.) and professional data (e.g. certifications, courses) and any other information that we received from the brokerage firm with which you are associated and with which we have a business relationship.
HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information directly from you or through the brokerage firm with which you are associated and with which we have a business relationship. For instance we collect personal information in the following situations:

  • When you open an account with us or when your brokerage firm opens an account on your behalf;
  • When you subscribe to our newsletter;
  • When you fill forms, take courses or make purchases on our platform;
  • When you contact us with an inquiry or to report a problem with our platform; or
  • When you agree to complete a research survey; or
  • You access and use the website/platform as per routine operations.

We also collect personal information automatically through our Platform using technologies (either our own or third party technologies) such as cookies and web beacons. This information collected is limited to IP addresses, browser type, and pages viewed on our Platform. For more information about the technologies we use to collect information through our Platform and how you can manage your choices, please review our Cookie Policy.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes or otherwise with your consent or as permitted or required by law:

  • To provide you with the Services you requested on the platform;
  • To customize the content of our platform;
  • To notify visitors about updates to the platform;
  • To improve the user experience of our platform and Services;
  • To improve the management of our platform and Services;
  • To monitor your usage of the platform for reporting to our business partners;
  • To ensure the security of our platform and Services, including sending you important administrative email notifications regarding security, support and maintenance advisories;
  • To identify you as a returning user of our platform and Services;
  • To send you marketing communications such as newsletters, surveys, offers, and other promotional and marketing materials related to our Services provided that you did not withdraw your consent to receiving such communications as provided under “Your Privacy Rights” section. Please note that even when you withdraw your consent to receiving marketing communications, you may still receive messages that are necessary as part of our business relationship with the brokerage firm with which you are associated or to the extent required and/or permitted by applicable law;
  • To respond to any request or inquiry you have sent us; and
  • To comply with legal obligations.

We may also use your personal information to create de-identified aggregated data. We use this data to analyze requests and usage patterns so that we may enhance the content of our Services and improve Platform’s performance. We reserve the right to use this data for any commercially reasonable purpose and disclose this data to third parties in our sole discretion at all times in compliance with applicable laws.

WHEN DO WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with service providers, including independent contractors (which may have access to your personal information in providing services to us or providing you with access to the Platform) cloud storage service providers, suppliers, partners and employees to use that information in connection with one or more of the purposes indicated in this Privacy Policy and to third parties with your consent (for instance with your associated brokerage firm at your request) or as set out below:

  • under applicable law, including laws outside your country of residence;
  • to comply with the legal process;
  • to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security, and/or law enforcement purposes;
  • to conduct fraud prevention or investigate a fraudulent activity which has already taken place;
  • to enforce the terms and conditions of our Services; and
  • to allow us to pursue available remedies or limit the damages that we may sustain.

We may use a variety of service providers, contractors, servers (and other hardware) or employees in locations both inside and outside of Canada, which may make your personal information the subject of foreign laws and foreign legal proceedings as indicated in the “Cross-Border Transfers of Personal Information” section.

Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the personal information we have collected to the relevant third party, including disclose your personal information to our successors (if our business or the Platform is acquired by another legal entity) or any assignee of our assets relating to the Platform or other software.

CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION

We, or our cloud storage service providers, may access, store and process your personal information outside of the province or country where you reside. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction. We take great care in protecting your personal information and have put in place adequate mechanisms to protect it when it is transferred internationally. We will transfer your personal information in compliance with applicable data protection laws and will implement suitable safeguards to ensure that your personal information is adequately secured in accordance with all applicable laws.

HOW WE MANAGE CONSENT

Consent is often referred to as a choice to “opt in” or “opt out” of NIIT’s use of your personal information and is usually obtained by a “check box” or signature confirming that you understand and agree to the processing of your personal information in accordance with this Privacy Policy. At times, express written consent from you may be required depending on the type of personal information, the purpose for which it will be used or the third party to which it will be disclosed.

By visiting our platform, using the Services, creating an account or subscribing to our newsletter, or otherwise interacting or communicating with us, you are providing your consent to the collection, use and disclosure of your personal information as set out in this Privacy Policy. In some cases, your consent may be “implied”, meaning that your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information. You provide implied consent where our purpose for collecting using or disclosing your personal information would be considered obvious or reasonable in the circumstances. Consent may also be implied where you have received notice and a reasonable opportunity to opt-out of having your personal information used for marketing communications and you do not opt-out, as required and/or permitted by applicable law.

If you choose not to provide us with your personal information, or if you withdraw your consent, as provided under “Your Privacy Rights” section below, we may not be able to provide you with the Services you requested.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION

We store your personal information for as long as is necessary to provide our Services to you, to manage our business operations and to comply with our legal and regulatory obligations. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

To learn more about our retention and destruction policies and practices, you may contact our Privacy Officer as described in the “Contact Us” section below.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION

NIIT makes commercially reasonable efforts to ensure that personal information collected from you is kept secure and protected against loss, theft, and unauthorized access, use or disclosure throughout its life cycle. Only authorized employees, business partners and service providers, who are contractually obliged to keep information secure and confidential, have access to this information, which is at all times restricted on a need-to-know basis.

NIIT ensures that our service providers employ industry-standard security measures to ensure the security of information we transferred to them through contractual agreements. However, users of our platform and Services are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password-protected or secure areas of the platform or the Services. Access to and use of password-protected and/or secure area of the platform and Services are restricted to authorized users only. Any unauthorized access to such areas is strictly prohibited.

  • Data Governance and Security
    NIIT maintains governance policies and practices which ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:
  • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle;
  • Employee privacy and data security training;
  • Designating a Privacy Officer to monitor and manage NIIT’s compliance with applicable privacy laws. The Privacy Officer’s role and responsibilities include approving internal policies and practices regarding the protection of personal information, assisting in conducting privacy impact assessments (when required by law), and responding to access and rectification requests or similar types of requests in accordance with this Privacy Policy and applicable laws;
  • Developing procedures for receiving, investigating and responding to complaints or inquiries regarding NIIT’s information handling practices, including any confidentiality incident involving personal information and any request from an individual to exercise their privacy as provided below under “Your Privacy Rights”;
  • Access controls that restrict access to your personal information to employees or service providers who have a business need consistent with the reason the information was provided;
  • Generally accepted information security techniques, such as firewalls, data encryption, antivirus software and access control procedures; and
  • Guidelines limiting our retention of personal information to what is necessary to achieve the purposes described in this Privacy Policy, including providing you with the Services requested. This framework also governs the disposal of your personal information and is more fully described in the How Long Do We Keep Your Personal Information section above.
LINKS TO THIRD-PARTY WEBSITES

The Platform and Services allow users to access Facebook, affiliates, service providers, suppliers, partners and employees and other social networking sites (collectively, “SNS”) to interact with friends and to share through walls and newsfeeds. Once you connect with an SNS, your use of the SNS is governed by the SNS’s terms and conditions and privacy policies. Any information that we collect from service providers, suppliers, partners and employees or other SNS account may depend on the privacy settings you have with that SNS. NIIT is not responsible for how SNS and other third-party websites collect, use, or disclose your personal information, so it is important to familiarize yourself with their privacy policies before providing them with your personal information.

YOUR PRIVACY RIGHTS

NIIT provides individuals with the right to control their personal information, which includes the right to access your personal information and request the correction or deletion of inaccurate information, subject to limited exceptions set out in applicable laws. Please send your requests to our Privacy Officer via email using the contact information provided under the Contact Us section below.

In your request, please make clear what personal information you are requesting access to or would like to have rectified or deleted. NIIT may require you to provide additional information in order to verify your identity.

While the majority of questions and issues related to access and rectification can be handled quickly, complex requests may take more effort and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within 30 days.

You may also exercise your right to withdraw your consent to the collection, use and disclosure of personal information in accordance with this Privacy Policy at any time upon reasonable notice to NIIT in writing, subject to legal or contractual restrictions. Please note that the withdrawal of your consent may affect our ability to continue to provide you with the Services that you have or would like to receive because the continued use and disclosure of your personal information is a necessary part of making the Services available to you. In some circumstances, legal requirements may prevent you from withdrawing consent.

  • Changing Your Communications Preferences

We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. It may take up to ten (10) business days to register a change of preference across all our systems.

Please note that even if you have indicated your choice not to receive, marketing or promotional messages from us, we may still communicate with you in connection with the Services provided to you (for example, to send you a customer service message, a security update, or a support and maintenance reminder) or as part our business relationship with the brokerage firm with which you are associated, at all times as required and/or authorized by applicable law.

CHANGES TO THIS POLICY

NIIT may modify this Privacy Policy from time to time. The Privacy Policy posted on the Platform shall be deemed to be the Privacy Policy then in effect and the date at the top of the Privacy Policy will be updated to reflect the date of effectiveness. We recommend that you check this Platform from time to time to inform yourself of any changes in this Privacy Policy. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws.

CONTACT US

If you wish to exercise the rights described under Your Privacy Rights section or if you have any question about this Privacy Policy or NIIT’s information handling practices in general, or otherwise need assistance understanding the scope of any consent we may request from you, you may contact our Privacy Officer in any of the following ways:

NIIT Learning Solutions (Canada) Ltd.

1050 Crown Pointe Parkway, Suite 300;

Atlanta, GA, USA 30338