FreshGrad takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights. We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Members (Section 2), and Visitors (Section 3). If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 3

• Our privacy policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this policy periodically.
• By visiting this Website you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree please do not use or access our Website.
• By mere use of the Website, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms of Use.

The primary purpose of our Site and the Services is to allow you to enroll in and take onlinecourses on a variety of topics (“Courses”). For the purpose of this Privacy Policy, information that you provide through the Site can be in one of two categories: information relating to your use of the Site or the Services, including, without limitation, enrollment information for Courses,is referred to as “Site Information,” while information relating to taking the Courses, including, without limitation, interchanges with the Course Authors (“Course Authors”), other students (“Users”), answers, essays and other items submitted to satisfy Course requirements, is referred to as “Course Information.”

A. About Us
FreshGrad is an online platform to manage and conduct trainings, assessments and placements in universities.

B. Key Terms
In this privacy policy, these terms have the following meanings: "Member" means any person or entity that is registered with us to use the Services. "Personal Information" means any information that identifies or can be used to identify a Member, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information. "Website(s)" means any website(s) we own and operate (such as www.FreshGrad.co) or any web pages, interactive features, applications, widgets, blogs, social networks, tabs, or other online or mobile offerings that post a link to this privacy policy. "Visitor" means any person who visits any of our Websites. "you" and "your" means, depending on the context, either a Member or a Visitor.

This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Services. If you are not a Member, the visitors section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Members and potential Members.

A. Information We Collect
The Personal Information that we may collect broadly falls into the following categories:

(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, or communicate with us in any other way. We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in this privacy policy.
This information may include:
Registration information: You need a FreshGrad account to use the Services as a Member. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, username, password, and location.
Billing and communications information: If you purchase our Services, you may also need to provide us with payment and billing information, such as your credit card details and billing address. FreshGrad will also maintain a record of your billing transactions and purchases, and any communications and responses.

(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information.
This information may include:
Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.
Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of courses. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.

(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.
Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.

(iv) Information from the use of our mobile apps: When you use our mobile apps, we may collect certain device and usage-related information in addition to information described elsewhere in this privacy policy.
Device information: We may collect information about the type of device and operating system you use. We do not ask for, access, or track any location-based information from your mobile device at any time while downloading or using our mobile apps or Services.
We may collect information about how often you use the application and other performance data.

B. Use of Personal Information
We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

• To bill and collect money owed to us by you.
  This includes sending you emails, invoices, receipts, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments.
• To send you system alert messages.
  For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.
• To communicate with you about your account and provide customer support.
  For example, if you use our mobile apps, we may ask you if you want to receive push notifications about activity in your account. If you have opted in to these push notifications and no longer want to receive them, you may turn them off through your operating system.
• To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own.
  This may include developing tools and algorithms that help us prevent violations.
• For our data analytics projects.
  Our data analytics projects use data from FreshGrad accounts, including Personal Information, to provide and improve the Services. We use information like your usage habits and purchase history, so we can make more informed predictions, decisions, and products for our Members.
• Combined information.
  We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.
• Other purposes.
  To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.

C. Other Data Protection Rights
You may have the following data protection rights:

• To access, correct, update or request deletion of Personal Information. FreshGrad takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a Member, you can manage many of your individual account and profile settings provided through the FreshGrad platform.
  
• In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us using the contact details provided below.
  
• Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  
• The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority.
  
• We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.
  

This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section "you" and "your" refers to Visitors.

A. Information We Collect
(i) Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, profile information) in order to sign up for FreshGrad account, apply for a role with FreshGrad, or otherwise submit inquiries to us. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.
The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.
(ii) Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.
Specifically, the information we collect automatically may include your IP address, your operating system, your browser ID, your browsing activity, and other information about your system and connection and how you interact with our Websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies.

B. Use of Personal Information
We may use the information we collect through our Websites for a range of reasons, including

• To provide, operate, optimize, and maintain our Websites.
• To send you information for marketing purposes, in accordance with your marketing preferences.
• For recruitment purposes if you have applied for a role with FreshGrad.
• To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
• To manage our Websites and system administration and security.
• To improve the navigation and content of our Websites.
• To identify any server problems or other IT or network issues.
• To process transactions and to set up online accounts.
• To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
• To carry out research and development to improve our products and services.
• To customize content and layout of the Websites.
• To carry out other legitimate business purposes, as well as other lawful purposes.

In addition, we may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.

C. Other Data Protection Rights
You have the following data protection rights:

• To access, correct, update, or request deletion of your Personal Information. FreshGrad takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by emailing us at support@freshgrad.co. We will consider your request in accordance with applicable laws.
• In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at support@freshgrad.co.
• Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your Personal Information.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
If you have any queries, write to us at support@freshgrad.co