2022-04-15
Privacy Policy

 PRIVACY POLICY

We, Vowel Learning Solutions LLP (“Vowel”, “We”,) are the owners of the Vowel LMS learning management tool (“Platform”). The Platform helps individuals and organizations conduct online and classroom training activities, content distribution and management, host workshops, webinars, create assessments and quizzes, hand out assignments (“Services”).

 

We respect data privacy rights and are committed to protecting personal information collected on this Platform. This privacy policy (“Privacy Policy”) sets forth how we collect, use and protect the personal information collected on this Platform.

 

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO USE THE SERVICES, USER AGREES TO THIS PRIVACY POLICY. IF USER DOES NOT AGREES TO THIS PRIVACY POLICY, USER MAY NOT AVAIL THE SERVICES OR ACCESS THE PLATFORM.

 

IF YOU ARE USING THE SERVICES OR ACCESSING THE PLATFORM ON BEHALF OF A THIRD PARTY, YOUR COMPANY YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO USE AND AVAIL SERVICES OR ACCESS THE PLATFORM AND  TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND, IN SUCH AN EVENT YOUR USE OF THE SERVICES OR THE PLATFORM SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL INFORMATION OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, THEN YOU SHOULD REFRAIN FROM USING THE SERVICES.

 

For residents of the EU, please note that this Privacy Policy has been updated in accordance with the requirements of the EU General Data Protection Regulation (“GDPR”).

For residents of the US, please note that the personal information provided by you on this Platform shall be utilised, used or handled in accordance with the applicable US data protection and privacy laws.

For Non-EU residents, by continuing to access the Platform, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you may not access the Platform.

 

  1. DEFINITIONS
  • “User(s)”, “you” or “your”-means any individual, organization its permitted users and customers that use the Platform to avail the Services.
  • “User Content” – meansall data and materials provided by the User to the Platform for creating e-learning courses and used in connection with the Services, including, without limitation, learning modules, data files, audio files, video files, graphics or other materials.
  • “Vowel Content” – means all the data and materials including but not limited to learning modules, data files, audio files belonging to us, which has been shared or uploaded on the Platform or has been provided to the User as the case may be.

 

  1. WHAT DATA DO WE COLLECT?

For accessing the Platform and using the Services, User shall be required to share/upload certain personal information. For the purposes of this Privacy Policy “Personal Information” means  information that can be used to personally identify the User, including but not limited to first name, last name, e-mail address, contact number, company website, company name,  country.

 

We also collect certain non-personal information on the way you use the Platform, through tools such as Google Analytics (a brief description of the same is provided below). This is done primarily to enhance user experience. These tools collect certain information which helps us understand how many visitors have visited the Platform and also, their behaviour.

 

Google Analytics-This Platform uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, text files that are stored on your computer and enable analysis of your use of the Platform. The information generated by the cookies about your use of this website are usually transferred to a server of Google in the US and stored there. In case of activation of IP anonymization on this website your IP address from Google will be truncated within Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address is transmitted to a Google server in the US and shortened there. You can refuse the use of cookies by selecting the appropriate settings on your browser software. You can also prevent the data generated by the cookie and related to your use of the Platform to Google and the processing of these data by Google, by selecting the in the following link (https (including your IP address.): // Download tools.google.com/dlpage/gaoptout?hl=de) available browser plug-in and install it.

 

  1. ACCURACY OF INFORMATION

User undertakes that he shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Information and User Content shared or uploaded on the Platform, whether of its own or any third party. In the event the User is sharing any Personal Information or User Content on behalf of a third person, the User represents and warrants that he has the necessary authority to share or upload such Personal Information or User Content on the Platform , We shall not be responsible for verifying the same.

As per the provisions of the GDPR we shall be considered as the controllers for Vowel Content and the processors   of the aforementioned Personal Information, User Content

 

  1. NON-PERSONAL INFORMATION

We collect User’s Internet Protocol (“IP”) addresses when User visits the Platform to track and aggregate non-personal information. Non-personal information may include the browser name, your usage and log related information, the type of electronic device, manufacturer, make, model, unique ID of the electronic device and other technical information about User’s means of connection to our Platform, such as the operating system and the Internet service providers utilized and other similar information. For example, we may use IP addresses to monitor the regions from which User navigates our Platform. User understands that this information shall be non-personal information and could be used by the Company, for its own business purposes. During troubleshooting and maintenance events we may have access to Users Content.

 

  1. WHAT DO WE DO WITH YOUR DATA?

We use the Personal Information for the following purposes:

  • to inform User’s about our Services and to respond to User’s requests;
  • for creation or development of business intelligence or data analytics in relation to the Services provided by us (for this purpose we may share the Personal Information with certain software or tools available online)
  • to improve the Services and generate reports;
  • to maintain and manage User accounts;
  • to assist User in case of technical difficulties that may arise in relation to User’s use and access of the Platform;;
  • to manage our relationship with User;  
  • for internal record keeping; and
  • to comply with our legal or statutory obligations.

Legal Basis (for people from the EU): We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal basis of consent [as provided in Art. 6 (1) (a) of the GDPR], contract [as provided in Art. 6 (1) (b) of the GDPR], or on the basis of our legitimate interests [as provided in Art. 6 (1) (f) of the GDPR], provided that such interests are not overridden by your privacy rights and interests.

 

  1. WHO DO WE DISCLOSE YOUR DATA TO?

We do not sell, rent, share, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Information in the following cases:

  • Affiliates: We may provide your Personal Information to our affiliates to enable them to promote and develop the Services.
  • Service Providers:We may share your Personal Information with the service providers who work with us in connection with operating the Platform and/ or providing the Services. All such service provider is subject to stringent confidentiality restrictions consistent with this Privacy Policy.
  • Merger or Acquisition:We may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Platform, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.
  • Legal and Regulatory Authorities: We may disclose your Personal Information in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.

 

  1. TRANSFER OF YOUR PERSONAL INFORMATION ACROSS BORDERS (FOR EU RESIDENTS)

The Personal Information we collect (of EU residents) might be processed outside the EU at a secure center located in  India. We collect and transfer Personal Information outside the EU in accordance with EU data protection laws. We will ensure that any such transfers of Personal Information (outside the EU) will be in accordance with the GDPR. If you have questions, please contact This email address is being protected from spambots. You need JavaScript enabled to view it..

 

  1. HOW LONG DO WE RETAIN YOUR DATA?

We will retain your Personal Information as long as it is required to be retained for the purpose of provision of the Services and to comply with our legal obligations. Subject to this section, we will try to delete your Personal Information upon reasonable written request for the same. Please note, however, that there might be latency in deleting Personal Information from our servers. For more information on where and how long your Personal Information is stored, and for more information on your rights of erasure and portability, please contact This email address is being protected from spambots. You need JavaScript enabled to view it..

 

  1. OUR SECURITY MEASURES

Your Personal Information is stored on, AWS cloud servers. Although we provide appropriate firewalls and protections, we cannot warrant the security of any Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we assume no liability or responsibility for it. You are required to be careful to avoid “phishing” scams, where someone may send you an e-mail that looks like it is from us asking for your personal information.

 

  1. ACCESSING AND MODIFYING PERSONAL INFORMATION

The User shall be solely responsible for maintaining the confidentiality of its account and for all other activities that occur under his/her account. You must keep your account and password secure. We encourage you to use “strong” passwords (passwords that use a combination of upper- and lower-case letters, numbers and symbols) for your account. You shall be solely responsible for your acts and omissions. We shall not be liable for any Personal Information or User Content loss caused by any unauthorized use of your account.

In case User needs to access, review, delete and/or make changes to the Personal Information, User may depending upon the access/admin rights granted by us or by administrators of the organization as the case may be do so on its own. Administrators of Users organization can manage, control and store the category of Personal Data (such as contact details, name, email address) as per the requirement of the respective organization.  User shall keep User’s Personal Information updated to help us improve our Services. If User updates, modifies or corrects his Personal Information, we may continue to keep copies of the Personal Information prior to such update, modification or correction for uses provided for in this Privacy Policy. We shall not verify any such modifications or corrections made by the User. User shall be solely liable for such modifications or corrections. In case User is not able to modify, delete its Personal Information User may contact us at This email address is being protected from spambots. You need JavaScript enabled to view it..

 

  1. LINKS TO OTHER WEBSITES

Our Platform may contain links to other websites/applications of your interest. Please note that we do not have any control over such other websites/applications, and you will be accessing these websites/applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/applications and those are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to such websites/applications.

 

  1. LIMITATION OF LIABILITY

To the extent permissible under the law, we shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data, information, or other intangible losses (even if we have been advised of the possibility of such damages), arising out of this Privacy Policy.  

 

  1. INDEMNIFICATION

User agrees to indemnify us, our subsidiaries, affiliates, officers, agents and employees (each, an “Indemnified Party”) and hold the Indemnified Party harmless from and against any claims and demand, including reasonable attorneys' fees, made by any third party due to or arising out of or relating to: (i) accuracy and correctness of Personal Information and User Contents that User submits or shares through the Platform; (ii) User’s violation of this Privacy Policy, (iii) or User’s violation of rights of another User.

 

  1. GOVERNING LAWS AND DISPUTES

This Privacy Policy shall be construed and governed by the laws of India without regard to principles of conflict of laws. Any dispute arising, between you and us shall be submitted to the arbitration to be conducted in Pune, India in English language, in accordance with the rules of Arbitration and Conciliation Act of 1996, by a sole arbitrator, who shall be appointed by us and the award made in pursuance thereof shall be binding on you and us. Subject to the arbitration provisions, you agree that the courts in Pune, India shall have an exclusive jurisdiction over such disputes.

For any EU residents, this Privacy Policy shall be governed by the provisions of the GDPR.

For any US residents, this Privacy Policy shall be governed by the provisions of the applicable data protection and privacy laws.

 

  1. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time and you are encouraged to check this Privacy Policy on a regular basis to be aware of the changes made to it.

This Privacy Policy was last modified on 2nd September 2021

 

  1. CONTACT US

If you have any questions or concerns or grievances regarding this Privacy Policy, you can email us at our grievance email-address This email address is being protected from spambots. You need JavaScript enabled to view it..