1. Introduction
ATLAS SkillTech University hereinafter referred to as ATLAS is committed to security and management of personal data, to function effectively and successfully for the benefit of our stakeholders, customers and for the community. In doing so, it is essential that people’s privacy is protected through the lawful and appropriate means for handling the personal data. Therefore, we have implemented this privacy policy (hereinafter referred to as ‘‘policy’’).
2. Aim
This policy aims to protect personal data of the various stakeholders connected to our organization. This policy is aimed at providing individuals notice of the basic principles by which the ATLAS processes the personal data of individuals (“Personal Data”) who visits, uses, deals with and/or transacts through the website and includes a guest user and browser (hereinafter ‘you’, ‘user’).
3. Purpose and Scope
The purpose of this policy is to describe how ATLAS collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to https://www.atlasuniversity.edu.in/ (hereinafter the "website"). This policy is also designed to provide information on how ATLAS ensures data security, conducts data transfers and process requests from data subjects.
This policy control applies to all systems, people and processes that constitute the organization’s information systems, including board members, directors, employees and other third parties who have access to Personal Data available within ATLAS.
ATLAS is also committed to ensure that its employees conduct themselves in line with this, and other related, policies. Where third parties process data on behalf of ATLAS, ATLAS endeavours to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.
ATLAS offers Degree courses in Design & Innovation, Management & Entrepreneurship and Digital Technology (“hereinafter individually or collectively referred to as Program”). This Privacy Policy applies to all our services unless specified otherwise.
4. Types of Personal Data collected
The Personal Data that we collect about you depends on the context of your interactions with us, the products, services and features that you use, your location, and the applicable laws.
Personal Data is stored in personnel files or within the electronic records (on servers in India or other countries) of ATLAS. The following types of Personal Data may be held by ATLAS, as appropriate, on relevant individuals:
A. Personal Identification Data
B. Identification Data
C. Financial Data
D. Personal Characteristics
E. Contact Data
F. Education and Recruitment Data
G. Electronic Identification Data
H. Inquiries
I. User Generated Data
J. Marketing Data
K. Behavioural Data
We do not collect any payments information processed by third-party payment gateway providers.
5. Special Categories of Personal Data
Special Category of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade unions memberships, information about your health and genetic and biometric data.
We do not collect or process any special or sensitive Personal Data.
Should we specifically require “special” or “sensitive” Personal Data in connection with one or more of the uses described below, we will request your explicit consent to use the data in accordance with this policy and/or in the ways described at the point where you were asked to disclose the data.
Other legal basis for our processing of special category data may include, as permitted by applicable law, for scientific research, for employment, social security or social protection law, for reasons of substantial public interest, or as necessary for the establishment, exercise or defence of legal claims. If you voluntarily share with us or post/upload any “special” or “sensitive” Personal Data to this website for any other reason, you consent that we may use such data in accordance with applicable law and this policy. You can contact our DPO for more information about our processing of your Personal Data.
6. Sources of data collection
The data collected by the ATLAS is derived directly from the data provided by the user or by use of our sites.
Data Collected when You:
Data Collected from third parties
We receive Personal Data such as access or login details, profile picture or any other text / image in relation to your Personal Data which may be available with such third parties.
We also receive information about your visits to this platform and to other websites using pixel tags.
Third parties from whom we receive your Personal Data include, our service providers, other networks connected to our service, our advertising partners, our marketing and advertising affiliates, our educational partners, scholarship providers, analytics providers, recruiters and such other third-party sources.
7. Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
Furthermore, we may allow third-party advertising companies (such as Facebook, Google, Twitter, Quora and Bing) to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display Ads and record your activities, so they can show Ads that they consider relevant to you as you browse the Internet. These cookies store information about the content you are browsing, together with an identifier linked to your device or IP address.
How do we use cookies?
ATLAS uses cookies in a range of ways to improve your experience on our website, including:
What types of cookies do we use?
There are a few different types of cookies, however, our website uses:
How to manage cookies?
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Disabling some cookies form the website, may have a negative impact and may result in some non-availability of some features.
If you want to remove previously stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless and until you adjust your Internet browser setting as described above.
You can however obtain up-to-date information about blocking and deleting cookies via these links:
These opt-out mechanisms rely on cookies to remember your choices. If you delete your cookies, use another computer or device, or change browsers, you will need to repeat this process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests.
8. Data Analytics
We use Analytics tools and search information providers to measure how visitors interact with content on our website. We also use Facebook Custom Audiences to ask Facebook to show you ads that are customized based on your interaction with our websites or our Facebook applications and to measure how you interact with those ads. Additional information on how these services use such technologies can be found on Google’s website, Adobe’s website and Facebook’s website.
If you do not wish to have data relating to your visits to our websites collected through Google Analytics, you may opt-out by installing the Google Analytics opt-out browser add-on. You may opt-out of Facebook Custom Audiences by visiting Facebook’s opt-out page.
9. Aggregated Data
“Aggregated Data” means records that have been stripped of Personal Data and has been manipulated or combined to provide generalised, anonymous information. Your identity and personal information are not available in Aggregated Data. We combine your Personal Data on an anonymous basis with other information to generate Aggregated Data for internal and commercial use and for sharing with affiliates, subsidiaries and business partners for planning and marketing purposes.
10. Data protection principles
Where third parties process data on behalf of ATLAS, we endeavour to obtain assurances from such third parties that your Personal Data will be safeguarded consistently. We understand that it will be accountable for the processing, management and regulation, and storage and retention of all Personal Data held in the form of manual records and on computers.
All Personal Data obtained and held by the ATLAS will:
11. Legal basis for processing your Personal Data
Certain jurisdictions require that we have a lawful basis to justify our processing of your Personal Data.
Where applicable, the lawful basis that ATLAS relies upon to justify a particular processing activity may differ from the lawful basis used to justify a different processing activity.
ATLAS relies on the following lawful basis to process Personal Data, as permitted under applicable law:
12. Consent
We may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law.
Once consent is obtained from the individual to use his or her information for those purposes, ATLAS has the individual's implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new use is identified.
Consent may also be implied where a user is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client, customer, member does not opt-out.
Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), individuals can withhold or withdraw their consent for ATLAS to use their personal information in certain ways.
Further, by using this website/ acknowledging this privacy policy / by voluntarily providing us with your Personal Data, you consent to collection, storage, and processing of your Personal Data in accordance with this privacy policy and our Terms of Service.
If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Data, we may not be able to provide you the services that can be offered on our Platform.
13. Purpose of collecting Personal Data
We collect your Personal Data for the following purposes
14. Advertising and Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or if you provided us with your details and expressly consented to receiving that marketing.
We may use your Personal Identification, Identity, Contact, Electronic and User Generated Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
We also enter into agreements with third parties to serve Ads on our behalf across the internet, social networking sites and blogs. These third parties may collect Personal Data about your visits to our platform and your interactions with our products and use this information to target advertisements for goods and services.
Where electronic direct marketing communications are being sent, you have the option to opt-out in each communication sent, and this choice will be recognised and adhered to by us.
15. Disclosure of Personal Data
ATLAS is a global entity and may share the personal information collected or provide such access to other companies within the ATLAS group.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
In addition to the examples cited above, ATLAS also shares your Personal Data with:
|
Recipients |
Category(ies) of Personal Data we share |
Why we share it |
Location(s) |
|
Educational Partners
|
|
|
Global |
|
Employers; Sponsors and Scholarship Providers |
|
If you are taking a Program that is sponsored or paid for by your employer or a sponsor, or if you have availed a scholarship from a third-party scholarship provider, we may share your Personal Data and grades, evaluations or progress in the Program with your employer/sponsor/scholarship provider. This information may be shared at any time during the Program or afterwards. |
Global |
|
Service Providers |
|
We provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf strictly on confidential terms. They provide a variety of services to us, including billing, sales, marketing, test proctoring, couriers, mentoring, recruitment consulting, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, credit facilities, payment processing and legal services |
Global |
|
Third Parties |
|
|
Global |
|
Recruitment Service providers
|
|
If you opt for any of our recruitment services or if you participate in any of our recruitment activities, we will be sharing your information with recruiters and potential employers. |
Global |
|
Associate and Business Transfers |
|
We share your Personal Data with our associates for business purposes. ATLAS may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganisation of all or substantially all of the equity, business or assets of ATLAS to which your Personal Data relates |
Global |
16. Data subject rights
Some jurisdictions have provided individuals with certain rights in relation to the processing of their Personal Data. This is the case where you or the any of our subsidiaries or affiliates with which you interact is located in the European Union, though these rights may be available in other jurisdictions as well. These rights are not available to everyone, and they do not necessarily apply in all contexts. Depending on applicable law, you may have the right to:
To exercise a right that you believe you may be entitled to under applicable law, please write to us at [email protected]
We may need to verify your identity before we fulfil your request.
Please note that certain conditions in relation to processing of your rights, will vary as many countries have varying data privacy rights. Our response and further processing of request to exercise these rights will depend upon the law applicable in relation to the rights exercised by you. We may refuse requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, may compromise and ongoing investigation, or are impractical. It is our policy to never discriminate against you for exercising any of these rights.
You may have the right to complain to a data protection authority about our processing of your Personal Data. For more information, please contact your local data protection authority.
17. Our Policy on Children’s Data
Children’s data privacy is important to us. Our Sites are not intended for children Age to constitute a user as children is different for different jurisdictions. The age (for valid consent) of children varies across jurisdictions. For example, under GDPR child is a person aged 16 years or below, and in United Kingdom, children are someone who is aged 13, in case of Singapore and Qatar the valid age for providing consent is 18 years.
As a general policy, ATLAS does not engage in the collection, processing, storage, use, dissemination, and transfer of Personal Data of children.
In case such a collection becomes necessary for the performance of our contractual obligations, or when required under the concerned law, we shall notify you in a time-bound and appropriate manner, informing the purposes and reasons for such collection and seek your explicit consent, and where applicable, parental authorization, prior to the processing of such data.
We will take appropriate steps to delete any Personal Data of children’s that has been collected on our website without verified parental consent upon learning of the existence of such Personal Data, subject to conditions stipulated in the laws of applicable jurisdiction.
18. Data Security
ATLAS will ensure that appropriate technical and organizational measures are in place, supported by privacy impact and risk assessments, to ensure a high level of security for Personal Data, and secure environment for information held both manually and electronically.
ATLAS implements appropriate security measures designed to prevent unlawful or unauthorized processing of personal information and accidental loss of or damage to personal information. ATLAS maintains written security management policies and procedures designed to prevent, detect, contain, and correct violations of measures taken to protect the confidentiality, integrity, availability, or security of your Personal Information. These policies and procedures assign specific data security responsibilities and accountabilities to specific individuals, include a risk management program that includes periodic risk assessment and provide an adequate framework of controls that safeguard your personal information.
In addition, as part of its organizational security measures, employees at ATLAS must:
Personal Data should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised. Where Personal Data is recorded on any such device it should be protected by:
Failure to follow ATLAS’s rules on data security may be dealt with via ATLAS’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
We also take steps to ensure that our service providers, contractors and other third parties maintain similar level of data protection measures when processing your Personal Data. While we strive to secure your Personal Data, please note that 100% security of Personal Data cannot be guaranteed and that ATLAS shall not be liable for any misuse or loss of Personal Data carried out by third party cloud service provider.
19. International data transfers
Our website is primarily operated and managed on servers located and operated within India. However, owing to the global nature of ATLAS, your Personal Data may also be stored in third party data servers located in other countries where ATLAS provides its products and services.
ATLAS engages sub-contractors, service providers and other third parties for facilitating our products, service offerings and to offer support services to you, and your Personal Data may be transferred to servers of such sub-contractors, service providers and other third parties. Depending upon the location of our service providers, your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Further, your Personal Data may be transferred may be shared, disclosed, and transferred between various ATLAS group companies where such transfers are required for legitimate business reasons.
Where required under applicable law we will seek your express consent for such transfers. In all other cases, by consenting to this policy, you also provide consent to ATLAS to transfer your Personal Data to ATLAS affiliated companies, service providers or any third-party entity in locations around the world. We take steps to ensure that a degree of data protection which is similar to this policy is afforded to such Personal Data transferred.
Where ATLAS transfers your personal information internationally, we will comply with applicable legal requirements and where required we will enter into a data transfer agreement with the recipient of the personal information, which in the case of European Personal Data may include the Standard Contractual Clauses. In other cases, and where applicable, we shall enter into separate Data Processing Agreements with the third parties / service providers / contractors and such other recipients of Personal Data. Further ATLAS takes steps to ensure that transfers of Personal Data to any public authority cannot be massive, disproportionate, and indiscriminate in a manner that would go beyond what is necessary in a democratic society. In the event of conflicts between these and public authority requirements, the company will find a practical solution that fulfils the purpose of this Policy.
We are committed to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with our data privacy and security standards.
20. Records management
Records management refers to a set of activities required for systematically controlling the creation, distribution, use, maintenance, and disposition of recorded information maintained as evidence of business activities and transactions. It is impossible to be compliant with information law without robust records management policies and practises. Good records management practices ensure not only record quality, but that Personal Data is only kept for as long as necessary for its original purpose and help support data minimization.
21. Organization and Responsibilities
ATLAS will maintain records of data processing as required by the laws.
The ‘Data Protection Officer’ (DPO) has the specific responsibility of overseeing data protection and ensuring that we comply with the data protection principles and relevant legislation. The DPO will ensure that the Data Processing Register is kept up to date and demonstrates how the data protection principles are adhered to by our activities. Individual members of staff have a duty to contribute to ensure that the measures outlined in the Register are accurately reflected in our practice.
Our compliance with relevant policies and regulatory requirements in respect of data protection as part of our Data Management Strategy will be periodically monitored internally by a designated governance group. All employees, volunteers, consultants, partners, or other parties who will be handling Personal Data on behalf of ATLAS will be appropriately trained and supervised where necessary.
The collection, storage, use and sharing of Personal Data will be regularly reviewed by the Data Protection Officer, the Governance Group, and any relevant business area. We will adhere to relevant codes of conduct where they have been identified and discussed as appropriate.
Where there is likely to be a high risk to individuals rights and freedoms due to a processing activity, we will first undertake a Data Protection Impact Assessment (DPIA) and consult with the relevant supervisory authority prior to processing, if necessary.
22. Conflicts of Law
This Policy is intended to comply with the laws and regulations in the place of establishment and of the countries in which ATLAS operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.
23. Retention of Personal Data
We retain your Personal Data, not longer than necessary for the purposes for which it was collected. The length of time to retain Personal Data depends on the purposes for which we collect and use it and/or as may be required to comply with applicable laws, to establish, exercise, or defend our legal rights.
The users can exercise their rights enumerated herein. Also, if in case required to extend the period of retention of such data, we shall obtain your consent for the same. Further, we may also dispose the data prior to completion of the period of retention, if the purpose for which it was collected is exhausted.
24. Procedures
ATLAS has taken the following steps to protect the Personal Data of relevant stakeholders, which it holds or to which it has access:
– the comprehensive reviewing and auditing of its data protection
systems and procedures
– overviewing the effectiveness and
integrity of all the data that must be protected.
– There are clear
lines of responsibility and accountability for these different
roles.
25. Breach notification
Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the relevant supervisory authority within 72 hours of ATLAS becoming aware of it and may be reported in more than one instalment. Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual. If the breach is sufficient to warrant notification to the public, ATLAS will do so without undue delay.
26. External Links on our website
For your convenience we may provide links to sites operated by organizations other than ATLAS ("Third Party Sites") that we believe may be of interest to you. We do not disclose your Personal Data to these Third-Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third-Party Sites. If you choose to click on a link to one of these Third-Party Sites, you should review the privacy policy posted on the other websites to understand how that Third-Party website collects and uses your Personal Data.
27. Use of this website and our Terms of Service
This website is the property of the ATLAS. Our Terms of Use and this Privacy Policy collectively govern the use of the Platform and the Programs offered by ATLAS. This Privacy Policy shall form a part of the Terms by way of reference. By using this website and the information offered herein, you indicate your acceptance of these Terms of Use.
28. Updates to this policy
We may update our Privacy Policy from time to time. We will take reasonable steps to inform all ATLAS entities, Customers, Business Partners, and other data subjects affected by the revisions by posting the new Privacy Policy on this page and/or via email.
29. Data Controller/ ATLAS Details
The "Data Controller" (i.e., ATLAS) means the entity that will make the decisions about how your data is used and that is responsible for deciding how it holds personal information about you.
Since ATLAS is made up of different legal entities, the entity who will be the controller for your data is dependent on the situation where your Personal Data is collected.
30. Data Protection Officer
ATLAS, in accordance with the applicable laws, and all applicable rules made thereunder, has appointed a Data Protection Officer; who can be reached at the details below:
Name: Mr. Imran Kapadia
Email Address: [email protected]
ATLAS SkillTech University hereinafter referred to as ATLAS is committed to security and management of personal data, to function effectively and successfully for the benefit of our stakeholders, customers and for the community. In doing so, it is essential that people’s privacy is protected through the lawful and appropriate means for handling the personal data. Therefore, we have implemented this privacy policy (hereinafter referred to as ‘‘policy’’).
This policy aims to protect personal data of the various stakeholders connected to our organization. This policy is aimed at providing individuals notice of the basic principles by which the company processes the personal data of individuals (“Personal Data”) who visits, uses, deals with and/or transacts through the website and includes a guest user and browser (hereinafter ‘you’, ‘user’).
The purpose of this policy is to describe how ATLAS collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to https://www.atlasuniversity.edu.in/ (hereinafter the “website”). This policy is also designed to provide information on how ATLAS ensures data security, conducts data transfers and process requests from data subjects.
This policy control applies to all systems, people and processes that constitute the organization’s information systems, including board members, directors, employees and other third parties who have access to Personal Data available within ATLAS.
The company is also committed to ensure that its employees conduct themselves in line with this, and other related, policies. Where third parties process data on behalf of ATLAS, the Company endeavours to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.
ATLAS offers Degree courses in Design & Innovation, Management & Entrepreneurship and Digital Technology (“hereinafter individually or collectively referred to as Program”). This Privacy Policy applies to all our services unless specified otherwise.
The Personal Data that we collect about you depends on the context of your interactions with us, the products, services and features that you use, your location, and the applicable laws.
Personal Data is stored in personnel files or within the electronic records (on servers in India or other countries) of ATLAS. The following types of Personal Data may be held by the Company, as appropriate, on relevant individuals:
We do not collect any payments information processed by third-party payment gateway providers.
Special Category of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade unions memberships, information about your health and genetic and biometric data.
We do not collect or process any special or sensitive Personal Data.
Should we specifically require “special” or “sensitive” Personal Data in connection with one or more of the uses described below, we will request your explicit consent to use the data in accordance with this policy and/or in the ways described at the point where you were asked to disclose the data.
Other legal basis for our processing of special category data may include, as permitted by applicable law, for scientific research, for employment, social security or social protection law, for reasons of substantial public interest, or as necessary for the establishment, exercise or defence of legal claims. If you voluntarily share with us or post/upload any “special” or “sensitive” Personal Data to this website for any other reason, you consent that we may use such data in accordance with applicable law and this policy. You can contact our DPO for more information about our processing of your Personal Data.
The data collected by the company is derived directly from the data provided by the user or by use of our sites.
We receive Personal Data such as access or login details, profile picture or any other text / image in relation to your Personal Data which may be available with such third parties.
We also receive information about your visits to this platform and to other websites using pixel tags.
Third parties from whom we receive your Personal Data include, our service providers, other networks connected to our service, our advertising partners, our marketing and advertising affiliates, our educational partners, scholarship providers, analytics providers, recruiters and such other third-party sources.
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
Furthermore, we may allow third-party advertising companies (such as Facebook, Google, Twitter, Quora and Bing) to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display Ads and record your activities, so they can show Ads that they consider relevant to you as you browse the Internet. These cookies store information about the content you are browsing, together with an identifier linked to your device or IP address.
ATLAS uses cookies in a range of ways to improve your experience on our website, including:
There are a few different types of cookies, however, our website uses:
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Disabling some cookies form the website, may have a negative impact and may result in some non-availability of some features.
If you want to remove previously stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless and until you adjust your Internet browser setting as described above.
You can however obtain up-to-date information about blocking and deleting cookies via these links:
These opt-out mechanisms rely on cookies to remember your choices. If you delete your cookies, use another computer or device, or change browsers, you will need to repeat this process. In addition, opting out of interest-based ads will not opt you out of all ads, but rather only those ads that are personalized to your interests.
We use Analytics tools and search information providers to measure how visitors interact with content on our website. We also use Facebook Custom Audiences to ask Facebook to show you ads that are customized based on your interaction with our websites or our Facebook applications and to measure how you interact with those ads. Additional information on how these services use such technologies can be found on Google’s website, Adobe’s website and Facebook’s website.
If you do not wish to have data relating to your visits to our websites collected through Google Analytics, you may opt-out by installing the Google Analytics opt-out browser add-on. You may opt-out of Facebook Custom Audiences by visiting Facebook’s opt-out page.
“Aggregated Data” means records that have been stripped of Personal Data and has been manipulated or combined to provide generalised, anonymous information. Your identity and personal information are not available in Aggregated Data. We combine your Personal Data on an anonymous basis with other information to generate Aggregated Data for internal and commercial use and for sharing with affiliates, subsidiaries and business partners for planning and marketing purposes.
Where third parties process data on behalf of ATLAS, we endeavour to obtain assurances from such third parties that your Personal Data will be safeguarded consistently. We understand that it will be accountable for the processing, management and regulation, and storage and retention of all Personal Data held in the form of manual records and on computers.
All Personal Data obtained and held by the Company will:
Certain jurisdictions require that we have a lawful basis to justify our processing of your Personal Data.
Where applicable, the lawful basis that ATLAS relies upon to justify a particular processing activity may differ from the lawful basis used to justify a different processing activity.
ATLAS relies on the following lawful basis to process Personal Data, as permitted under applicable law:
We may obtain your consent to collect and use certain types of Personal Data when we are required to do so by law.
Once consent is obtained from the individual to use his or her information for those purposes, ATLAS has the individual’s implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new use is identified.
Consent may also be implied where a user is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client, customer, member does not opt-out.
Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), individuals can withhold or withdraw their consent for ATLAS to use their personal information in certain ways.
Further, by using this website/ acknowledging this privacy policy / by voluntarily providing us with your Personal Data, you consent to collection, storage, and processing of your Personal Data in accordance with this privacy policy and our Terms of Service.
If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Data, we may not be able to provide you the services that can be offered on our Platform.
We collect your Personal Data for the following purposes
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or if you provided us with your details and expressly consented to receiving that marketing.
We may use your Personal Identification, Identity, Contact, Electronic and User Generated Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.
We also enter into agreements with third parties to serve Ads on our behalf across the internet, social networking sites and blogs. These third parties may collect Personal Data about your visits to our platform and your interactions with our products and use this information to target advertisements for goods and services.
Where electronic direct marketing communications are being sent, you have the option to opt-out in each communication sent, and this choice will be recognised and adhered to by us.
ATLAS is a global company and may share the personal information collected or provide such access to other companies within the ATLAS group.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
In addition to the examples cited above, ATLAS also shares your Personal Data with:
| Recipients | Category(ies) of Personal Data we share | Why we share it | Location(s) |
Educational Partners University or company offering the course External graders Mentors | Personal Identification Data Personal Characteristics Data Contact Data User generated data | Evaluate and assess your progress and performance in the Program report on your progress in the Program enable them to issue a certificate to you on completion of the Program | Global |
Employers; Sponsors and Scholarship Providers | Personal Identification Data Personal Characteristics Data Contact Data User generated data | If you are taking a Program that is sponsored or paid for by your employer or a sponsor, or if you have availed a scholarship from a third-party scholarship provider, we may share your Personal Data and grades, evaluations or progress in the Program with your employer/sponsor/scholarship provider. This information may be shared at any time during the Program or afterwards. | Global |
Service Providers | Personal Identification Data Personal Characteristics Data Contact Data User generated data Financial Data Electronic Identification Data Data generated from inquires Marketing Data | We provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf strictly on confidential terms. They provide a variety of services to us, including billing, sales, marketing, test proctoring, couriers, mentoring, recruitment consulting, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, credit facilities, payment processing and legal services | Global |
Third Parties | Personal Identification Data Personal Characteristics Data Contact Data User generated data Financial Data Electronic Identification Data Data generated from inquires Marketing Data Education and Recruitment Data Behavioural Data | we share certain Personal Data and materials with third parties including, but not limited to, service providers such as Facebook or WhatsApp in order to provide you services that you have requested or services that ATLAS provides in conjunction with the Programs to arrange and provide networking activities to previous, current or potential students of ATLAS may share information that can be used to directly contact you with third-party business partners, such as companies that may be offering products or services or other opportunities that may be of interest to you. To third party business partners | Global |
Recruitment Service providers Recruitment agency Potential employers | Personal Identification Data Personal Characteristics Data Contact Data User generated data Education and Recruitment Data | If you opt for any of our recruitment services or if you participate in any of our recruitment activities, we will be sharing your information with recruiters and potential employers. | Global |
Associate and Business Transfers | Personal Identification Data Personal Characteristics Data Contact Data User generated data | We share your Personal Data with our associates for business purposes. ATLAS may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganisation of all or substantially all of the equity, business or assets of ATLAS to which your Personal Data relates | Global |
Some jurisdictions have provided individuals with certain rights in relation to the processing of their Personal Data. This is the case where you or the any of our subsidiaries or affiliates with which you interact is located in the European Union, though these rights may be available in other jurisdictions as well. These rights are not available to everyone, and they do not necessarily apply in all contexts. Depending on applicable law, you may have the right to:
To exercise a right that you believe you may be entitled to under applicable law, please write to us at [email protected]
We may need to verify your identity before we fulfil your request.
Please note that certain conditions in relation to processing of your rights, will vary as many countries have varying data privacy rights. Our response and further processing of request to exercise these rights will depend upon the law applicable in relation to the rights exercised by you. We may refuse requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, may compromise and ongoing investigation, or are impractical. It is our policy to never discriminate against you for exercising any of these rights.
You may have the right to complain to a data protection authority about our processing of your Personal Data. For more information, please contact your local data protection authority.
Children’s data privacy is important to us. Our Sites are not intended for children Age to constitute a user as children is different for different jurisdictions. The age (for valid consent) of children varies across jurisdictions. For example, under GDPR child is a person aged 16 years or below, and in United Kingdom, children are someone who is aged 13, in case of Singapore and Qatar the valid age for providing consent is 18 years.
As a general policy, our company does not engage in the collection, processing, storage, use, dissemination, and transfer of Personal Data of children.
In case such a collection becomes necessary for the performance of our contractual obligations, or when required under the concerned law, we shall notify you in a time-bound and appropriate manner, informing the purposes and reasons for such collection and seek your explicit consent, and where applicable, parental authorization, prior to the processing of such data.
We will take appropriate steps to delete any Personal Data of children’s that has been collected on our website without verified parental consent upon learning of the existence of such Personal Data, subject to conditions stipulated in the laws of applicable jurisdiction.
ATLAS will ensure that appropriate technical and organizational measures are in place, supported by privacy impact and risk assessments, to ensure a high level of security for Personal Data, and secure environment for information held both manually and electronically.
ATLAS implements appropriate security measures designed to prevent unlawful or unauthorized processing of personal information and accidental loss of or damage to personal information. ATLAS maintains written security management policies and procedures designed to prevent, detect, contain, and correct violations of measures taken to protect the confidentiality, integrity, availability, or security of your Personal Information. These policies and procedures assign specific data security responsibilities and accountabilities to specific individuals, include a risk management program that includes periodic risk assessment and provide an adequate framework of controls that safeguard your personal information.
In addition, as part of its organizational security measures, employees at ATLAS must:
Personal Data should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised. Where Personal Data is recorded on any such device it should be protected by:
Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
We also take steps to ensure that our service providers, contractors and other third parties maintain similar level of data protection measures when processing your Personal Data. While we strive to secure your Personal Data, please note that 100% security of Personal Data cannot be guaranteed and that ATLAS shall not be liable for any misuse or loss of Personal Data carried out by third party cloud service provider.
Our website is primarily operated and managed on servers located and operated within India. However, owing to the global nature of ATLAS, your Personal Data may also be stored in third party data servers located in other countries where ATLAS provides its products and services.
ATLAS engages sub-contractors, service providers and other third parties for facilitating our products, service offerings and to offer support services to you, and your Personal Data may be transferred to servers of such sub-contractors, service providers and other third parties. Depending upon the location of our service providers, your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Further, your Personal Data may be transferred may be shared, disclosed, and transferred between various ATLAS group companies where such transfers are required for legitimate business reasons.
Where required under applicable law we will seek your express consent for such transfers. In all other cases, by consenting to this policy, you also provide consent to ATLAS to transfer your Personal Data to ATLAS affiliated companies, service providers or any third-party entity in locations around the world. We take steps to ensure that a degree of data protection which is similar to this policy is afforded to such Personal Data transferred.
Where ATLAS transfers your personal information internationally, we will comply with applicable legal requirements and where required we will enter into a data transfer agreement with the recipient of the personal information, which in the case of European Personal Data may include the Standard Contractual Clauses. In other cases, and where applicable, we shall enter into separate Data Processing Agreements with the third parties / service providers / contractors and such other recipients of Personal Data. Further as the Company takes steps to ensure that transfers of Personal Data to any public authority cannot be massive, disproportionate, and indiscriminate in a manner that would go beyond what is necessary in a democratic society. In the event of conflicts between these and public authority requirements, the company will find a practical solution that fulfils the purpose of this Policy.
We are committed to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with our data privacy and security standards.
Records management refers to a set of activities required for systematically controlling the creation, distribution, use, maintenance, and disposition of recorded information maintained as evidence of business activities and transactions. It is impossible to be compliant with information law without robust records management policies and practises. Good records management practices ensure not only record quality, but that Personal Data is only kept for as long as necessary for its original purpose and help support data minimization.
ATLAS will maintain records of data processing as required by the laws.
The ‘Data Protection Officer’ (DPO) has the specific responsibility of overseeing data protection and ensuring that we comply with the data protection principles and relevant legislation. The DPO will ensure that the Data Processing Register is kept up to date and demonstrates how the data protection principles are adhered to by our activities. Individual members of staff have a duty to contribute to ensure that the measures outlined in the Register are accurately reflected in our practice.
Our compliance with relevant policies and regulatory requirements in respect of data protection as part of our Data Management Strategy will be periodically monitored internally by a designated governance group. All employees, volunteers, consultants, partners, or other parties who will be handling Personal Data on behalf of ATLAS will be appropriately trained and supervised where necessary.
The collection, storage, use and sharing of Personal Data will be regularly reviewed by the Data Protection Officer, the Governance Group, and any relevant business area. We will adhere to relevant codes of conduct where they have been identified and discussed as appropriate.
Where there is likely to be a high risk to individuals rights and freedoms due to a processing activity, we will first undertake a Data Protection Impact Assessment (DPIA) and consult with the relevant supervisory authority prior to processing, if necessary.
This Policy is intended to comply with the laws and regulations in the place of establishment and of the countries in which company operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.
We retain your Personal Data, not longer than necessary for the purposes for which it was collected. The length of time to retain Personal Data depends on the purposes for which we collect and use it and/or as may be required to comply with applicable laws, to establish, exercise, or defend our legal rights.
The users can exercise their rights enumerated herein. Also, if in case required to extend the period of retention of such data, we shall obtain your consent for the same. Further, we may also dispose the data prior to completion of the period of retention, if the purpose for which it was collected is exhausted.
The Company has taken the following steps to protect the Personal Data of relevant stakeholders, which it holds or to which it has access:
– the comprehensive reviewing and auditing of its data protection systems and procedures
– overviewing the effectiveness and integrity of all the data that must be protected.
– There are clear lines of responsibility and accountability for these different roles.
Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the relevant supervisory authority within 72 hours of the Company becoming aware of it and may be reported in more than one instalment. Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual. If the breach is sufficient to warrant notification to the public, the Company will do so without undue delay.
For your convenience we may provide links to sites operated by organizations other than ATLAS (“Third Party Sites”) that we believe may be of interest to you. We do not disclose your Personal Data to these Third-Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third-Party Sites. If you choose to click on a link to one of these Third-Party Sites, you should review the privacy policy posted on the other websites to understand how that Third-Party website collects and uses your Personal Data.
This website is the property of the ATLAS. Our Terms of Use and this Privacy Policy collectively govern the use of the Platform and the Programs offered by ATLAS. This Privacy Policy shall form a part of the Terms by way of reference. By using this website and the information offered herein, you indicate your acceptance of these Terms of Use.
We may update our Privacy Policy from time to time. We will take reasonable steps to inform all ATLAS entities, Customers, Business Partners, and other data subjects affected by the revisions by posting the new Privacy Policy on this page and/or via email.
The “Data Controller” (i.e., ATLAS) means the entity that will make the decisions about how your data is used and that is responsible for deciding how it holds personal information about you.
Since ATLAS is made up of different legal entities, the entity who will be the controller for your data is dependent on the situation where your Personal Data is collected.
The company, in accordance with the applicable laws, and all applicable rules made thereunder, has appointed a Data Protection Officer; who can be reached at the details below:
Name: Mr. Imran Kapadia
Email Address: [email protected]
