Privacy Policy
Our privacy policy is designed to provide transparency into our privacy practices and principles in a format that users can navigate, read and understand. We are dedicated to treating any personal information with care, trust and respect. Our privacy policy governs your use of theapplication, https://turbotorq.com/ (“website”), https://smartlessonplan.com/(“website”)and other associated services provided and managed by us. Please read this privacy policy carefully before using the application, website and other services in connection with the same. If you have questions or concerns regarding this privacy policy or our practices, please contact us at info@turbotorq.com.
Our privacy policy explains:
1. What Information We Collect
1) Information Provided by You
2) Automatically Collected Information
2. How We Use Your Information
3. How We Secure Personal Information
Cookies
Links
Updates
Comments
4. How We Store and Process User Data
Log Information
User Communications
5. Changes to This Privacy Policy
6. Your Consent
7. How You Can Contact Us About Privacy Questions
1. What Information We Collect
1) Information Provided by YouThe application, website and other services in connection with the same obtain the information you provide when you download and sign up for the application or use the website and other associated services. When you sign up, you provide your email address, grade and gender; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you contact us for help; (d) information you enter into our system when using the application, website or other associated services, such as uploading photos in the app. The mentioned information collected from you could be categorized as “personal information”, “sensitive personal information” and “associated information”. Personal information, sensitive personal information and associated information (each as individually defined under this Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (the “Data Protection Rules”)) shall collectively be referred to as ‘Information’ in this privacy policy. We may use the Information to contact you from time to time, to provide you with the Services, important information, required notices and marketing promotions. We will ask you when we need more information that personally identifies you (personal information) or allows us to contact you. We will not differentiate between who is using the device to access the application, website or other associated services, so long as the log in/access credentials match with yours. In order to make the best use of the application, website and other associated services, and enable your Information to be captured accurately on the same, it is essential that you have logged in using your own credentials. We will, at all times, provide the option to you to not provide the personal information or sensitive personal information, which we seek from you. Further, you shall, at any time while using the application, website or other associated services, also have an option to withdraw your consent given earlier to us to use such personal information or sensitive personal information. Such withdrawal of the consent is required to be sent in writing to us at the contact details provided in this privacy policy below. In such an event, however, we fully reserve the right not to allow further usage of the application, website or other associated services thereunder to you.
2) Automatically Collected Information
In addition, the application, website or other associated services may collect certain information automatically, including, but not limited to, your name, age, coarse geolocation information, namely your country/city, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the application, website or other associated services. As is true of most mobile applications, we also collect other relevant information as per the permissions that you provide. We use Google Payment to bill you for in-app purchases and services. This payment system does not retain, share, store or use personally identifiable information for any other purpose.
2. How We Use Your personal information
We use the collected information to analyse trends, to conduct research, to administer the application, website or other associated services, to learn about each user’s learning patterns and movements around the application, website or other associated services and to gather demographic information and usage behaviour about our user base as a whole. Aggregated and individual, anonymized and non-anonymized data may periodically be transmitted to external service providers to help us improve the application, website or other associated services. We will share your information with third parties only in the ways that are described below in this privacy policy. We may use the individual data and behaviour patterns combined with personal information to provide you with personalized content and better your learning objectives. Third parties provide certain services which we may use to analyse the data and information to personalize, drive insights and help us better your experience or reach out to you with more value-added applications, products, information and services. However, these third-party companies do not have any independent right to share this information. We do not sell, trade or share your information to any third party (except subsidiaries/affiliates of Turbotorq for related offerings) unless we have been expressly authorized by you either in writing or electronically to do so. We may at times provide aggregate statistics about our customers, traffic patterns, and related site information to reputable third parties, however, this information when disclosed will be in an aggregate form and does not contain any of your personally identifiable information. We will occasionally send email notices, messages or contact you to communicate about our application, website or other associated services, as they are considered an essential part of the application, website or other associated services you have chosen. We may disclose Information:
· as required by law, such as to comply with a subpoena, or similar legal process;
· to enforce applicable Terms and Conditions, including investigation of potential violations thereof;
· when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, address security or technical issues or respond to a government request;
· with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy policy;
· to protect against imminent harm to the rights, property or safety of the application, website, other associated services, Turbotorq, or its users or the public as required or permitted by law;
· with third-party service providers in order to personalize the application, website or other associated services for a better user experience and to perform behavioural analysis;
Any portion of the information containing personal data relating to minors provided by you shall be deemed to be given with the consent of the minor’s legal guardian. Such consent is deemed to be provided by your registration with us.
3. How We Secure Personal Information
We will provide you with the means to ensure that your personal information is correct and current. If you have filled out a user profile, we will provide an obvious way for you to access and change your profile from our application, website or other associated services. We adopt reasonable security measures to protect your password from being exposed or disclosed to anyone.
Cookies
We send cookies to your computer, thereby uniquely identifying your browser. Cookies are used to track your preferences, help you log in faster, and aggregated to determine user trends. This data is used to improve our offerings, such as providing more content in areas of greater interest to a majority of users. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some of our features and services may not function properly if your cookies are disabled.
Links
We may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve our customized content and your experience with the application, website or other associated services. Clicking on links may take you to sites outside our domain. We are not responsible for the privacy practices of other websites. We encourage our users to be aware when they leave our site to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by our Website.
Updates
We may update you by email to inform you about new service offerings from us or other information which we feel might be useful for you.
Comments
When you use certain features on our website and you post or share your personal information such as comments, will be available to all users, and will be in the public domain. All such sharing of information is done at your own risk. Please keep in mind that if you disclose personal information when posting on our website this information may become publicly available.
Security
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect the information we process and maintain. For example, we limit access to this information to authorized employees only who need to know that information in order to operate, develop or improve our application, website or other associated services. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
4. How We Store and Process User Data
We plan to retain user data while an account is active and for at least three years afterwards. We may alter this practice according to legal and business requirements. For example, we may lengthen the retention period for some data if needed to comply with law or voluntary codes of conduct. Unless otherwise prohibited, we may shorten the retention period for some types of data if needed to free up storage space.
Log Information
When you access our website, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, internet protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
User Communications
When you submit a contact form, send an email or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services.
5. Changes to This Privacy Policy
From time to time, we may make changes to this privacy policy to accommodate new technologies, regulations, industry practice or other purposes. When this occurs, we will post changes to this privacy policy here and update the effective date at the top of this document. We will obtain prior parental consent if any changes we make to this privacy policy affect users under the age of 13 in a way that would require consent under COPPA. You are advised to review this privacy policy regularly for any changes, as continued use is deemed approval of all changes.
6. Your Consent
By using our application, website or other associated services, you consent to have your personal information/user data transferred to and processed in the United States, South Korea, India, Ireland or any location of Amazon and Google cloud services. By signing up to our application, website or other associated services, you are expressly consenting to our collection, processing, storing, disclosing and handling of your information as set forth in this privacy policy now and as amended by us. Processing your information in any way, including, but not limited to, collecting, storing, deleting, using, combining, sharing, transferring and disclosing information, all of which activities will take place in India. If you reside outside India your information will be transferred, processed and stored in accordance with the applicable data protection laws of India.
7. How You Can Contact Us About Privacy Questions
If you have any questions about this privacy policy, the practices of Turbotorq, or your dealings with Turbotorq or our application, website or other associated services, regarding in case of any unresolved privacy or data use concern, you may contact at info@turbotorq.com or at the address below.