Privacy Policy

This is the privacy policy (“Privacy Policy”) that governs how Unherd.in (“Unherd”, “company,” “we”, “our” or “us”), uses personal information (as defined below) that it collects, receives and stores about individuals, in connection with the use of the website www.unherd.in, and any other associated websites that Unherd operates. Unherd.in is intended to help students make informed career choices through experiential learning and mentorship programs.

Unherd.in aims at ensuring students gain first-hand experience, in the field of their interest, by interacting with industry
professionals and learning from them.

Unherd.in respects your privacy and is committed to protecting your personal data. You can download a pdf version of the policy here. Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

IMPORTANT INFORMATION AND WHO WE ARE:
1. Purpose of this privacy policy:
This privacy policy aims to give you information on how Unherd.in collects and processes your personal data through your use of this website, including any data you may provide through this website such as when you sign up to our newsletter or fill in an application form to join a program.

This website is not intended for children below the age of 13 years and we do not, knowingly, collect data relating to children below the age of 13.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

a) Controller
Unherd.in is the controller and responsible for your personal data (collectively referred to as [“Unherd”], “company’, “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, please contact us by dropping a mail to contact@unherd.in

b) Changes to the privacy policy and your duty to inform us of changes:
We review our privacy policy regularly and this version was last updated on 23rd August 2020. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

c) Third-party links:
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you:
a) Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
b) We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes [first name, maiden name, last name, username or similar identifier, title, date of birth and gender].
• Contact Data includes [address, email address and telephone numbers].
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
• Usage Data includes [information about how you use our website and services].
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
• Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
c) If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with suitable mentorship programs/courses/classes). In this case, we may have to cancel your admission but we will notify you in advance.

3. How is your personal data collected?
We use different methods to collect data such as:
a) Direct interactions: You may give us your [Identity, Contact information etc] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for a program
• fill an application form for admission or key in a query
• subscribe to our newsletter and other services
• request marketing or promotions to be sent to you
• enter a competition, promotion or survey conducted by Unherd.in
• give us feedback or contact us.
b) Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
c) Third parties or publicly available sources: We might receive personal data about you from various third parties and public sources as set out below –
• analytics and SEO/SEM providers such as Google, SEMRush etc.
• form building providers like Google forms, Typeform, Mailchimp, Cognito forms
• advertising social media networks such as Facebook, Instagram, Twitter, Linkedin
• search information providers such as Google contact, financial and transaction data from providers of technical, payment and delivery services such as Google Pay.

4. How we use your personal data:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where your personal data needs to be shared with Unherd’s partners, mentors and third party entities.
• Where we need to comply with a legal obligation.

NOTE: Unherd.in is not responsible/ liable for how mentors and partners use the personal data shared with them.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

a) Marketing & Promotional offers
We may use your Identity, Contact, Technical, Usage and Profile 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 programs may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or are attending our mentorship programs and have not opted out of receiving that marketing.
b) Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
c) Opting out
Where you opt out of receiving these marketing messages, this will not apply to your personal data that you provided to us.
d) Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click here
e) Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data:
a) We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Mentors, Partners
b) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
c) 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.
d) International transfers:
We share your personal data within the Unherd group. This will involve transferring your data outside India at times. Many of our external third parties are based outside India so their processing of your personal data will involve a transfer of data outside of India. Whenever we transfer your personal data out of India, we ensure a similar high degree of protection is afforded to it.

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the applicable international standards.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of India.

6. Data security:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. However, Unherd.in is not responsible/ liable for how mentors and partners use the personal data shared with them.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention:
a) How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

[Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us OR set out in the table [Purposes for which we will use your personal data] above].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your
request in these circumstances.

b) What we may need from you:
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

c) Time limit to respond:
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the
impact on you unless we have your consent or are otherwise required or permitted to by law. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties:
a) Internal Third Parties
• Other companies in the Unherd Group [acting as joint controllers or processors] and who are based inside India or outside and provide IT and system administration services and undertake leadership reporting].
b) External Third Parties
• Service providers acting as processors based in [inside India or outside India] who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Bangalore, India who provide [consultancy, banking, legal, insurance and accounting services].
• Revenue & Customs, regulators and other authorities acting as processors or joint controllers based India who require reporting of processing activities in certain circumstances.

Purposes for which we will use your personal data:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Information Collected by Unherd When and Where We Collect this Information Mandatory/ Optional How This Personal Information is used by Unherd
First Name, Last Name, and Email
Address
Upon registration Mandatory We may use your email to send you important information regarding the Site, changes of our terms, conditions, and policies and/or other administrative information. Because this information may be important to your use of the Site, if you have provided an email, you may not optout of receiving such communications.
Birthdate Upon registration Mandatory For our internal business purposes, including for data analysis and audits. We
may use this data, in conjunction with other sources of data (for example, responses to surveys we administer to stakeholders) to assess the quality and impact of our programs, and inform you of program which may be of interest to you, and ongoing program planning and improvements.
Affiliations (School,
Employment, Community-Based
Organizations)
Upon registration Mandatory Same as above for “Birthdate”.
Demographic
Information
Upon
registration
Mandatory Same as above for “Birthdate”.
Contact Information (including full name, email address, or physical mailing
address)
Upon contacting Unherd or submitting a query requesting information from unherd Optional This information may be collected when users submit an online form that we make available or send an email to us. It is used to contact a user interested in receiving information about our Site in general or our different programs in particular.
Information Generated from Log Files (including
information such as internet protocol (IP) addresses, type of browser, Internet Service Providers
(ISP), date/time
stamp, referring/exit
pages, clicked pages, and any other information your browser may send to
us)
Upon usage of Site Mandatory We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.
Data from Cookies Upon usage of Site Optional Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. “Cookies” are small text files that may be used, for example, to collect information about activity on the
Site. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. This data is collected in order for us to provide our site and keep you logged in. Certain cookies and other technologies may serve to recall Personal Information, such as
an IP address, previously indicated by a user
Site Usage Information from Google Analytics (including how often
you visit the Site, what pages you visit within the Site, and what other sites you used prior to coming to this Site)
Upon usage of Site Mandatory The information we receive from Google Analytics is used to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/.
Personal Information of Others (Email Addresses, Third Party Website Account User Names/ID) Upon sending invitations to others through the Site Optional This data is used in order to enable you to invite your friends to use our Site by
sending them an invitation email or message. Inviting friends may be done by
either using the Site to send or post an invitation message via your Third Party
Account and/or by using the Site to send an invitation email to your friend’s external email address (for example, a Gmail address).
Criminal & Identity
Background Screenings
Upon application for employment or volunteer position Mandatory Applicants for adults administering and/or hosting programs (Mentors) are required to provide personal information to verify eligibility, which is reviewed internally by Unherd team members.
Financial Documents for Income Verification Upon scholarship application Mandatory Applicants for scholarship application upload documents to confirm program
eligibility, which is reviewed internally by Unherd Staff.

YOUR LEGAL RIGHTS
You have the right to:
1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal
data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
6. If you want us to establish the data’s accuracy.
7. Where our use of the data is unlawful but you do not want us to erase it.
8. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
9. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
10. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
11. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

We are committed to protecting your privacy. Protecting your privacy online is an evolving area, and we are constantly evolving our Service to meet these demands. If you have any comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing and using, please contact us at contact@unherd.in