Introduction
Your privacy is important to us. This Privacy Policy explains what personal data Scholastic Test Masters collects from you, through our interactions with you and through our services and how we use that data.
Scholastic Test Masters offers a wide range of products in the higher education sector, both in the physical and virtual realm, customized marketing solutions for the higher education sector and services developed to assist prospective MBA, Undergraduate and Masters students in every step of their journey to desired colleges.
Applicability under Indian Law
This Privacy Policy is issued in compliance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the rules made thereunder, as applicable in India.
To the extent this Privacy Policy refers to concepts or standards derived from other data protection frameworks, such references shall not override or dilute compliance with the DPDP Act.
References to other data protection regimes are illustrative and shall not override compliance with the DPDP Act.
Definitions
For the purposes of this Privacy Policy:
(a) “Data Fiduciary” means Scholastic Test Masters;
(b) “Data Principal” means the individual to whom the personal data relates;
(c) “Data Processor” means any person processing personal data on behalf of the Data Fiduciary;
(d) “Personal Data” shall have the meaning assigned under the DPDP Act, 2023.
Notice under Section 5 of the DPDP Act, 2023
Personal data is collected and processed for the purposes of providing educational counselling services, facilitating admissions-related interactions, marketing communications (subject to consent), analytics, and compliance with applicable law.
Data Principals may exercise their rights including access, correction, erasure, withdrawal of consent, grievance redressal, and nomination, in the manner set out below.
Information We Collect
Scholastic Test Masters collects data to operate effectively and provide you the best experience with our services. You will provide some of this data directly, such as when you sign up for our email communication or register for our program through our website or Landing pages. We also collect the information in other various ways such as on social media channels, in-person communication, or during the pre-counselling process when we may contact you for additional clarification regarding your profile or to organize one-to-one meetings for you. Categories of personal data collected and detailed purposes are set out below in this Privacy Policy.
We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this policy, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time, but have included:
- Database providers from trusted sources
- Social networks when you grant permission to Scholastic Test Masters Education to access your data
- Partners with which we offer co-branded services or engage in joint marketing activities
- Publicly-available sources such as open government databases or other data in the public domain
Personal data shall be processed only on the basis of free, specific, informed, unconditional and unambiguous consent provided through a clear affirmative action.
Consent may be withdrawn at any time, and such withdrawal shall be as easy as the manner in which consent was given. Withdrawal shall not affect the lawfulness of processing prior to such withdrawal.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a service, you may not be able to use that service.
The data we collect depends on the context of your interactions with Scholastic Test Masters. The data we collect can include the following:
- Name and contact data. We collect your first and last name, email address, postal address, phone number and other similar data to contact you..
- Credentials. We collect your username and password when you create your personal account on our websites.
- Demographic data. We collect data about you such as your date of birth, age, gender, country, citizenship and preferred language.
- Educational and professional background. We collect data about your employment history, education history and possibly your standardized test scores.
- Content. Information contained in your resume or CV, information you provide regarding your career and educational development interests and other information about your qualifications for MBA, Undergraduate or Masters programs.
- Videos and pictures. Photographs or video recordings may be taken during our physical events, we may use the visual or video captures of your person on our websites or promotional material.
- Other information you may provide to us, such as in feedback forms or through the “Contact Us” feature on our Sites.
- Information Collected By Automated Means When you visit our websites, we may collect certain information by automated means, such as cookies, web beacons and web server logs. The information we may collect in this manner includes:
- IP address
- Unique device identifier
- Browser characteristics
- Device characteristics
- Operating system
- Language preferences
- Referring URLs
- Information on actions taken on our websites
- Dates and times of visits to our sites and other usage statistics
A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links webpages to web servers and their cookies and is used to transmit information collected through cookies back to a web server. Through these automated collection methods, we may obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website.
As the visitor clicks through the website, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our websites. To the extent required by applicable law, we will obtain your consent before collecting personal information using cookies or similar automated means.
Scholastic Test Masters shall take reasonable steps to ensure that personal data processed is accurate, complete and up to date, having regard to the purpose for which such data is processed.
The providers of third-party apps, tools, widgets and plug-ins on our websites, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers.
Security Safeguards
Scholastic Test Masters implements reasonable technical and organisational measures to protect personal data in its possession or under its control, including where such processing is carried out on its behalf by Data Processors, to prevent unauthorised access, disclosure, alteration, loss or destruction of personal data.
Access to personal data is restricted to authorised personnel on a need-to-know basis and subject to confidentiality obligations.
Personal Data Breach
In the event of a personal data breach, Scholastic Test Masters shall take reasonable steps to mitigate harm and shall notify the Data Protection Board of India and affected Data Principals, where such notification is required under applicable law.
Processing of Children’s Personal Data
Where personal data relates to a Data Principal below the age of 18 years or such lower age as may be notified by the Government of India, such data shall be processed only upon obtaining verifiable consent of the parent or lawful guardian, in accordance with the DPDP Act and applicable rules.
Scholastic Test Masters does not undertake tracking, behavioural monitoring or targeted advertising directed at children.
How We Use the Information We Collect
Scholastic Test Masters uses the data we collect to operate our business and provide services, which include using data to improve our products and personalize your experience. We may also use the data to communicate with you, for example, informing you about your account, and product information or to send you promotional communication.
However, to enhance privacy, we have built in technological and procedural safeguards designed to prevent certain data combinations. For example, photographs or video recordings of our physical events will not be connected to your personal data.
Providing and improving our services: We use data to provide and improve the services we offer and perform essential business operations. Examples of such uses include the following:
Providing our services. We use data to make the connection between the prospective MBA and Masters candidates and the business schools / colleges, we connect students with our value added service partners such as discounted couriers, discounted foreign exchange services, discounted air tickets, education loans, discounted student health insurance etc. We use data to provide guidance services to the MBA and Masters candidates, including personalised candidate matching and advising, assessing candidates suitability for MBA and Masters programmes, and associate candidate qualifications for the specific programmes.
We use data also to perform data analytics, such as using information to match individuals and potential opportunities, and analyzing pipeline data (trends regarding higher education sector).
We use data to connect professionals who are interested in education sector and would like to use our services as mediator in their connection with business schools.Certain processing activities may be undertaken without consent where such processing qualifies as a legitimate use under Section 7 of the DPDP Act, including for compliance with law, prevention of fraud or responding to lawful requests by public authorities.
Product Improvement. We use data to continually improve our services. For example, we use your feedback forms to add features to our services or to change them according your experience.
Communication. We use data we collect to communicate with you and personalize our communication with you. For example, we may contact you by phone or email to inform you when we need clarification on the data in your personal account, when your subscription is ending or to discuss educational opportunities that you may be interested in, according to your preference settings.
Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications from Scholastic Test Masters and in relation with the services that our clients are providing.
In addition, we use information collected through cookies, web beacons, pixels, web server logs and other automated means for purposes such as (i) customizing our user’s use of our websites; (ii) delivering content tailored to our users’ interests and the manner in which our users use our websites; and (iii) managing our websites and other aspects of our business. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.
We also use third-party analytics services on our websites, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyse your use of our websites. The information collected through these means (including IP address) may be disclosed to these analytics providers and other relevant third parties who use the information, for example, to evaluate use of the websites. Such processing shall be subject to consent requirements under applicable law. To learn more about these analytics services and how to opt out, please visit the following sites and any sites contained in the country-specific addenda:
Google Analytics: https://tools.google.com/dlpage/gaoptout
This is in addition to consent-based controls provided under applicable law.
Information We Share
We do not disclose personal information we collect about you, except as described in this Global Privacy Policy or in separate notices provided in connection with particular activities.
- Personal data may be disclosed only to the extent necessary for the purposes stated in this Privacy Policy.
- Where third parties process personal data on our behalf, they shall act as Data Processors and shall be bound by contractual obligations to process such data only on documented instructions and in compliance with the DPDP Act.
- Scholastic Test Masters does not sell personal data.
- We share your personal data to provide the services you have requested or authorized. For example, we share your content with third parties when you tell us to do so, such as when you register for our events and express the will to meet business school representatives that provide more information about their educational opportunities
- We share personal data among Scholastic Test Masters controlled affiliates and subsidiaries
- We share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide value added services. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose
- We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets
In addition, we may disclose information about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a re-organization, dissolution, or liquidation).
Rights of Data Principals
- In accordance with the DPDP Act, Data Principals have the right to:
access information regarding personal data processed;
b. seek correction or erasure of personal data;
c. withdraw consent;
d. register grievances; and
e. nominate another person to exercise rights in the event of death or incapacity.
- To submit a request regarding your personal data by email, post or telephone, please contact us as indicated in the “How to Contact Us” section of this Privacy Policy.
- Data Principals may nominate another individual to exercise their rights by submitting a request through the grievance redressal mechanism.
Data Transfers
Personal data may be transferred outside India only in accordance with Section 16 of the DPDP Act, 2023 and subject to any restrictions or conditions notified by the Government of India.
Personal data shall not be transferred to any country or territory notified as restricted or prohibited.
Providing your personal data to others
We may share information about with third parties in some circumstances, including; (1) to a service provider or partner who meets our data protection standards; (2) with academic or non-profit researchers, with aggregation, anonymization, or pseudonomization; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) to protect the vital interest of others, when we have reason to believe that doing so will prevent harm to someone or illegal activities.
Our categories of service providers and partners are:
- Education Loan providers
- Forex Card
- Travel and Tours
- Student’s Insurance
- Courier Service
- Airlines
- Universities/ colleges
This section is to be read together with ‘Information We Share’ above.
Our Retention of Personal Data
We retain personal data for as long as necessary to provide services you have requested or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. Personal data shall be erased upon withdrawal of consent or once the specified purpose is fulfilled.
Grievance Redressal Mechanism
In accordance with the DPDP Act, grievances may be addressed to:
Name: Shaillendra Verma
Grievance Redressal Officer
Email:shailendra@siecindia.com
Mobile No.: 9818845348
Grievances shall be acknowledged and resolved within timelines prescribed under applicable law. A Data Principal must exhaust this mechanism before approaching the Data Protection Board of India.
Our Contact Us
If you have any questions or comments about this Privacy Policy, would like to exercise your rights or would like us to update information we have about you or your preferences, please contacts us at:
- Address: House no. E-71 , Ground Floor, South Extension Part 1, New Delhi , Bangali Sweet, New Delhi, South East Delhi , Delhi , 110049
- Phone: 9289429946
- Email: stm@siecindia.com
Updates to this privacy policy
We regularly review and, if appropriate, update this privacy policy from time to time as our services and use of personal data evolve. If we want to make use of your personal data in a way that we have not previously identified, we will contact you to provide information about this and, if necessary, ask for your consent.