This Information is obtained by Turnkey, its group companies and Turnkey Affiliates in relation to our services offered on our website: www.turnkeylearning.com
- HOW TO CONTACT US
We have a customer support team that will address your grievances through email,
chat and voice call. For queries to be addressed through email, users can reach out to Sirisha Ramesh. The chat and voice call details are as follows: 1-800-103-8627
For data related issues, users can contact our IT Head/Security officer at:
Users can also contact our respective Grievance Officer for any kind of grievance related to the content, features, offers, subscription and/or payment related queries. Our Grievance Officer can be reached at:
- INFORMATION COLLECTED FROM YOU
We collect the following Information about You, such as: –
- Non-Personal Information: You can access Our Website without disclosing any Personal Information, although the Services, in whole or part, require You to provide your personal Information. If you choose not to use Our Services, then the only Information collected will be ‘Non-Personal Information’ i.e. the Information that cannot be used to identify You. Non-Personal Information may include the last web pages you have visited.
- Anonymized Information: We collect anonymous Information from You when you access Our Website to monitor traffic and fix bugs. For example, we collect information like web requests, the data sent in response to such requests, the internet protocol address, the browser type, the browser language, and a timestamp for the request.
- Personally Identifiable Information: We also collect through our Website, or through third-party platforms being hosted by us, Personal Information or SPD that you provide to us when you create an Account for any educational programs or Course(s), participate in our public forums, avail our chat room services, send you emails, call you, participate in online events such as live lectures, webinars etc. and/or receive other services on or through our Website or through any our Educational Partners’ platform. This Information may include, among other things, your name, billing address, email address, contact number, tax identification numbers, login credentials (in the case of registered users), educational qualification(s), salary Information, working goals, post-qualification experience, current organization, and photographs. We collect demographic Information such as your gender, socio-economic status, and other similar personal Information. We may also collect your bank account Information. Apart from the aforementioned, we do not collect any of your financial Information, and all payments are processed by third-party payment gateway providers.
- Turnkey directly collects Information when you:
- create a Turnkey Account and fill the Application Form;
- enroll and participate in online courses;
- send email messages to Turnkey (including messages to learner support);
- participate in user surveys; and
- participate in public forums, webinars, and other interactive experiences on the Turnkey’s Website.
- Information You give us: We collect, Personal Information and/or SPD and/or such other Information such as first and last name, gender, e-mail, contact number, professional title, company name, educational institution or organization name, and password. This includes Information provided to Turnkey in the course of routine interactions or provided in response to an email from Turnkey.
In order for you to use certain features of the Services, such as enrolling for a Course, You are required to register for an Account, and fill out an application form for that Course, and in that case, We will collect and store any registration Information You provided to Us, such as name, contact Information, e-mail address, educational background, work experience, current organization, password, Your date of birth, and age, and we will assign You a unique identifying number (“Registration Information”).
- Information we collect automatically
- Your Device Information: Log Information, hardware model, operating system version, unique device identifiers, and IP Information including geographical location Information, and usage Information.
- Your Demographic Information
- Information Collected by Third Parties: Turnkey, or its Educational Partners and third-party service providers, may, for instance, collect certain Information from you in conjunction with assignments, exams and other assessments related to the Course. For instance, for pedagogical purposes, Turnkey’s Educational Partners (or its third-party service providers) may collect certain Personal Information or SPD from you to:
- verify or authenticate your identity or submissions made by you, such as a signature for a test or an assignment log, a photograph or a recording of you (e.g., using a digital camera) or Information pertaining to your account or any document in connection with your account, or
- review your performance throughout the Course, (e.g., confirming that you are not using prohibited resources during an exam). Turnkey may also collect Information from its Educational Partners about your performance or your progress, such as quiz/exam scores, grades, assignment evaluations, teacher evaluations and any other evaluations necessary, in connection with the Course.
We may receive Information about you if you use any of the other platforms we host or any other platform in connection with the Services. In this case, the Information may be analyzed internally and aggregated with the data collected on the Website and via Services. We also work closely with third parties including, Educational Partners, marketing partners, sales affiliates, third party technical/advertising networks, analytics providers, and search Information providers, and may receive Information about you from such sources. We may also receive your Information from your employers, educational institution or scholarship providers, where your Course is partly or fully sponsored by such a third-party. The third-party sponsoring your participation in the Courses may provide us your Information, subject to our agreement with them and, therefore, the third-party sponsor may be the controller with respect to such data.
- Information we collect from third parties: We may receive your Information when you access or log in to a third-party site, e.g., Facebook, WhatsApp from our Website or when you respond to our Ads on such third-party platforms. This may include some of your Personal Information or SPD available from the third-party site. Please note that the Information we obtain from such third-party platforms is often dependent on their privacy policies and/or on your preferences as to what Information you have consented to share with them, so and further.
We enter into arrangements with third parties to serve Ads on our behalf across the Internet for e.g. Google search engine, social networking sites, such as Facebook, Instagram and LinkedIn. They may collect or store Information about your visits to our Website and your interaction with our Services. They may also use Information about your visits to our Educational Partner’s platforms and to other websites to target advertisements for goods and services or for any other purpose. This Information is collected through the use of industry standard technology used by most major websites. Such third parties are not permitted by Turnkey to sell or share your Personal Information as part of this process. If such third parties sell or share the Personal Information as part of the process, Turnkey’s liability shall be limited to providing you with reasonable assistance in any action you may choose to take against such third parties, solely at your cost and expense.
We have third-party sales and marketing affiliates who may collect your Information through one of the various channels owned by them and share this Information with us, based on your interest in our Courses.
- PURPOSE / USE OF INFORMATION
The collected Information, including Personal Information and/or SPD, will be used for the following purposes only:
- Operate, Maintain and Improve Our Website: We may use the Information collected from You and also the Information you provided to Us for creating and improving features on Our Website and also in Our Services to provide a learning experience tailored for You best suited to meet yo01 u interests and requirements.
- Offer and Improve the Services and Courses: This includes and improving the delivery of diverse Courses available on Turnkey. This also includes personalizing Courses, so your learning experience is tailored to your interests and requirements and assessing your performance and awarding certificates. This also includes enabling you to browse the Website, to enroll and participate in Courses, to learn and to obtain the requisite certificate for that Course.
- Academic and Pedagogical purposes: We use your Information for managing and academic processing purposes, including, but not limited to, tracking attendance, progress and completion of a Course. As part of our management and processing of the Course, we will use certain Personal Information to administer exams, assignments, and other academic evaluations and programs for the Course.
- Security and Quality Control: We may use the Information to facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse; for detecting violations of the Terms of Service, and supervising uses, misuses, and potential misuses of the Website and/or the Services.
- Marketing and Promotional Activities: To the extent any Personal Information collected by us contains images of you, you grant Turnkey a limited, non-exclusive right to use, reproduce, distribute, or prepare derivative works of or publicly display such images and/or your likeness in relation to the Course or for marketing purposes. We may use your photograph along with employer Information, transition Information, designation change, etc., for Ads/and or social media posts to highlight our learners’ accomplishments and achievements.
- Compliance with legal obligations: We may use the Information for the purpose of responding to court orders, or other legal process; and investigating, preventing, or taking action regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of Turnkey, Turnkey Affiliates, or others, and as otherwise required by applicable law.
Turnkey, or the case maybe, its Education Partners’ may also seek your consent for additional uses of Information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.
- DISCLOSURE OF INFORMATION
- Users data will be used by the marketing team to send promotional emails.
- User’s Account Information and Personal Information and/or SPD will be used by the customer support team to address any issues raised by the users or preventive mechanism.
- Transaction data will be used by the finance team.
- The statistics and analytics team will access the user’s data for processing click and session, events.
- The IT Team will have the users IP address and location data.
- The third-party “Software-as-a-Service” provider(s) of Turnkey will access the relevant and necessary Information of the users in relation to the Services and the Content.
- Third-party payment gateways and other payment service providers will be able to access the necessary financial details of the users.
- With your consent: We will share any of your Personal Information or SPD for any other purpose not stated herein, only after you have given us your consent to do so with any third party.
- Educational Partners: We may share the Information that we collect from you with Our Educational Partners (e.g., a university or a professor/lecturer) that developed or curated the Course you are taking; the professor(s) who taught, managed or otherwise oversaw the Course; external graders who will be assessing your performance; or mentors who will be supporting learners. For example, if you are taking a Course developed by a university, we may share Personal Information about you and your performance with the university to report on your progress in the Course and to enable them to issue a certificate to you on completion of the Course. Personal Information shared with our Educational Partners will be subject to their privacy policies and procedures of such partners. Also, we may archive this Information and/or use it for future communications with you.
- Employers and Sponsors: If you are opting a Course that is sponsored or paid for by your employer or a sponsor, we may share your Information, including but not limited to, Personal Information, grades, evaluations or progress in the Course with your employer/sponsor. This Information may be shared at any time during the Course or afterwards.
- Learning Management Platform Providers: We provide access to or share your Information with third parties who perform services on our behalf or whom we commercial relationship to provide certain integrated resources in relation to our Services/Courses. They have access to perform these Services but are prohibited from using your Information for other purposes. They provide a variety of services to us, including providing a platform for the administration, documentation, tracking, reporting, automation and delivery of our Courses. Also, we use certain third-party platforms to collect your Information (such as Amazon Web Services, Typeform or Google Forms), as a consequence of which, your Information may be stored on their servers.
Please note that any Personal Information that is voluntarily displayed by you on the Website may be used by third parties for unsolicited purposes. Please note that Turnkey shall not be liable for such unsolicited use by third parties of your Personal Information that has been voluntarily displayed by you.
- INFORMATION STORAGE
We and the third parties obtaining your Information retain your Information in a manner that identifies you only for the time period necessary for fulfilling the purposes mentioned under this Policy.
Turnkey stores Information, including Personal Information, on its own servers and also on servers of companies that Turnkey engages to provide services. Each Educational Partner also stores Information, including Personal Information, on its own servers and/or on servers of companies that the Turnkey engages to provide services. In each case, Information may be stored in the countries where Turnkey or such party operates from.
Cookies are small pieces of Information saved by your browser onto your computer or other device used to access the Website and/or Services. Cookies are used to record various aspects of your visit and to assist Turnkey to provide you with a better experience.
- YOUR RIGHTS
- You can always choose not to provide the requested Information to us, even though it may result you in not being in a position to avail certain features of Turnkey’s Services on Our Website.
- You shall have the right to access your Personal Information and/or SPD that we hold and raise a request with us for rectifying, modifying or deleting your Personal Information and/or SPD by raising a request to our customer support/grievance officer, with the necessary contact details provided above.
- Our customer support/grievance officer shall process your request and revert to You within 15 days from the date of such request.
- If you think that any of your Personal Information and/or SPD that we hold is inappropriate/incorrect/inaccurate, and you want us to rectify the same, OR If you want to access any of your Personal Information and/or SPD, you can approach us at support @turnkeylearning.com, or reach us out at 1-800-103-8627.
- If you want to withdraw your consent or raise any objection to the use of your Information for receiving any direct marketing Information to which you previously opted-in, you can do so by unsubscribing to such direct marketing by contacting our customer support at above mentioned addresses. If you withdraw/object your consent, our use of your Information before you withdrew/objected shall still be lawful.
- SECURITY OF YOUR INFORMATION
- We, as well as third parties obtaining your Information, are committed to ensuring that your personal Information is protected and secure with us. In order to prevent unauthorized access or divulgence of your personal Information, we, as well as third parties obtaining your Information, have put in place suitable technical and organizational measures (such as physical, electronic and managerial procedures) to safeguard and secure the personal Information we collect from You.
- We have appointed “Data Protection Officers” who will protect your Information and help withstand it from breach.
- We perform periodical “Data Protection Impact Assessment” to identify risks to user Information and “Data Protection Compliance Reviews” to ensure those risks are addressed.
- All the Information we collect from you is in encrypted form by Secure Server Software (SSL) before it is sent to Turnkey, and from Turnkey to other third parties.
- Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding Information to help protect you from identity theft is a top priority. We do not and will not at any time request your credit card, or debit card, PIN in a non-secure, or unsolicited e-mail, or telephone communication.
- GRIEVANCE MECHANISM