2020-05-29
Privacy Policy

PRIVACY POLICY

We, Vowel Learning Solutions LLP (“Vowel”, “We”,) are the owners of the website www.vowellms.com (“Website”) and have developed a learning management tool (“Vowel LMS”). Vowel LMS 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 Website. This privacy policy (“Privacy Policy”) sets forth how we collect, use and protect the personal information collected on this Website.

Please read this Privacy Policy carefully.

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 Website 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 Website, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you may not access the Website.

1. WHAT DATA DO WE COLLECT?

To register for our free services, interacting with us using our chat window or to get in touch with us through the ‘contact us’, ‘sign up’ page on our Website, you would need to provide us with your first name, last name, e-mail address, contact number, company website, company name, number of learners, lead referral details, country. For the sake of brevity, the aforementioned information shall be referred to as “Personal Information”.

We also collect certain non-personal information on the way you use the Website, 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 Website and also, their behaviour.

Google Analytics-This Website 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 Website. 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 website 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.

As per the provisions of the GDPR we shall be considered the Controllers of the aforementioned Personal Information.

Cookies-

We use cookies and similar tracking technologies to track user traffic patterns and hold certain registration information. Tracking technologies also used are beacons, tags and scripts to collect and track information and to improve and analyze our service. If you wish to not have the information these technologies collect, used for the purpose of serving you targeted ads the Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to disable cookies altogether etc.

We use cookies to:

  • improve the user experience on the website
  • understand the usage based on the geographical area
  • understand the usage based on the demographics
  • understand and get usage patterns of the users

Examples of Cookies We Use: Session cookies, First party cookies, Third Party cookies, Secure Cookies, HTTP-only cookies, Flash cookies, Zombie cookies.

The cookies will collect following information:

  • Clicks and scroll on the Website;
  • Visitor’s operating system, browser information, CPU, GPU; and
  • Information of Service Provider.

Will disabling the cookies allow users to use the website?

We will not restrict the usage of the Website if the cookies are disabled.

Accuracy of information. Please make sure that any Personal Information you share with us is accurate and up to date information. If you are sharing any Personal Information on behalf of a third person, you should ensure that you are authorized to do so.

2. WHAT DO WE DO WITH YOUR DATA?

We use the Personal Information for the following purposes:

  • to inform you about our Services and to respond to your 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;
  • to run marketing and promotional campaigns, to process job applications (if you apply for a position with our organization),
  • to maintain and manage our Website;
  • to manage our relationship with you;
  • 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.

3. 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 Website 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 Website, 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.

4. 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..

5. 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..

6. OUR SECURITY MEASURES

Your Personal Information is stored on, third party 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.

7. YOUR RIGHTS

You have the right to access your Personal Information in our possession, right to have us rectify or modify any such Personal Information, right to have us erase/delete your Personal Information, right to restrict us from processing such Personal Information, right to object to our use of your Personal Information. If you would like to exercise any of these rights, please contact This email address is being protected from spambots. You need JavaScript enabled to view it.. If you are a resident of the EU, you have the right to lodge a complaint with a data protection authority.

8. LINKS TO OTHER WEBSITES

Our Website 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.

9. 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.

10. 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.

11. 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.

The Privacy Policy was last updated on 1st March 2020

12. 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.