Privacy Policy

INTRODUCTION

Subtlehub is committed to the security and management of personal data of individuals (Personal Data), to function effectively and successfully for the benefit of our stakeholders, vendors, 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 Personal Data. Therefore, we have implemented this Privacy Policy (hereinafter referred to as ‘‘Policy’’).

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 company processes Personal Data who visits, uses, deals with and/or transacts through the website and includes a guest user and browser (hereinafter ‘you’, ‘user’).

PURPOSE AND SCOPE

The purpose of this Policy is to describe how Subtle collects, uses, and shares information about you through our online interfaces (e.g., websites) owned and controlled by us, including but not limited to https://www.Subtlehub.in/ (hereinafter the “website”). This Policy is also designed to provide information on how Subtle 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 company’s information systems, including board members, directors, employees and other third parties who have access to Personal Data available within Subtle.

The company is also committed to ensure that its employees conduct themselves in line with this, and other related, policies. Where third parties process Personal Data on behalf of Subtle, the company endeavors to obtain assurances from such third parties that your Personal Data will be safeguarded consistently.

Subtle offers curated and specially designed industry-relevant certification and bootcamps programs online (“hereinafter individually or collectively referred to as Program”). This Policy applies to all our services unless specified otherwise.

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 Subtle. The following types of Personal Data may be held by Subtle, as appropriate, on relevant individuals:

SOURCES OF DATA COLLECTION

The Personal Data collected by Subtle is derived directly from the data provided by the user or by use of our sites.

Data Collected when You:

  • Register for various seminars, webinars or any other outreach initiatives made available by us or Educational Partner’s offline activities
  • Request a quote for the various products and services offered by us
  • Place a feedback, complete any customer surveys circulated or interact with our customer services online
  • View our services or visit our website pages on the internet
  • Browse our website
  • When you appear for assignments, exams or any other assessments in relation to online course
  • When you avail scholarships, refunds and referrals

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.

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, 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

“Aggregated Data” means records that have been stripped of Personal Data and has been 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.

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 Subtle relies upon to justify a particular processing activity may differ from the lawful basis used to justify a different processing activity.

Subtle relies on the following lawful basis to process Personal Data, as permitted under applicable law

  • Processing necessary for the negotiation, execution, or performance of contracts.
  • Processing to comply with legal and regulatory obligations.
  • Processing in furtherance of our legitimate interests, including our interests to conduct legitimate business activities (such as improving our products and services, to communicate with you, to secure our systems, among other legitimate interests).
  • Processing necessary to protect vital interest of a user or any other natural person.
  • Processing necessary for public interest.
  • Processing based on your consent.

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, Subtle 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 user 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 Subtle to use their Personal Data in certain ways.

Further, by using this website/ acknowledging this Policy / by voluntarily providing us with your Personal Data, you consent to collection, storage, and processing of your Personal Data in accordance with this 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.

Data Security

Subtle 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.

Subtle implements appropriate security measures designed to prevent unlawful or unauthorized processing of Personal Data and accidental loss of or damage to Personal Data. Subtle 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 Data. 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.

UPDATES TO THIS POLICY

We may update our Policy from time to time. We will take reasonable steps to inform all Subtle entities, Customers, Business Partners, and other individuals affected by the revisions by posting the new Policy on this page and/or via email.