Privacy Policy
Triveni Kala Sangam, a non-profit society registered under the Societies Registration Act, 1960, owns and operates the website www.trivenikalasangam.org ('Website'), referred to as 'we', 'our', and 'us'. This Privacy Policy governs the receipt, collection, processing, storage, usage, transfer, and disclosure of personal data ('Personal Data') of users ('you', 'your', and/or 'user/s') through the Website and through our center. We process Personal Data of users in our capacity as a 'data fiduciary', as defined under the Digital Personal Data Protection Act, 2023.
By engaging with Us and using our services, You agree to the data collection and processing practices and policies set forth in this Privacy Policy. You hereby acknowledge that You have expressly consented to our collection, use, processing, storing, disclosure and/ or transfer of Your Personal Data in the manner as described hereinunder and for the specified purposes.
Please note that this Privacy Policy does not apply to websites maintained by other companies or organizations with which We partner with and/or link, and We are not responsible for any Personal Data You submit to third parties as part of the exhibitions or events organized by us. Please ensure that You read the privacy policy of such third parties before submitting Your details.
1. Modes of Collection of Personal Data
1.1 Information You Provide Us
We will collect Personal Data that You choose to provide Us, for registration purposes and in relation to the courses, exhibitions and workshops organized by Us and/or services provided by Us. This will be used for account creation, marketing communications, sending notifications to You, etc. (discussed below).
1.2 Automatically Collected Information
When we provide you with our services, we collect activity information, such as your device's IP address, the time your device accessed the website, etc. In this regard, we may utilize cookies, pixel tags, web beacons, etc., as further specified in our Cookie Policy in Section 3 of the Privacy Policy.
2. Nature of Personal Data Collected and Their Respective Purposes
We collect various types of Personal Data for specific purposes as detailed below:
The details required for course registration could be course specific. Other types of Personal Data may be required depending on the forms.
2.1 Personal Data Collected at the Time of Account Creation on Website
- Email address
- Username
- Password
2.2 Personal Data Collected at the Time of Registering for a Course or Workshop
- Full name
- Contact details such as phone number and email address
- Contact details such as phone number and email address of Parent/Guardian (as applicable)
- Date of Birth
- Present Address
- Nationality
- Passport details
- Identity Card (along with attestation to the photo ID)
- Visa copy for international students
- Vaccine certificates (as applicable)
- Economically weaker section certificates (as applicable)
- Financial details such as credit or debit card information / UPI ID / Net banking
2.3 Marketing Communications
To send You newsletters, promotional content, confirmations, etc., we collect contact details such as email address.
2.4 Automatically Collected Log Data
- IP address, location, timestamp information
- Application, device, versions and configurations
- Operating systems
- Device brand and model
- Unique identifiers associated with Your device(s)
2.5 Compliance with Legal Obligations
- To comply with disclosure obligations in accordance with applicable laws
- To respond to subpoenas, search warrants, court orders, or other legal process
- Any Personal Data collected by Us pursuant to the above-mentioned purposes
4. Minors
Parental consent is mandatory for collecting and processing children's data. We take the privacy and safety of minors very seriously and have strict protocols in place.
4.1 Types of Minor Data Collected
In the event you decide to register your child for any course offered by us, we shall collect, store, and use the following categories of Personal Data about your children: Name, Date of birth, Age, Gender, Copy of Birth certificate and other Government issued ID, Parent/Guardian identity documents, Attendance and absence information, Information about a child's health (including any medical condition, health, and sickness records), and Custody or guardianship legal documents.
4.2 Parental Consent and Authorization
You, as a parent, will be required to sign a consent and authorization form at the time of registration of your child with our centre. A dedicated file will be created for your child with respect to the Personal Data collected above. In addition to the Personal Data of your child above, you will need to provide us with a copy of your government issued identity card. We will maintain a register on details pertaining to drop and pick-up of your child and shall verify your identity with the government issued identity card provided to us each time you come to pick-up your child.
4.3 Purpose for Collection of Children's Data
We need all the categories of information mentioned in the list above primarily to allow us to register the child for the classes/ workshops and perform our obligations (including our legal obligations to the children attending our centre). The Personal Data of the children is also needed to (i) to ensure we meet the needs of the children, (ii) to enable enrolment with the classes and register in and out time, and (iii) in case treatment needs to be administered in the event of any medical emergency.
5. Disclosure and/or Transfer of Your Personal Data with Third Parties
We will not share the Personal Data we have collected from You, except as described below:
5.1 Third-Party Service Providers
We may share and/ or transfer Your Personal Data with a third-party service provider, on a need-to-know basis, and only to enable them to perform their services.
5.2 International Transfer
Your Personal Data may be transferred to and maintained on computers located outside of Your state, country, or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.
5.3 Transfer to India
If You are located outside India and choose to provide information to Us, please note that We transfer the information, including Personal Data, to India and process it there. Your consent to this Privacy Policy followed by Your submission of Your Personal Data represents Your agreement to that transfer.
5.4 Legal and Regulatory Disclosure
We may disclose Your Personal Data to law enforcement or regulatory authorities and / or government agencies, as applicable. We may disclose Your Personal Data if required to do so for compliance of a legal obligation under applicable laws or in good faith belief that such disclosure is reasonably necessary to respond to summons, court orders, or other legal process, law enforcement authorities, government authorities, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities.
5.5 Government Agencies
Your Personal Data may be shared, without obtaining prior consent, with government agencies mandated under the applicable laws or any law in India to obtain Your Personal Data for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences. Your Personal Data so obtained by the government agency or authority is not published or shared with any third party, unless the disclosure to any third party is required by an order under the applicable laws in India for the time being in force.
5.6 Protection of Rights
We may also disclose Your Personal Data to respond to claims that the content or information uploaded pursuant to partnership with a third party violates the rights of a third party, or protect the rights, property or personal safety of Our Users or the general public.
5.7 Business Transfers
We may share and/ or transfer some or all of Your Personal Data with another business entity should We plan to merge with, or be acquired by that business entity, or for the purposes of M&A transactions, reorganization, amalgamation or restructuring of our business.
5.8 Data Protection Safeguards
If We share and/ or transfer Your Personal Data to third parties for purposes stated in this Privacy Policy, We will use best endeavors to put in place appropriate controls and safeguards to ensure that Your Personal Data is adequately protected and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is necessary.
6. Your Rights as Users
You have extensive rights over your personal data. To exercise any of these rights, please contact our Grievance Officer using the details provided in Section 11.
6.1 Access Information About Personal Data
You can request a summary of the Personal Data which is being processed by Us and the processing activities undertaken by Us with respect to such Personal Data. You can also request for the identities of all data fiduciaries and data processors with whom Your Personal Data has been shared by Us along with a description of such Personal Data shared.
6.2 Access Privacy Policy in Another Language
If you wish to view the Privacy Policy in another language, then please reach out to us and we will arrange for the same. However, in the event of any discrepancy or conflict between the English version of the Privacy Policy and versions in other languages, the English version will prevail over the other translated versions.
6.3 Option to Not Provide the Personal Data
You can always elect not to disclose Your Personal Data to Us. However, please keep in mind that We may need some information to allow You to register with Us or for You to take advantage of some or all of the features offered on Our Website, and if You choose not to provide that information, Your ability to use our Website may be limited and it would be difficult for us to offer you access to the course or workshop.
6.4 Correction of Data
You have an option to access Your account and Your Personal Data in order to view, add, alter, update and/or modify Personal Data provided to Us.
6.5 Erasure of Personal Data
You can request for erasure of any Personal Data being processed by Us.
6.6 Deactivation and/or Deletion
You have a right to request for deactivation of Your account, and post such deactivation, Your Personal Data shall not be collected or processed.
6.7 Right to Withdraw Consent
You have the right to withdraw Your consent previously given for the collection, use or processing of all and/or any part of the Personal Data collected by Us, however, please note that this may disrupt Your user experience on Our Website. You may withdraw Your consent by writing to the Grievance Officer by using the contact information provided in Section 11 of this Privacy Policy. We shall discontinue processing Your Personal Data (and require other third-parties to discontinue processing) once We receive a request from You in writing, however, We have a right to retain and will not be held liable for processing any Personal Data that We collected prior to the said withdrawal request.
6.8 Right to Grievance Redressal
Please see Section 11 of the Privacy Policy on the grievance redressal mechanism available to You.
6.9 Right to Nominate
You have the right to nominate any other individual who can, in the event of death or incapacity, exercise rights on Your behalf.
7. Data Security
While we implement robust security measures, no electronic transmission or storage is 100% secure. We cannot guarantee absolute security but continuously work to protect your data.
7.1 Security Measures
We use commercially reasonable security measures (including physical, electronic and procedural measures) to safeguard Personal Data against loss, misuse, damage or modification and unauthorised access or disclosure. However, no system for transmitting or storing information electronically can be completely secure. Therefore, we cannot guarantee that Personal Data or other communications will always remain secure.
7.2 Data Storage and Protection
We maintain Personal Data pertaining to You in our business records as per current regulatory requirements. We have secure and appropriate data collection, storage, and processing practices. Our security measures protect against unauthorized access, alteration, disclosure or destruction of Your Information including Your username and other data stored on the mobile application or in our database.
7.3 Statistical Information
From time to time, We may reveal general statistical information about our Website, such as number of Users, etc., however, this will be anonymized or de-identified.
7.4 Employee Access
Only those of our employees, who need access to Your information in order to perform their duties as mentioned in the purpose section of this Privacy Policy, are allowed such access. Our employees and/or any other person processing Your Personal Data will respect the internal rules and procedures related to the Personal Data protection, including the technical and organizational security measures implemented to protect Your Personal Data.
7.5 Regular Reviews
In this context, We regularly review and update our practices to enhance Your privacy and ensure that its internal rules and procedures are duly followed. Our data collection, handling and processing practices are also continually reviewed to ensure compliance with the applicable data protection and privacy laws and regulations in India.
7.6 Limitation of Liability
We assume no liability or responsibility for disclosure of Your Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
7.7 Security Incident Reporting
If You have come across a vulnerability or would like to report a security incident, You can directly contact the Grievance Officer by using the contact information provided in Section 11 of this Privacy Policy.
8. Retention of Data
8.1 Retention Period
We will retain Your Personal Data and any data only for the period necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by Indian law.
8.2 Post-Withdrawal Retention
Pursuant to withdrawal of consent, We will retain Your Personal Data for a period of 1 year.
8.3 Legal Grounds for Processing
Under Indian laws, We process Your Personal Data with Your consent. However, You are entitled to withdraw Your consent any time and ask Us to stop such processing, in which case We will process Your data for a short period of time after this (and solely to allow Us to implement Your requests), provided there is no other legal ground for further processing.
9. General
9.1 Account Security
To help Us in protecting Your privacy, You should maintain secrecy of Your login information, if any, provided to You in connection with Your account. You should not share/transfer/ disclose Your account related information with anyone, nor will any of our representative(s) ask You for the same. Access of Your account by someone other than You is also prohibited.
9.2 Accurate Information
You acknowledge and agree that if You provide any Personal Data that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete over a period of time), or We have reasonable grounds to suspect that such Personal Data is untrue, inaccurate, not current or incomplete, We may not be able to provide You with continued access to our Website or our services. Your Personal Data collected and access to our Website is subject to the Terms of Use of our Website available at https://www.trivenikalasangam.org, and You are advised to read the same carefully in conjunction with this Privacy Policy.
9.3 Information Disclaimer
The information contained on our website is for general information purpose only and assures no accuracy or commitment on our behalf. Any reliance you place on such information is therefore strictly at your own risk.
9.4 Limitation of Liability
In no event will Triveni Kala Sangam or any of its officers and employees be liable for any loss or damage including without limitations, indirect, consequential loss or damage, or any loss or damage whatsoever arising from loss of data, or profits arising out of, or in connection with the use of the Website or the physical spaces at our centre.
10. Changes to Privacy Policy
10.1 Policy Updates
The Privacy Policy may be amended from time to time and will indicate the update by changing the 'Last Updated' date at the beginning of this privacy policy. This may be undertaken to reflect changes to the Website or applicable Indian laws. We recommend that you review this Privacy Policy each time you use the Website.
10.2 Effect of Updates
Once posted on our Website or otherwise notified to You, the revised Privacy Policy supersedes all previous versions, and continued access to and/or use of our Website after the date of such revision constitutes your acknowledgment of such changes and agreement to be legally bound by the terms of the revised Privacy Policy. Any new version of the Privacy Policy shall take effect and will govern the use of the Website and your relationship with us immediately upon the date of posting and will supersede all previous versions of the Privacy Policy.
11. Grievance Redressal Mechanism and Grievance Officer
For the purpose of grievance redressal or in the event You have any questions regarding our privacy practices or this Privacy Policy, please contact our Grievance Officer.