Contact information
Step Up Education Consultants established in 2024 having office at 9407 Garden Villas ,DLF Phase 4, Gurugram 122009 ,Haryana India.
Step Up values the trust placed by its users ("you", "your", "user", "subscriber") and therefore, we follow the highest standards to protect your Personal Information.
If you require any information or clarification regarding the use of your Personal Information (defined below) or this Privacy Notice or if you require any general information or clarification or inquiry regarding the Platform please email us at info@stepupedu.co.in
2. Objective and Scope
This Privacy Notice ("Privacy Notice") explains how we use and protect Personal Information (defined below) of the users or subscribers of our Step Up Service in India.
This privacy notice describes the usage of information provided or collected through sites and applications, where this privacy notice is posted ("Platform") and affiliate or third-party sites / platforms through which the Platform and/or any of its features and/or services available on the Platform may be provided. We follow this privacy notice in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices
specific to certain features or services. Those notices are to be read in combination with this Privacy Notice. Please also keep in observance that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your Personal Information.
We encourage you to read the applicable Terms of Use to understand the terms related to the use of the Platform and Step Up Service in general.
3. Collection of Personal Information
Where we refer to 'Personal Information' we mean any information related to a particular individual who we identify (whether directly or indirectly) a particular individual or natural person. This includes direct identifiers such as your name, postal address, email address, and mobile number, and also includes all other information which is linked to that information such as your location. Where we refer to "ID" we mean a list of numbers and/or letters (also known
as a numeric or alphanumeric string) which we or our service providers may generate and which is used as a means to give you a unique customer or user identifier – it cannot directly identify personally but it may be able to do so where your Personal Information is associated with it. If you are accessing the Step Up Service from the territory of India, for the purpose of this Privacy Notice,Personal Information.
3.1 Information provided by you
We may ask for and you may choose to provide the below information, which may include Personal Information, when you use or register for the Step Up Service and create an account, or interact via the Platform, use any of the features or services available on the Platform or contact us directly:
Name
Email Address
Phone number
Age or date of birth
Gender
Password
Location, pin code, area code, and occupation as provided by you Payment and other information pertaining to your transactions on the Step Up Service
Any service requests;Search terms;language preferences,content preferences,account settings,user-generated content including comments, photos or videos which you choose to upload or broadcast on the Platform
game play data during game play events on our Platform Other profile information, such as social media account information and profile image (where feature is available) your phone and social network contacts, with your permission information to verify an account such as a form of identification (if requested) information in correspondence you send to us, including responses to surveys or other feedback information you share when you participate in marketing promotions, prize draws or
competitions, your opt-in choices and communication preferences; any other information that you may otherwise choose to provide us.
We collect this information in a number of ways, including when you enter it while using our Platform, interact with our customer support, or participate in game play events or hosted games on our Platform, surveys, or marketing promotions, or competitions. In some cases, where you access our Platform service available via mobile devices, Smart TVs or Internet connected TVs or Internet connected devices (streaming devices) your streaming device may store some of your Personal Information in their memory. These streaming devices are operated by third parties and these third parties will have their own privacy notices or other policies regarding the handling of Personal Information that they independently collect from such streaming devices. You should carefully read the privacy notice and policies of these streaming devices. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Notice.
3.2 Information we collect automatically
We and certain third parties on our behalf may collect information about you and your use of our Platform, your interactions with us or our advertising or any direct marketing we send you, as well as information regarding your computer or other streaming device used to access our service. The information may be collected using tracking technologies such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons and may include:
Your activity on the Step Up Platform such as pages/titles viewed, load times, watch times,content selection and course history, transactions initiated and/or completed, search queries and platform features used. This information may include the platform or website that you just visited (whether this platform is on Step Up Services or not), which platform or website you next visit.
Device tokens for push notification (if you have enabled push notifications) Your interactions with our emails, communications, messages, advertisements on third party
platforms and other channels Your interactions with our customer support such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings; Information about your general location, including location based on your mobile phone SIM card and/or IP address and, with your permission your precise location based on GPS data. In the event IP detection fails, we will collect the last cached location as your current location; Device and software information such as device id, device model, platform, type of operatin system, installed version, time zone setting, mobile carrier, screen resolution etc. and other unique identifiers. With your permission we may also collect information pertaining to the applications frequently used by you on your device; Advertisement identifiers such as IDFA, GAID etc and data related to your interaction with the Device tokens for push notification (if you have enabled push notifications)
Your interactions with our emails, communications, messages, advertisements on third party
platforms and other channels
Your interactions with our customer support such as the date, time and reason for contacting
us, transcripts of any chat conversations, and if you call us, your phone number and call
recordings;
Information about your general location, including location based on your mobile phone SIM
card and/or IP address and, with your permission your precise location based on GPS data. In
the event IP detection fails, we will collect the last cached location as your current location;
Device and software information such as device id, device model, platform, type of operating
system, installed version, time zone setting, mobile carrier, screen resolution etc. and other
unique identifiers. With your permission we may also collect information pertaining to the
applications frequently used by you on your device;
Advertisement identifiers such as IDFA, GAID etc and data related to your interaction with the
advertisement that are served on the Step Up Platform;
We capture information related to the performance of the mobile application and the Platform,
such as crash logs, build analytics and other performance statistics generated when you use the
Platform;
3.3 Inferred Information through usage and log data
We may track certain information about the content viewed and your visit to our Platform. This
information may include the platform that you just visited (whether this platform is on Step Up
Services or not), which platform you next visit, your computer browser information, your mobile
phone OS version.
3.4. Information we collect through third party sources
We may obtain your Personal Information from other sources.
If you choose to link, connect or login to our Platform using a social media platform like
Facebook, Twitter, Instagram, YouTube, LinkedIn, or Google the social media platform may send
us your profile and social information such as Email ID, Name, Friend list, Friend's social
information, etc.
We may also receive information about you from third parties but will only do so where we have
assurances that you have given your permission. For example, we may obtain data related to
you and your interests from i) publicly available sources such as public or open government
databases or ii) online and offline data providers (including advertising networks and analytics
providers).
4. Payment Card and Billing Information
When you purchase our services using one or more of our payment gateway service providers,
or any other online or mobile payment services provider we may use (including through any app
stores), the following payment information will be collected: your credit/debit card details
(number, card expiry date, CVC code) or other bank account details along with the date, time
and amount of the transaction payment. This payment information is stored by our payment
processors and associated with a merchant name/ID and location which our payment processor
gives to us, together with a unique customer ID which we share with them but this payment
information is never stored or processed by us. Our payment processors use this payment
information to process and facilitate the payment of your subscription fee in order that we may
provide you with the service you have requested or to enter into a contract with you to access
the Platform (in other words to perform the contract). So that we know you have paid your
subscription fee our payment processors will send us a unique transaction ID which we associate
with your unique customer ID and which we keep for internal accounting purposes because we
have a legal obligation to do so.
Our payment processors may use third party fraud detection software or providers which
analyse your payment information in order to make automated decisions as to whether or not
payment from you will be accepted. You have the right to contest any fraud decision made
about you and to be given more information about why any such decision was made by
contacting us.
Where you pay a third party for your subscription package (e.g. an app store like Apple App
Store) your payment information may be directly collected and controlled by that third party.
However, we may receive invoice receipts from third parties for your subscription purchase and
these receipts are stored by us as we have a legitimate business interest to keep them for
internal accounting and tax purposes and to comply with our legal obligation as per any
applicable laws including any audits, legal proceedings and/or investigations.
Where our payment processors are providing payment processing services to us we put in place
appropriate contracts to protect your personal information. For the following aspects of the
payment processing our payment processor may act as a controller of your payment
information (identified and listed above): providing the payment processing services to you at
your request,):, monitoring, preventing and detecting fraudulent payment transactions,
complying with legal or regulatory obligations which apply to the financial services sector and
analysing, developing and improving their products and services. Our payment processors have
their own privacy policies in place and we recommend you read those policies before you
provide your payment information.
In order to process any of your customer support queries related to payment processing, our
payment processors give us access to your credit/debit card details (including any updates) so
that we can perform the contract with you and provide you with a quick resolution of your
queries. We also use the credit/debit card details so that, on the basis of our legitimate business
interest, we can analyse the most popular card types and issuing banks of our customer base to
ensure that we are able to improve our user experience and provide you better service. Our
payment processors may also pass us your expiry date after each payment transaction is
completed and we will use this to send you an email reminder to update your payment
information before your card expires as we believe we have a legitimate interest to make sure
your access to the Platform is not interrupted, you can still cancel at any time.
5. Purposes of processing
We will only collect and process Personal Information about You where we have lawful basis to
do so. Our lawful basis for processing your Personal Information will vary depending on your
country, the context in which we collect and use it and the following examples give you as a
guide as to which basis we think applies (but if the context changes or other circumstances arise
then the lawful basis may also change). Our primary purpose in collecting your information,
including Personal Information from you is to deliver the personalized Step Up Service and its
various features. Please note that should you choose to not provide us consent to collect your
information, including Personal Information, we may not be able to perform the contract with
you. Where we refer to 'perform the contract' we mean the Terms of Use applicable to your use
of the Step Up Service, which means that you may either not be able to access certain features
of the Step Up Service or we may not be able to provide you the Step Up Service in entirety.
For example, we use your information where we need the Personal Information to perform the
contract with you (for example, to provide the Platform or our services to you) so as to:
Register you on our Platform and create an account or give you access,
Allow you to Sign Up/ Log In using social media accounts like Facebook etc.,
Process your payment card details (as described in Section 4 above),
Provide you with customer or technical support including addressing support queries related to,
but not limited to, payment processing, or to diagnose any problems with our servers etc.
Send you transactional emails or to provide you with information, direct marketing, online and
offline advertising and other materials regarding products, services and other offers from time
to time in connection with the Step Up Service or its parent, subsidiary and affiliated companies
("Platform Entities") and its joint ventures/affiliates.
Determine your geographic location, to provide you localized content including advertisements,
personalized viewing recommendations, allow you to continue watching previous content at
another time or on another streaming device, and to determine your Internet service provider
to troubleshoot a technical issue, and help us quickly and efficiently respond to inquiries and
requests;
If you are a traveller visiting various countries around the world and avail the Platform's
services, then we will determine your location using your IP address to determine the relevant
Step Up Services which may be offered to you;
To provide you with a personalised service and experience; we do this by linking some or all of
your Personal Information with your activity on our Platform across all your streaming devices
and associating and storing this information with a unique platform generated identifier that is
generated for user.
In other contexts, if the processing of your Personal Information is subject to the General Data
Protection Regulation, we use your Personal Information where the processing is in our
legitimate interests and not overridden by your fundamental rights and freedoms (for example,
our direct marketing activities in accordance with your preferences) such as to:
Display or target advertisements on the Platform based on your registration or profile
information, location and/or your activity on the Platform across all your streaming devices
(including inferred information through usage and log data) which is associated with your device
advertising identifier (IDFA, GAID etc) – this is typically referred to as 'interest-based
advertising'. We also display contextual advertisements on the Platform but these are not
targeted to any particular user and does not make use of any information that personally
identifies you or precisely locates you (contextual advertising is advertising which we target
based on the content being viewed, for example if you are viewing a course, we may serve
adverts of companies or products related).
Research, analyse and understand our audience and what content and advertising they may
view, watch or otherwise engage with, in order to improve our service (including our user
interface experiences and security features) and optimize content selection i.e. recommend or
make it easier for you to find content we think you will prefer; evaluate your eligibility for
certain types of offers, products or services and market such products or services to you; to
perform analytics and conduct customer research, including general market research or
surveying our customers' needs and opinions on specific issues, generating sales and traffic
patterns, and to analyse advertising effectiveness, both on an anonymous basis (e.g., by
aggregating data) or on an individual basis (if legally permissible), in combination with other
information collected from tracking technologies and aggregate it with information collected
from other Users using our Platform, to attempt to provide you with the Services and a better
experience on the Platform.
Allow you to participate in interactive features such as Game play events on the Platform,
providing you with relevant gameplay experience, determine and declaring winners and
providing you with prizes.
Analyse and measure how effective our advertising is by determining which media sources
should be paid for delivering a desired action e.g. users who install our application or subscribe
(also known as 'attribution'), so that we pay for demonstrated value and don't overspend.
We will use your Personal Information with your explicit consent as follows:
When you agree to share your precise location based on GPS data, we will combine this
information with other information that you provide to us on the Step Up Service to provide
personalised content and advertisements with better accuracy basis your geographic location
e.g. you may see more regional content recommendations or advertisements for local
establishments, when you share your precise location based on GPS data;
When you agree to share information pertaining to the applications frequently used by you on
your device, we will combine this information with other information that you provide to us on
the Step Up Service, to display advertisements that are more relevant to your interest area.
When you agree to share information pertaining to the content you are exposed to on the
television, we may use this information along with other information that you provide us on the
Step Up Service, to provide you with personalised content similar to those you might prefer to
watch.
Or otherwise whenever the law requires us to get your permission or where we have stated we
may seek your permission in this Privacy Notice. In some contexts, we use your Personal
Information where we have a legal obligation to do so or to protect your vital interests or those
of another person:
Prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and
enforcing our terms;
Confirming your identity if you are exercising legal rights;
Notify you about changes in the Terms of Use or in this Privacy Notice;
Carry out our obligations and enforce our rights arising from any contracts entered into
between you and us/our distributor.
When you access or use the Services or send any data, query, request or communication to us
via our Support email, you understand that you are communicating with us electronically, and
that we may respond via electronic means from us, such as by email.
6. Disclosure
6.1 SERVICE PROVIDERS
At times we may make your Personal Information available to our service providers (such as but
not limited to: marketing, analytics, research, communication, advertisements, infrastructure
and IT services, technology or software providers, payment processing and other service
providers) that work with us or assist us to provide services to you or license us software which
we include in our application(s). Personal Information will only be shared with our service
providers to provide or improve the Step Up Service and to enable us to analyse our efforts. We
do not authorize our service providers to use or disclose your Personal Information except in
connection with providing their services. We or our service providers may also share your
advertisement identifiers such as IDFA, GAID etc. with advertising / data exchanges, and
marketing analytics and other digital advertising and marketing service providers. The
advertisement identifiers are used by these exchanges and service providers to decide which
ads you see both on our sites and applications and on third-party sites and applications.
6.2 BUSINESS OR PROMOTIONAL PARTNERS
We may offer joint promotions that, in order for you to participate and benefit from any
promotional offer, will require us to share your Personal Information with third parties so that
we co-ordinate and fulfil the incentive offered. These third parties are responsible for their own
privacy practices.
6.3 Business Transfers
We provide Personal Information to our affiliates and other trusted businesses or persons to
process it for us, based on our instructions and in compliance with our Privacy Notice and any
other appropriate confidentiality and security measures.
6.4 Legal
In the event of any requirement by court order, government or quasi-government agency to
disclose your Personal Information, we will disclose information as may be legally required. We
may also disclose your Personal Information if we, in the good faith believe that such disclosure
is reasonably necessary to respond to subpoenas, court orders, or other legal process.
In the event Step Up is merged with or acquired by another company or in case of re-
organization or re-structuring of business, we and our affiliates may share your Personal
Information, wholly or in part, with another business entity.
7. Your Controls and Choices
We provide you the ability to exercise certain controls and choices regarding our collection, use
and sharing of your Personal Information. In accordance with applicable law, your controls and
choices may include:
7.1 Managing Your Information
You can access some of your Personal Information through the Platform after a successful login.
You are responsible for providing us with your accurate Personal Information and keeping your
Personal Information up-to-date.
7.2 INTEREST-BASED ADVERTISING
To opt out of interest-based ads from Step Up Service in connection with a resettable device
identifier on a mobile device, tablet, or streaming media devices, please drop a mail to
info@stepupedu.co.in You may still see ads on your device, but they will not be tailored to your
interests.
7.3 PUSH NOTIFICATIONS
If you are receiving push notifications, then you can disable it any time by dropping a mail to
info@stepupedu.co.in
(Different device configurations, or updates to devices, may affect or change how these settings
work)
7.4 Rectification of Inaccurate or Incomplete Information
You can ask us to correct inaccurate or incomplete Personal Information concerning you by
sending us an email to our support email address.
7.5 Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your Personal
Information held by us. You may also be entitled to request copies of Personal Information that
you have provided to us in a structured, commonly used, and machine-readable format and/or
request us to transmit this information to another service provider (where technically feasible).
You can issue such a request by contacting us via the provided support email.
7.6 Data Retention and Erasure
We retain your Personal Information as long as necessary for providing you the services and as
per the lawful basis of processing and to comply with our legal obligations. In particular, when
determining how long we retain personal data, we take into account how long we need it to:
Maintain business records for analysis and/or audit purposes;
Comply with record retention requirements under the law;
Defend or bring any existing or potential legal claims; and
Deal with any complaints regarding the Platform/any services provided on the Platform.
The data that we collect to create a profile of you for the purpose marketing and advertising (i.e.
your buy history and activity on the platform) is retained for: the maximum period allowed by
Indian/applicable country law.
The data that we collect for sending your direct marketing communications (i.e. your phone
number), except your registration information, is retained and used for a period as considered
suited by Step Up or as permitted by Indian/applicable country law, whichever is least.
At the end of the retain period your personal data will be anonymised.
If you no longer want us to use your information, then you can request that we erase your
Personal Information and close your Platform account. Erasure of your information from the
Platform will result in your subscription being terminated without any refunds.
Please note that if your request for the erasure of your Personal Information;
We may retain some of your Personal Information as necessary for our legitimate business
interests, such as fraud detection and prevention and enhancing safety. For example, if we
suspend a Platform account for fraud or safety reasons, we may retain certain information from
that account to prevent that user from opening a new account in the future.
We may retain and use your Personal Information to the extent necessary to comply with our
legal obligations. For example, we may keep some of your information for tax, legal reporting
and auditing obligations.
7.7 Withdrawing Consent and Restriction of Processing
For data that we collect, and process based on permissions or consent obtained from you, you
may withdraw your consent at any time, by dropping a mail to info@stepupedu.co.in . We shall
review your request and may ask you to verify your identity.
8. Children's Privacy
We do not knowingly permit any person who is under 18 years of age to register or to provide
any other personally identifying information. Please do not register with us if you are below 18
years of age. If we become aware that any Personal Information of persons less than 18 years of
age has been collected on the Platform without verified parental consent, then we will take the
appropriate steps to delete any such information.
While persons under the age of 18 may utilize the Step Up Service, they may do so only with the
involvement, supervision, and approval of a parent or legal guardian.
9. Data transfer, storage & processing globally
We shall operate globally and may transfer your Personal Information to Step Up affiliated
companies or service providers or third-party recipients to whom we provide technology and
hosting services, in locations around the world for the purposes described in this Privacy Notice.
Accordingly, by consenting to this Privacy Notice, you also provide consent to Step Up to
transfer your Personal Information to Step Up affiliated companies or service providers or such
third-party recipients in locations around the world. Wherever your Personal Information is
transferred, stored or processed by us or our affiliates or service providers, we will take
reasonable steps to safeguard the privacy of your Personal Information.
10. Security
We are continuously implementing and updating administrative, technical, and physical security
measures to help protect your Personal Information against unauthorized access, loss,
destruction, or alteration. Some of the safeguards we use to protect your information are
firewalls and data encryption, and information access controls. These measures are designed to
provide a level of security appropriate to the risks of processing your Personal Information. If
you know or have reason to believe that your account credentials have been lost, stolen,
altered, or otherwise compromised or in case of any actual or suspected unauthorized use of
your account, please (See Contact Information below).
The Step Up Service uses commercially reasonable security practices and procedures industry
practices and procedures designed to help keep your Personal Information safe and secure.
Unfortunately, the transmission of information over the Internet is not completely secure.
Although we strive to protect your Personal Information, we cannot guarantee the security of
your data while it is being transmitted to our Step Up Service; any transmission is at your own
risk. We will also ensure, on a commercially reasonable efforts basis, that any agent or third
party that we employ complies with the same security standards as we do for the protection of
your Personal Information.
Your information may be transferred to or may be maintained on computers, computer systems
and computer resources located outside of your state or country where the privacy laws may be
different (but no less stringent than the restrictions imposed by Indian law) as those where you
live. If you are located outside India and choose to provide information to us, please be aware
that the Step Up Service is hosted in India and that Platform keeps or transfers information to
and from India for storage and processing.
11. Cookies
A cookie is a small text file that can be stored on and accessed from your device when you visit
our Platform, to the extent you agree. The other tracking technologies work similarly to cookies
and place small data files on your devices or monitor your website activity to enable us to collect
information about how you use our sites. The information provided below about cookies also
applies to these other tracking technologies.
We and our service providers may uses cookies and other technologies to store information in
your web browser or on your mobile phone, tablet, computer, or other devices (collectively
"devices") that allow us to store and receive certain pieces of information whenever you use or
interact with our Platform. Such cookies and other technologies help us to identify and learn
more about our users and their likely interests, and to deliver and tailor marketing or
advertising. We also use cookies and other tracking technologies to control access to certain
content on our sites, protect the sites, and to process any requests that you make to us.
If you do not want cookies to be dropped on your device, you can adjust the setting of your
Internet browser to reject all or some cookies.
Please note that if your browser setting is already setup to block all cookies then some of this
site's features may not operate as intended.
If you want to remove previously-stored cookies, you can manually delete the cookies at any
time through your browser settings. However, this will not prevent the Platform from placing
further cookies on your device unless and until you adjust your internet browser setting as
described above.
12. Change in Privacy Notice
This Privacy Notice is subject to change from time to time. We reserve the right, at our sole
discretion, to modify the terms of this Privacy Notice from time to time in order to ensure
compliance with applicable laws or in response to changing regulatory or operational
requirements ("Updated Terms"). The Updated Terms shall be effective immediately (unless we
state otherwise) and shall supersede the terms of this Privacy Notice. We will notify you of any
changes to this Privacy Notice if the changes significantly affect your rights or as may be
required by law. Your continued use of the Step Up Service after any updates will mean you
have accepted those changes. If you do not agree to the updates you should stop using the
Service and cancel your subscription.
13. Contact us
If You have any questions about this Privacy Policy, the practices of Platform or Your dealings
with the Website, You can contact us at info@stepupedu.co.in or via the links at the bottom of
the page or you can write and send a letter to us at the below address :-
Step Up Education Consultants
9407 Garden Villas
DLF Phase 4
Gurugram 122009
Haryana,India.
Please do not share any private information at the above stated email id info@stepupedu.co.in
If you're not satisfied with our response to any complaint or believe our processing of your
information does not comply with data protection law, you can write to our Grievance Officer:
Ms. Monica on the email id info@stepupedu.co.in
