SWIFTPAL User Privacy Policy

Last Modified:

Background
1. SWIFTPAL is provided to You under the SWIFTPAL User Terms of Service (“Terms”) and this SWIFTPAL User Privacy Policy (“Privacy Policy”). You herein refers to the Secondary User of the SWIFTPAL as defined in the Terms.
2. SWIFTPAL and the Company understand and recognize your right to confidentiality and is committed to protecting and preserving your privacy. Pursuant to such commitment, the Company has developed this Privacy Policy for the handling of or for dealing with a Centre Administrator’s and/or a Secondary User's Information, as defined and provided hereunder.
3. This Privacy Policy applies to all the Services offered under SWIFTPAL to the Primary User(s), the Centre Administrator(s) and the Secondary User(s) (collectively referred to as “You” “Your” or “Users” as the context may require) unless specified otherwise. Please also read SWIFTPAL Terms of Service, which describe the terms under which the Centre Administrator(s) and Secondary User(s) use, and We provide SWIFTPAL
4. This Privacy Policy applies to all the Services offered under SWIFTPAL to the Primary User(s), the Centre Administrator(s) and the Secondary User(s) (collectively referred to as “You” “Your” or “Users” as the context may require) unless specified otherwise. Please also read SWIFTPAL Terms of Service, which describe the terms under which the Centre Administrator(s) and Secondary User(s) use, and We provide SWIFTPAL
5. In the event that the Secondary User is a minor, the Centre Administrator and/or the legal guardian/parent and/or the Primary User as the case maybe (on behalf of a Secondary User) must be in a position to provide informed consent prior to their use of the Services. By registering the Secondary User with us, You, the Centre Administrator and/or the legal guardian/parent as the case maybe hereby consents to Us collecting, receiving, storing, possessing, dealing with, sharing and/or handling the Secondary User's Information in accordance with the terms of this Privacy Policy. Accordingly, You are required to read and understand this Privacy Policy, the Terms and any such other terms and conditions as may be applicable to a Secondary User's use of the Services, before submitting any Information.
6. Please note that access to the Services on the SWIFTPAL Platform is conditional upon consenting to this Privacy Policy. Please further note that if You are a Secondary User, please immediately stop using the Services until Your Centre Administrator and/or parent/ legal guardian approves and consents to the usage of the Services in accordance with the Privacy Policy and the applicable terms and conditions relating to use of the Services.

Acceptance of Terms.
1. By visiting, using, or registering with Our Website, Platform, and the associated Services/products thereto, You are agreeing, without limitation or qualification, to be bound by, and to comply with this Privacy Policy and all the terms thereof, and any other posted guidelines or rules applicable to any individual sections of the Platform, or Services. You are requested not to use and/or access Our Platform and/or any part thereof if You do not approve of, agree with and accept all the terms mentioned herein.

Information You Provide.
1. Account Information: We must receive certain basic information regarding You from the Primary User for the purpose of registering You as a Secondary User on SWIFTPAL and providing You access to the Services thereto. If We don't get this Information, We will not be able to register You as a User and enable You to use SWIFTPAL.
2. User Support and Other Communications: When You contact Us for support or otherwise communicate with Us, You may provide Us with information related to Your use of SWIFTPAL, and any other Information You deem helpful, and how to contact You (e.g., email address and phone number). For example, You may send Us an email with information relating to SWIFTPAL performance or other issues.

Information We Collect
1. We must receive or collect some information to operate, provide, improve, Our Services to You on the Platform
2. We require certain basic information to provide Our Services and without such information, We will not be able to provide them to You. The information that We require has been detailed in Clause 4.3 and 4.4 to this Policy, respectively.
3. Centre Administrator account information: We require the following information from the Primary User for the purpose of successfully registering any authorized individual as the Centre Administrator on the Platform:
  1. Administrator Code
  2. Name
  3. Centre Code
4. Secondary User account information: We require the following information from the Primary User for the purpose of successfully registering any individual as a Secondary User on the Platform
  1. Name
  2. Centre Code
  3. Centre Name
  4. Gender
  5. Grade
  6. Student ID
  It is assumed that such basic account information as provided to Us for the purpose of Secondary User has been duly provided with the informed consent of their respective legal guardian/parent and/or the Primary User, as the case may be. In the event that such information is provided without due consent, the Company shall take all reasonable steps to remove such information.

Automatically Collected Information
1. User Information: SWIFTPAL obtains the Information (including Personal Information) when You download, login, access or use any of the Services provided by SWIFTPAL. When logging with SWIFTPAL either as a Centre Administrator or as a Secondary User, the Services thereto are provided to You as against the account information received by Us as mentioned in Clause 4.3 and 4.4 to this Policy, respectively. The above-mentioned information is necessary to allow Us to operate the Platform and provide the relevant Services to You. Without it, We may not be able to provide You with all the requested Services, which could result in You not being able to use the Platform (or any part thereof).
2. Activity Information: For the purpose of successfully providing the Services on our Platform to a Secondary User, We require to store certain information pertaining to such User’s activities such as User interaction, academic data, etc. This is further required to provide the Secondary User with a personalized experience on the Platform.
3. Device Information: We only collect device installation identification information whenever a User installs SWIFTPAL on their respective device.

Purpose of Collecting, Storing and Using Personal Information.
1. SWIFTPAL will collect Your Personal Information only by lawful and fair means and not in an intrusive way to provide its Services, only for the following purposes:
  1. to process Your registration as a User of SWIFTPAL;
  2. to provide Services to You as a User;
  3. to process Your registration as a Centre Administrator; and
  4. to comply with SWIFTPAL’s legal and statutory obligations including in relation to User and/or Centre Administrator identity verification and reporting obligations as per the applicable law.

How We Use Information.
We use information We have (subject to choices You make and applicable law) to operate, provide, improve, research, understand, and support SWIFTPAL. Here's how:
1. Our Services: We use information We have to operate and provide SWIFTPAL, including providing customer support; fixing, and improving the Services under SWIFTPAL for You. We also use information We have to understand how Users use SWIFTPAL; evaluate and improve SWIFTPAL; undertake research and development activities; test new services and features; and conduct troubleshooting activities. We also use Your information to respond to You when You contact Us.
2. Safety, Security, and Integrity: Safety, security, and integrity are an integral part of SWIFTPAL. We use information We have to verify accounts and activity, combat harmful conduct, protect Users against bad experiences, and promote safety, security, and integrity on SWIFTPAL, such as by investigating suspicious activity or violations of Our Terms and policies, and to ensure that SWIFTPAL is being used legally.
3. We use Your Personal Information as provided by You to prevent and detect fraud and abuse in order to protect the security of Our Users, SWIFTPAL, and others.
4. Storage of Information: All information You share with Us and retained by Us is stored securely on Our servers and used strictly to support You and efficiently provide Our services to You.
5. No Third-Party Banner Ads: We do not allow third-party banner ads on SWIFTPAL. We have no intention to introduce them, but if We ever do, We will update this Privacy Policy accordingly.

Managing Your Information.
1. We store information for as long as necessary for the purposes identified in this Privacy Policy, including to provide SWIFTPAL or for other legitimate purposes, such as complying with legal obligations, enforcing and preventing violations of Our Terms, or protecting or defending our rights, property, and Users. The storage periods are determined on a “case-by-case” basis that depends on factors like the nature of the information, why it is collected and processed, relevant legal or operational retention needs, and legal obligations.

Retaining Your Information.
1. We retain the data We collect from You for different periods of time depending on what such data is, and how We use such data. Following are the ways in which We treat different types of data collected by Us from You:
  1. Data We keep unless Your account is removed: We keep some data related to Your account on SWIFTPAL until Your SWIFTPAL account is removed, such as Your “about section” and the Information about how often You use SWIFTPAL
  2. Data We keep for a long time: We may keep some of Your data for a long period of time (including after Your account on SWIFTPAL has been removed). We keep such data when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention.

Security of Personal Information
1. SWIFTPAL takes all reasonable steps to ensure that the Personal Information which it collects, uses or discloses is correct and is stored in a secure environment which is accessed only by authorized personnel. SWIFTPAL will destroy or permanently de-identify the Personal Information held when it is no longer required for any purpose permitted under the Information Technology Act 2000, and the amendments thereto, the Digital Data Protection Act, 2023, and any other applicable law of India, including legal or operational obligations.
2. When storing and/or accessing Your Personal Information, We implement stringent access controls to limit access to Your sensitive Information. Our internal policies mandate that access is granted to any authorized personnel only based on the principle of least privilege (“PoLP”). Adhering to PoLP allows Our authorized personnel to successfully undertake their tasks while having the minimum access needed to Your Information, whereby balancing usability and data security
3. All Information You provide to Us is stored on secure servers with VPC isolation We further secure Your information via encrypted RDS and S3 storage and defining IAM roles with strict access controls. Further, passwords are securely hashed.
4. However, You are responsible for maintaining the confidentiality of Your account login ID and the password which have been provided to You and enables You to access Our Services on the Platform. We ask You not to share Your login ID and password with anyone
5. Please note that no computer system or transmission of information over the Internet can ever be completely secure or error-free, and although We take reasonable security precautions, You understand and acknowledge that We shall not be liable towards securing Your information while the same is in transit. Accordingly, SWIFTPAL does not warrant the security of any Information which You transmit to it outside the Platform. Any information which You transmit shall be at Your own risk. Neither SWIFTPAL nor the Company will be liable for damages of any kind arising from the use of the Platform, including, but not limited to any indirect, incidental, special, consequential or punitive damages, or any loss of data, good-will, or other intangible losses.
6. Once We receive Your transmission, We take reasonable steps to protect Your Personal Information from misuse, loss and unauthorized access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer (“SSL”) technology.
7. SWIFTPAL’s employees, agents, contractors, and affiliates are required to maintain the confidentiality of the Users’ Personal Information.

Law, Our Rights and Protection.
1. We access, preserve, and share Your information described in the “Information We collect” section of this Privacy Policy, if We have a good-faith belief that it is necessary to: (a) respond pursuant to applicable law or regulations, legal process, or government requests; (b) enforce Our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, or address fraud and other illegal activity or security, and technical issues; or (d) protect the rights, property, and safety of Our Users, SWIFTPAL Platform or others, including to prevent death or imminent bodily harm.

Grievance Redressal.
1. In the event a Secondary User wants to raise any query, support or complaint in relation to any Services being provided on the Platform, the User may submit their feedback on the feedback form, duly integrated into the Platform.
2. In the event a Centre Administrator might want to raise any query, support or complaint in relation to the Services under the Platform, such Centre Administrator may send Us an email regarding their grievance(s) at help@convegenius.com.
3. We shall use Our best efforts to notify all the relevant stakeholders in the event of any change in the details of Our grievance officer, from time to time.

Updates to Our Privacy Policy
1. We may amend or update our Privacy Policy. We will provide You notice of amendments to this Privacy Policy, as appropriate, and update the last modified date at the top of this Privacy Policy. Please review Our Privacy Policy from time to time.
2. If You have questions or issues about Our Privacy Policy, please contact Us at help@convegenius.com