• User information, whether personally identifiable or not, is administered by or on behalf of the TakingCharge in association with its trusted business partners, service providers, affiliate(s), etcetera;
• Online coaching experience is regulated with respect to the payment, shipping, delivery of content placed on TakingCharge
• Features, information, products / listings – Coaching (audio or video based sessions), live stream, webinars, e-meetings, coaching packages any other related offerings and ancillary services (collectively the “Services”) are made available on the website via any internet connected device or web-platform.

The term “User” includes the Registered Users and also the Visitor(s) and the policies and the terms shall apply uniformly to all Users.

By accessing or using our Website or availing any of our services, to which this privacy policy applies, or otherwise providing us with information, you are unconditionally accepting and consenting to the application, usage, collection, storage, disclosure, transfer, transmission, distribution, retention, destruction and behavioural analytics of your information as described in this policy.

Please be aware that if you do not allow us to collect the requisite information, we may not be able to deliver certain services or platforms to you or customize the offerings based on your preferences.

This policy is effective from the date and time a user visits or registers with or accesses our Sites. Please read this Privacy Policy and other E-Commerce Policies hosted on the website of the TakingCharge carefully before using our Services. If you do not agree or have serious concerns regarding the terms of any our e-commerce policies, please do not further use or access our Sites (defined in Clause 2) or any of our platforms.

The E-commerce Policies including this document are an electronic record pursuant to the Information Technology Act, 2000 and rules made there under are applicable including any statutory modifications, amendment or re-enactment thereof. This electronic record is generated by a computer system and does not require any physical or digital signatures.

If any provision of this privacy policy or part thereof is inconsistent with or is held to be invalid / void or defective by or under any law, rule, order, or regulation of any Government or by the final adjudication of any court / tribunal, such inconsistency or invalidity shall not affect the enforceability of any other provision of the privacy policy contained herein.

Our failure to exercise or enforce any rights or provisions under this privacy policy shall not constitute a waiver of our right to enforce such rights or provisions subsequently.

• You would have accorded express or implied acceptance to our Privacy Policy
• You would have given us express permission to do so
• We may have a contract / agreement with you
• We must have provided or negotiated about any of our services or provided any ancillary support required by you
• You have engaged, inquired about or employed any of our services by availing any of our special / promotional offers or by visiting or contacting us

• Information provided by you
  We receive Personal Data from you with express permission, which means and includes, any data relating to identified or identifiable living person (‘data subject’ herein referred as you / your’) and any personal details that may have been voluntarily provided by the user for making use of our services.We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our website, register on the website, subscribe to our services, email us, complete an enquiry form, subscribe to the newsletter, respond to an optional online survey, fill out a form, report a problem with our Sites, or by corresponding with us through a phone call, e-mail, WhatsApp or any other means of digital communication or otherwise or, by interacting with any of our business partners, trusted affiliates, authorized persons engaged on our behalf and in connection with any activities, services, features or resources that we make available on our Sites. Users may be asked for basic personal and demographic information, as appropriate, such as name, date of birth, gender, email address, city, mailing address, pin code, contact number, educational qualification, areas of interest and skill development, financial information such as payment instrument related details to successfully process payment for the services subscribed by you and any other information which we may request and you may choose to provide to us from time to time with regards to your enquiry or request for any services, information or product.

Users may also visit our website anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identifiable information, except that it may prevent them from engaging with us on certain website related activities or otherwise access our services.

If you choose to sign in / register using your other social media accounts like Facebook, Gmail, etcetera to access our Sites, or otherwise connect your social media account with the services of our Sites, you consent to our retrieval, collection, storage, and use, in accordance with this Privacy Policy, of the data that you make available to us through the social media interface. Please see your social media provider’s privacy policy and help centre for more information about how they share data when you choose to connect your account.

In case you choose to decline to submit personally identifiable information on the Sites, we may not be able to provide certain services. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

We disclaim any liability arising out of breach of financial information given to unauthorized individuals via unofficial channels or any breach of trust or damages arising to the users thereby.

Further, we may collect non-personal identification information about Users whenever they interact with our Sites, as detailed in the Sections II & III below:

• Information collected about you
  We may receive information about you if you use our Sites or any other services we provide. We may automatically collect: technical, log and location information such as your computer’s/devices connection to the Internet, including the IP address, your computer’s name, your login information, browser type and version, time zone setting, browser plug-in types and versions, CPU speed, connection speed, operating system and platform, your device’s name, device’s serial number or unique identification number (e.g. UDiD on your iOS device), your device operating system, device’s – browser type and version, CPU speed, and connection speed etc. during your visit on our Sites; and other information about your visit, including the full URL clickstream to, through and from our Sites; materials you viewed or searched for, page response times, download errors, length of visits on certain pages, page interaction information, and methods used to browse away from the page and any phone number used to call our customer service number.We may collect additional information through marketing campaigns and publicly and commercially available sources and at other times, including but not limited to, when you provide feedback, comments, change your content or email preferences, or information regarding any other communications with us or during the usage of our Sites to communicate with other members, we also collect data about your communication and any other data you choose to provide. We reserve the right to monitor / record calls, chats, e-mails, etc between users and our service providers or business partners or coaches or instructors for quality checks and monitoring purposes. We may also conduct surveys and contests to collect information about user’s preferences; however, these surveys and contests are optional.We may combine this additional data with other data we receive from you.

  Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, and scribbles etc available on social platforms like Facebook, WhatsApp, Twitter, Instagram, Pinterest, Snapchat and the rest.

  Any posted / uploaded / conveyed / communicated information by users on the public sections of the Sites becomes published / public content and is not considered personally identifiable information subject to this Policy.

  Clear GIFs (Web Beacons)

  We may use “clear GIFs” (Web Beacons) to track the online usage patterns of our Users in an anonymous manner, without personally identifying the User. We may also use clear GIFs in HTML-based emails sent to our Users to track which emails are opened by recipients.

• Information received from other sources
  We may also receive information about you from other sources, add it to our account information and treat it in accordance with this Policy. In this case we will use the data received from third party sources, which may then be shared internally and combined with data collected on our Sites for better user association and engagement. We also work closely with third parties (including, for example, business-partners and associates in website-related, technical, technological, payment, and delivery related services, advertising and marketing networks, analytics providers, search information providers, credit reference agencies) and may receive or share information about you pursuant to our contract with them in furtherance of our services to you. However, it shall be on the basis that the third-party affiliates are required to keep the information confidential and will not use the information for any other purpose other than to carry out the services they are performing for us or on our behalf.We may refer other sources of demographic and other non-personally identifiable information to provide you with more targeted communications and promotions. We use Google Analytics, Facebook Pixels among others, to track the user behaviour on our Sites.If you provide information to the platform provider or other partner, to whom we are associated with, your account information and order information may be passed on to us. We may also receive data about you from third-party social networking services if you are already connected with those services.

Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer or device. The only personal information a cookie can contain is information you supply. A cookie cannot read data off your hard drive or device. Our advertisers and service providers may also assign their own cookies to your browser (if you click on their ads etc.), a process that we do not control.

By continuing to browse our Sites, you are agreeing to our use of cookies.

A user has the option of accepting or declining the cookies of this website by changing the settings of their browser. You can block cookies by activating the relevant setting on your browser that allows you to refuse permission to all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or certain parts of our Sites.

• To help us identify you and create a unique database about you for supply of Services and Products
• We use this information to carry out our obligations arising from any contracts / agreements entered into between you and us and to provide you with the relevant coaching instructions, services, information and products and you request from us as listed on our Sites or otherwise notified to you
• To identify individual users via e-mail confirmation or OTPs or otherwise to ensure the correct identity in order to facilitate the sale of or access to any of our services and products
• To improve our services by providing a personalised browsing experience in order to deliver or allow access to the most relevant services and information that meet the user’s requirements
• Information you provide helps us respond to your service requests and provide related assistance promptly and efficiently like helping you in subscribing to our services, customisation of a service, business co-ordination, quality control and feedback, payment related grievances, convey service-related detail / certifications / assurances, convey promotional offers and discounts, track your services / progress, etcetera
• For the purpose of contacting you to complete any transaction after having provided us with your contact information in the course of completing such steps designed for completion of the said transaction.
• Processing payment instructions including those through independent third-party service providers such as payment gateways, banking and financial institutions, pre-paid instrument, and digital wallet platform providers for the processing of payment transaction, EMIs / Credit Cards or any other deferral payment facilities, usage of cash backs / coupons / promotional offers during the placement of orders / subscriptions on TakingCharge
• For non-marketing and administrative purposes such as to gather feedback, grievance redressal in relation to coaching, instructions, orders, products, appointments, services, billing, content, debugging customer support related issues etcetera
• To improve our marketing and promotional efforts and to analyze Sites usage and improvise our services, content, and product offerings
• To improve the interface of our Sites based on your feedback and customise the Sites’ content, layout, and services.
• We may use information in the aggregate for internal operations, including troubleshooting, statistical research, business intelligence / behavioural analysis purposes such as to analyse the clickstream patterns and dates and times that our Sites are accessed and improve our services by understanding how our users collectively use and interact with the services, products and resources provided on our Sites. We may sell or transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates
• To allow you, when required, to participate in interactive features of our Sites; as part of our efforts to keep our Sites engaging, user-centric, safe and secure;
• To run a quiz, promotion, contest, survey, forums, blogs etc on any of our Sites
• To send Users information they agreed to receive about the latest business related news, updates, offers, events, and products or service related information, etc, along with an option to unsubscribe as detailed further below in this policy
• To provide you with information about other services and affiliated products / packages we offer that are similar to those that you have already availed / purchased or enquired about and to provide you, or permit selected third parties to provide you, with information about goods or services which we feel may interest you
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; to make suggestions and recommendations to you about goods or services that may interest you
• To use the information derived from “clear GIFs” (Web Beacons) to inter-alia deliver our web pages to you upon request, to personalise our Sites or Service to the interests of our users, to measure traffic within our Sites to improve the quality, functionality and interactivity of our Sites and let advertisers know the geographic locations from where our Users come without personally identifying the Users in order to honour our agreements with them and establish the effectiveness of advertisements on our platform.

If at any time the User would like to unsubscribe from receiving future emails, they may contact us via our Sites as detailed further below in this policy.

You agree that we may use your personal information to contact you and deliver information to you that, in some cases, are targeted to your interests, such as targeted banner advertisements. By accepting this Privacy Policy, you expressly agree to receive this information. If you do not wish to receive these communications, we encourage you to opt out of the receipt of certain communications by altering your profile settings or as advised further below in this policy. You may make changes to your profile at any point of time.

• To provide services or products you’ve requested or to enter into or enforce mutually accepted contracts or agreements
  We seek to share User Information to conduct our business and to share such information with its coaches, instructors, affiliates, business-partners, and officers and employees and/or of its third-party affiliates for the purpose of processing personal information on its behalf to provide the Services requested. We provide reasonable access to your Personal Data in good faith only to those parties, who need to know that data in order to fulfil their jobs to provide, operate, develop, or improve our services or products. We also ensure that these recipients agree to process such information based on our instructions and in compliance with this Policy and any other reasonably appropriate confidentiality and security measures. We make user information accessible to our coaches, instructors, employees, business-partners, agents, or partners and third parties only on a need-to-know basis and we also bind them to reasonable confidentiality obligations.We may share the information that we collect from you with coaches or instructors that developed or offered the coaching that you are taking to enable them to coach, manage or otherwise oversee the coaching, assess your performance and to otherwise support users in any other manner whatsoever. Also, we may archive this information and/or use it for future communications with you.We provide the data to trusted partners i.e. our coaches, instructors, business partners, agents, suppliers, contractors/sub-contractors, service providers, professional advisors, technological partners, (hereinafter referred to as “affiliates”) for the performance of any contract or any potential contract we may enter into with them or you, or in relation to any ancillary requirements “on need” basis. Some of these affiliates work on behalf of or with the TakingCharge pursuant to the understanding that they are required to keep the information confidential and will not use the information for any other purpose other than to carry out the services they are performing for us nor do they have any independent right to share this data. These affiliate parties may use your Personal Data to help us communicate with you about requested services, upcoming events and latest offers from our TakingCharge and about the products/services of our marketing partners.

  We also collate and process the updated information received from you, from time to time, to establish effective communication, maintain databases and enable the seamless flow of information about products and services.

• When we have your express permission in the context of your consent to our Terms of Use and Privacy Policy
  We may also share generic aggregated demographic and statistical information not personally identifiable regarding visitors, users and on traffic to various pages within our Sites with our Business-partners, trusted affiliates/third parties and advertisers and advertising networks for the purposes of directing targeted advertisements relevant to your interests and to help them understand our audience and confirm the value of advertising on our Website. We may share your information with third parties like Analytics and search engine providers for the limited purpose of assisting us in the improvement and optimisation of our Sites.
• Other circumstances
  We may store or transfer user’s information to and from Sites hosting partners and other parties who assist us in operating our platform, conducting our business, analysing your data, or servicing you, as long as those parties agree to keep this information confidential. To the extent necessary to provide users with the Services through our Sites, we may provide the user’s personal Information to third party contractors who work on behalf of or with us to provide the users with such services and to help us communicate with Users or to maintain the Sites or with independent third-party service providers to process payment instructions including providing a payment deferral / promotional / partnership / strategic tie-up related facility to users in relation to our Services. These third-party service providers have access to only information which is necessary for fulfilment of the contract or payment or promotional or tie-up activity. Generally, these contractors do not have any independent right to share this information; however, certain contractors who provide services through our Sites or other web-platforms may use and disclose the personal information collected in connection with the provision of these services through TakingCharge in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your Personal Information to such parties, solely for the intended purposes only.We will however not be responsible for the confidentiality, security, or distribution of your Personal Information by our coaches, instructors, partners and third parties outside the scope of our agreement with such partners and third parties. We shall not be responsible for any breach of security or for any actions of any third parties.We aim to fully comply with all applicable Indian laws and we strongly believe in the protection of privacy of users in conjunction with the Law enforcement agencies by extending our sincere cooperation. We respond to legal obligations including but not limited to subpoenas, court orders, inquiries / show cause notices from Government Authorities and law enforcement authorities for legal processes. We believe it is necessary to share data in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the physical safety of any person or any other requirement by law. We may disclose all or part of your personal details in response to a request from the Government Department / law enforcement agencies or in case of a bona fide requirement to prevent an imminent breach of law. This will also include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

  We may also share information in order to establish or exercise our legal rights or defend against legal claims where it becomes necessary to do so and to enforce or apply or protect against violation of our privacy policy or other e-commerce policies hosted herein and any other agreements entered with our business-partners or otherwise; or to protect the rights, property / intellectual property, or safety of TakingCharge, our users / customers, business-partners, coaches, instructors, associates, employees, directors or officers or others when we have reason to believe that disclosing information of User(s) is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or our Sites, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

  We may also transfer data about you in the circumstances that our business is acquired by or merged with another enterprise. If we sell our business operations and any/all of our assets are acquired by a third party, your personal data may be one of the transferred assets. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other user information provided to us.

Some of the ads may also be served by Google. Google’s use of the DART cookie enables it to serve ads to Users based on their visit to our Sites and other websites / mobile applications on the Internet. DART uses “non-personal identification information” and does not track personal information about you, such as your name, email address, physical address, etc. You may opt out of the use of DART cookie by managing your Ads settings by visiting the Google’s ad and content network privacy policy or relevant webpage operated by Google in this regard.

Further, we do not accept any liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential, punitive, or exemplary loss, damage or expenses) from your use of any third party website or any application or inability to use such platforms of any party, howsoever arising, and including any loss, damage or expense arising from, but not limited to, any defect, error, omission, interruption, imperfection, fault, fraud, mistake, unavailability of, inadequacy or inaccuracy with any online website, application, its contents or associated services and products.

We have put in place reasonably adequate security practices, appropriate procedures and confidentiality measures commensurate with respect to the nature of our services and information collected, such as – organisational, managerial, operational, administrative, physical, technical and technological safeguards against unauthorised access, alteration, accidental loss, disclosure or destruction and unlawful processing of your personal information, username, password, contact information, coaching related information, progress report, transaction information and any other data stored on our Sites. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered by us is securely stored within controlled databases.

However, as effective as our security measures are, no security system is impenetrable. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data transmitted to our Sites and any transmission of your Personal information is at your own risk. And, of course, any information you include in a posting to the publicly accessible areas is available to anyone with internet access.

Your personal information processed by us is kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data is processed in line with legal, regulatory, contractual or statutory obligations as applicable. At the expiry of such periods, your personal information will be securely disposed of at the end of such records retention period.

You are requested to help us protect your data privacy by maintaining the secrecy of the username and password that you use for any of our Services. You are solely responsible for maintaining confidentiality and accuracy of the username, password and any other user identification and all activities and transmission performed by the user through their user identification. It is your responsibility to ensure the privacy and security of your email account and phone calls and messages so they cannot be accessed by third-party. Be sure to log off from the Sites when not in use.

We will use your email or phone number or any other applicable channel to communicate with you regarding information related to the services and products availed. We shall not be liable for any breach in confidentiality or data loss or theft, should your email or messages or phone or computer / electronic device be accessed by any third-party, with or without your consent.

We do not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify us by sending an email to natty@takingcharge.in You shall be liable to indemnify us due to any loss suffered by us due to such unauthorized use of your account and password.

You shall also be solely responsible for carrying out any transaction involving credit cards / debit cards or such other forms of instruments or documents for making any financial transactions with us and we assume no responsibility or liability for the improper use of information relating to such usage of credit cards / debit cards or any other information used by the user. A user always has the option of not providing the information which is not mandatory.

We will not be responsible for any personal data transmitted to a third party as a result of incorrect account related information.

The user’s information is purported to be collected, protected and kept in the country of service provision, i.e., in our case – India in congruence with the applicable laws prescribed in this country. Your information may be transferred to or be maintained on computers, computer systems and computer resources located outside of your location or country where the privacy laws may not be as protective as those where you live. If you are located outside India and choose to provide information to us, please be aware that we ultimately transfer, protect and keep information in our databases in India and also process it here. Your submission of such information represents your agreement to such transfer, processing and retention by us at our preferred location.

Notwithstanding anything to the contrary contained herein or the other e-commerce policies, neither party shall be liable for any delays or failures in performance of any service or any loss, damage or misuse of a user’s sensitive personal information resulting from acts beyond its reasonable control including without limitation, acts of God, fire, flood, explosion, sabotage, pandemics, acts of war, insurrection, or terrorism, shortage of supply, labour difficulties or civil unrest, breakdowns or malfunctions in business units, internet, connectivity issues, interruptions or malfunction of computer facilities, computer hacking, technical glitches, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption or loss of data due to power failures or mechanical difficulties with information storage or retrieval systems. Notwithstanding the foregoing, in the event of such an occurrence, TakingCharge agrees to make unguaranteed reasonable effort in good faith to perform the services and obligations applicable.

• Effectiveness of the Coaching / Instructions undertaken by users
• Non-infringement of third-party rights
• Sites’ complete freedom from all computer viruses and
• Any other violation of user rights regarding Services and Products or any other information or contents of Taking Charge

Hence, we do not guarantee or warrant or accept any responsibility or liability for the accuracy, completeness, adequacy or currency of the services, products or information or content posted on our Sites. Users are advised at all times to undertake their own due diligence, inspection or investigation for relying on any information or subscribing to any services made available on our Sites.

• Should You Want To Opt Out
  If we possess your contact information, we would want to keep you posted about our services, products, packages, and events, etcetera. Should you prefer not to keep up to date with our latest offerings or receive such marketing / promotional materials on your email, please send a request to unsubscribe at natty@takingcharge.inHowever, such withholding of information or withdrawal of consent may result in us not being able to provide services and facilities and we reserve the right to take appropriate action in terms of communicating you with respect to any obligations in relation to any subscription / contract / orders placed or the exigency of the communication required.We will update your preferences as soon as reasonably practical. However, do note, if you opt out of our emailing list, as described herein, we may not be able to remove your Personal Data from all databases of our TakingCharge or of our business-partners, affiliates and third parties. We may reasonably try to erase your data as requested; however, we do not guarantee the total elimination of your data from all the databases that it may have been a part of.
• Rights regarding Personal Information
  When you use our Sites or Services, we take efforts in good faith to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information provided and subsequently found to be inaccurate or deficient and requested for change thereupon shall be corrected or amended or you may be given a reasonable access as feasible, subject to any requirement for such personal information to be retained or for legitimate business purposes. You have the general right to access and request rectification, erasure and restriction of processing and withdraw consent regarding your personal data (“requests”).We may ask individual users to identify themselves and the relevant information before the said requests are accepted. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical or for which access is not otherwise required. In any case, where we provide information access correction and erasure, we perform this service free of charge, except if doing so would require a disproportionate time or effort. Because of the robust and secure way of maintaining user databases, even after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may still remain in any of our backup systems. You consent to the possibility of such inadvertent retention of residuary information.
• Grievance Redressal and Contact Information
  We have a grievance redressal mechanism and a dedicated Grievance Officer for resolution of user’s requests and concerns. Questions, concerns, comments and requests regarding this Privacy Policy or any of the other E-commerce Policies or our services, products and/or content are welcomed and should be directed to Mr. Natarajan Viswanathan (Grievance Officer at TakingCharge) through an email at natty@takingcharge.inAny communication relating to the grievances or concerns, which is not addressed to this e-mail address, shall not be treated as a valid and binding for the purpose prescribed above.We will take all suitable efforts to get in touch with you and address your requests as soon as reasonably possible.