Privacy statement for our website

1. Introduction

This privacy statement provides information about the different types of personal data that PVNRTVU and/or, where relevant, its subsidiaries (together, ‘PVNRTVU’, ‘us’, ‘our’ or ‘we’) collects and the ways in which we use it and your data protection rights, including a right to object to some of the processing which we carry out. This privacy statement applies to all those who visit our Sites and interact with us online through our websites:

• pvnrtvukiosk.in
• and any other website run by us from time to time

(our ‘Sites’ and each a ’Site’).

We are not responsible for the content or privacy practices of other websites. Any external links to other websites are clearly identified as such.

2. Our role

PVNRTVU is the data controller in respect of any personal information we collect about you.

As a data controller, we are committed to protecting your privacy at all times in accordance with all applicable laws and regulations governing the use or processing of personal data, including (where applicable) the General Data Protection Regulation and any subsequent data protection legislation, which is in force in India at the relevant time.

3. When and what personal information do we collect?

(a) When you visit our Site(s)

The information collected about your visits to our Site(s) is usually limited to personal data such as:

1. the internet address (or IP address) of the device you used to access the Sites.
2. whether you reached the Sites using a search engine or if you clicked a link on another website.
3. the type of web browser you used and
4. the type of device you used to access the internet

We use this data for administrative and statistical purposes as well as to help us improve our Sites. More information about the data we collect about your visits to our Sites and the purposes for which we collect it can be found in our Cookie Policy.

Most websites use cookies in order to improve the visitor experience by enabling that website to ‘remember’ you, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (using a ‘persistent cookie’). Cookies may be set by the website you are visiting (‘first party cookies’) or they may be set by other websites who run content on the page you are viewing (‘third party cookies’). Some third parties, such as social media websites, may use cookies and other storage technologies to collect or receive information via our website and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt out of the collection and use of information for ad targeting. For further information on internet browser cookies please see our Cookie Policy.

The personal information collected by the ‘Facebook pixel’ cookie on our Site(s) includes:

1. HTTP header information which include information about the web browser or app used (eg user agent, locale country-level/language).
2. information regarding standard/optional events such as "Page view" or "App install", further object properties, as well as buttons clicked by site visitors, each according to configuration of the ‘Facebook pixel’. and
3. online identifiers including IP addresses and, insofar as provided, Facebook-related identifiers or device identifiers (such as mobile OS advertising IDs) as well as information on opt-out/limited ad tracking status.

We may use this data to measure, optimise and build audiences for advertising campaigns. You have the option to choose not to accept the ‘Facebook pixel’ or to remove it at any time from your browser whilst still accepting and keeping other essential cookies on our Site(s). More information on the ‘Facebook pixel’ can be found in our Cookie Policy.

(b) Information you give to us directly

We will collect certain personal information about you when you interact with us, for example when you complete an online form on one of our Sites (including our online ‘Contact Us’ forms and/or when you subscribe to our newsletter), or a printed form which you (or the person who fills it on your behalf) have downloaded from the Sites or obtained by participating in a PVNRTVU event or webinar, when you respond to a survey, when you register as a user on our Site(s), where you post entries on our online forums and every time you send us an email of contact us by other means.

We may collect the following information from you:

• Your full name and contact details, including email address, postal address, telephone number.
• Other information about your application provided on your application form.
• Information that we require to verify your identity, such as the details of your identity documentation and/or a photograph and/or copy of your passport, driving license or other identity documentation.
• Profile information if you register on our Site(s).
• Information about your communication preferences and/or

(c) Information we obtain indirectly

Your personal information (as listed above) may also be shared with us by third parties. For instance, we may receive it from your training provider.

4. Special categories of information

Data protection law recognises certain categories of personal information as sensitive and therefore requiring higher levels of protection. These categories of data include information about health and ethnicity.

We may collect and/or use special categories of data in connection with the provision of our services, for example in order to make adjustments for any disabilities you may have. We may also collect race, nationality or ethnicity data from you (should you choose to provide it) to ensure meaningful equal opportunity monitoring, reporting and treatment.

5. Children’s Privacy

The Sites are not intended for use by individuals under 13 years of age and so, if you are under 13, you must not use our Sites or provide any personal information to us without the express consent of your parent or guardian. If you are under 13 years of age, we may need to verify your parent or legal guardian’s consent for your use of the Sites.

6. How do we use your personal information?

We may use your personal information for one or more of the following purposes (depending on the nature of our relationship, and whether you are just visiting our Sites, interacting with us online or booking an exam):

• Providing, improving and personalising our services and our Sites.
• Retaining a record of incoming and outgoing communications (eg e-mails, telephone calls) - information in the e-mail we receive and send will not be disclosed to any third party without the permission of the sender unless otherwise permitted in accordance with the applicable data protection laws.
• Providing you access to downloadable support resources (if available on the relevant Site).
• Inviting you to participate in marketing and academic surveys, if you have specifically consented to receive such communications or if you are our existing or former customer.
• Administering registered user records.
• Using aggregated data for academic, research and training purposes to improve and develop our products and services.
• Administering our online forums (when such functionality is available on our Site(s)).
• Generating anonymous reports about the use of our Sites and our services (including about qualifications).
• Monitoring malpractice and preventing fraud or misuse of service.
• In response to requests by government or law enforcement authorities conducting an investigation.
• To further our charitable aim in general.
• To satisfy legal obligations which are binding on us.
• In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such personal information in connection with legal process or litigation).
• For the prevention of fraud or misuse of service and/or
• For the establishment, defense of enforcement of legal claims (including disclosure of such personal information as is required in connection with legal process or litigation).

7. Marketing communications and your rights

PVNRTVU operates a strict ‘opt-in’ policy for individuals. That means we will not send you any information unless you have requested to receive email/text/social media message updates from us.

For legal entities, such as companies, limited liability partnerships and other incorporated organisations, PVNRTVU operates, in compliance with the relevant data protection laws, an ‘opt-out’ policy. This means that we will continue to contact such businesses with news and information of our goods and services until we are informed that this communication is no longer required.

You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by clicking on the unsubscribe link in the relevant email or message or by emailing us at unsubscribe@pvnrtvukiosk.in. Once this information is received we will remove you from our direct marketing database

8. Lawful processing

We are required to rely on a lawful ground to collect and use the personal information that we have outlined above. The following are applicable, depending on the context:

Consent - Where you have provided your consent for our use of your personal information in a certain way. When we ask you for consent we will explain at that time the purpose for which we will use your personal information. For example, where we ask for your consent to send you our newsletter or information about our products, publications and programmes of events, or where we invite you to participate in marketing and academic surveys. Where applicable, we may require the consent of your parent or guardian.

Legal obligation - Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject. For example, to comply with our obligation to provide reasonable adjustments to candidates with disability or where we respond to requests by government, regulatory or law enforcement authorities conducting an investigation.

Contractual relationship - Where it is necessary for us to process your personal information in order to perform a contract to which you are a party or to take steps at your request prior to entering a contract.

Legitimate interests - We rely on this basis where applicable law allows us to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced, and does not unduly impact your rights. For instance, it is in our legitimate interest to process personal data of any person who contacts us with an enquiry, in order to respond to such enquiry. You can obtain information on our legitimate interest balancing tests by contacting us using the details set out later in this notice.

9. Sharing your Personal Data

We will not sell, rent or lease your personal information to others.

We will only share personal information we collect from you with:

• In relation to data collected by the ‘facebook pixel’ cookie only, to facebook ireland limited, to enable us to measure, optimise and build audiences for advertising campaigns.
• Other companies in our group such as our subsidiaries where they are providing support services to us.

We may disclose your personal information to selected third party processors (such as agents and our suppliers) but only in connection with our own processing purposes, as outlined above in paragraph 6. Any such third party will be required to use any personal data they receive from us in accordance with our instructions and the applicable data protection laws.

We reserve the right to disclose your personal information to third parties:

• In the event that we buy or sell any business or assets, in which case we will disclose your personal information to the prospective buyer or seller of such business or assets.
• If substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets.
• For auditing purposes eg finance audits where we employ chartered accountants.
• In connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.

11. International data transfers

Where we transfer personal information to and from India we adopt all relevant measures required by the data protection laws. As we sometimes use third parties to process personal information, it is possible that personal information we collect from you will be transferred to and stored in a location outside the India. Please note that certain countries outside of India have a lower standard of protection for personal information, including lower security protections.

Where your personal information is transferred, stored, and/or otherwise processed outside India in a country which does not offer an equivalent standard of protection to India, we will put in place appropriate transfer mechanisms as required under the relevant data protection laws and take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information. If you have any questions about the transfer of your personal information, please contact us.

12. Security of Data

PVNRTVU takes seriously its security obligations in respect of your personal data under the data protection laws. We will endeavour to take all reasonable steps to protect your personal information in order to prevent unauthorised access to, or alteration or destruction of personal data in our possession. All the personal information we collect is stored securely on servers and we use secure internet protocols and secure networks to protect data collection and processing.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that is transferred via the internet. If you have any particular concerns about your information, please contact us (see paragraph 15 below for our contact details).

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

13. How long do we keep your personal information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. Information which is necessary to verify or confirm may be kept by us indefinitely. For further detail about the periods for which we retain personal data and the criteria determined for setting these periods, please see our Data Retention Policy and Data Retention Schedule.

14. Your rights

Where we rely on your consent to use your personal information, you have the right to withdraw your consent at any time. Under certain circumstances, by law, you have the right to:

1. (a)Request access to your personal information (commonly known as a ‘data subject access request’). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it. For further details please refer to the Data Subject Access Request Policy.
2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
3. Request erasure of your personal information (often referred to as ’the right to be forgotten’). This enables you to ask us to delete or remove personal information where there is no appropriate reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
4. Object to the processing of your personal information where we are relying on a legitimate interest (ours or those of a third party) and there is something about your particular situation which causes you to object to processing on this ground. You also have the right to object if we are processing your personal information for direct marketing purposes.
5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
6. Request the transfer of your personal information to another party. Your rights described above may be limited in some instances where statutory exemptions apply, such as where they would infringe the rights of a third party or our rights or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. For example, under data protection laws, PVNRTVU is not required to provide personal data comprising information recorded by candidates in circumstances where its release would adversely affect our rights in the intellectual property and confidentiality or reveal the personal data of another data subject. We will inform you of the relevant exemptions we rely upon when responding to any request you make. Where we send you emails, if you decide you do not wish to receive any further emails from us, please tell us and we will remove you from the mailing list. At any point you can request to unsubscribe from our mailing by contacting us using the details listed at paragraph 15.

If you would like to exercise any of the above rights, please:

• email, call or write to us (see paragraph 15 below).
• let us have proof of your identity. This is to allow us to verify your identity and prevent disclosure to unauthorised third parties. and
• let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.
• If you have unresolved concerns, you have the right to complain to a data protection authority where you are based or where you believe a breach may have occurred.

15. Changes to this privacy statement

From time to time we may update this privacy statement. When we do, we will publish the updated version on the Sites. If material changes are made to this privacy statement we will notify you by email or by placing a prominent notice on the Sites. PVNRTVU trusts that you appreciate that we respect and value your right to privacy, and that our honesty and integrity shall mean that you will continue to trust us with your personal data, knowing that we will not use it for any inappropriate purpose.