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100 Canal Pointe Blvd. Suite 123, Princeton, NJ 08540 | © 2022 LearningMate. All rights reserved. Privacy Policy | CSR Policy | DEI Policy

Privacy Policy

1 Introduction

LearningMate respects your privacy and is committed to protecting your personal data. This Privacy Policy below describes how we look after your personal data when you visit our website or access our services and products by any other means. This Privacy Policy applies to all information we collect using our parent website, www.learningmate.com, as well as any related sites, services and products.

We review our privacy policy periodically. This version was last updated on April 18th, 2019.

You can access previous versions of our privacy policy at https://learningmate.com/privacy/archive

CONTACT US

For the purpose of this Privacy Policy, LearningMate is the controller of and responsible for your personal data (and may be referred to as “we” “us” or “our”).

If you have any questions about this privacy policy or how your personal data is handled, please email LearningMate’s data privacy manager at dpo@learningmate.com We would appreciate an opportunity to address your concerns before you approach a supervisory authority.

2 Collection of Personal Information

To facilitate access to our products and communication around our services, LearningMate may ask you to provide information that personally identifies you (“Personal Data”). This occurs in certain circumstances such as when you request information via our website, register for a demo, or create an account to access one of our products.

Personal Information or personal data means any piece of information about an individual from which a person can be identified. It does not include data where the identity has been removed (anonymous data).

Examples of personal data include : Name, Address, Telephone Number, Date of Birth, Personal Identification Numbers (SSN, Passport, Taxpayer Identification number etc.), Photographic Images, log in details etc.

LearningMate may collect, use, store and transfer different kinds of personal data about you as follows:

Type of Information collected	Purpose
Full Name (First Name + Last Name)	1. To identify the data subject 2. To send relevant offers 3. To send marketing emails
Email	To send data subjects emails about the products

Information that is collected through automated means:

Type of information	Purpose
IP address	LearningMate use IP address for traceability.
Browser types	LearningMate use data subject’s browser types for better experience.
Browser version	To identify the operating system and screen size of your device to ensure all content renders appropriately.
Google Analytics Information	The pages of our site that you visit, the time and date of your visit, the time spent on those pages and other statistics
Geographic location	For language preference settings
Social networking plugins	To redirect the data subject onto one of our social media pages

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with goods and services). in this case we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3 Methods of collection

Method	Purpose
Web Form	If you request additional information via a web form, we collect personal information such as your name and email address to facilitate your request
Book Fairs	We collect corporate information of the data subjects from book fairs for the purpose of business to business communication

4 Cookies

Refer to the Cookie Consent tool on the web site

5 Use of Personal Information

To help you quickly find information regarding the products, services or content available on the LearningMate Website.
Respond to support requests.
To share the content most relevant to you.
To send communications related to our businesses such as product or service updates, special offers, upcoming events, and company news. You may unsubscribe from any of these communications at any time using our email preferences page.

We may use data generated from our web properties to make automated decisions that help us personalize the type of content we share with you.

Occasionally, we publish customer testimonials on our website. These may include your personal information; however, we will not publish any personal information on our web properties without obtaining prior consent via a release form.

The personal information collected by LearningMate and stored by LearningMate and its 3rd party vendors is only used in compliance with this privacy policy.

6 Sharing of Information

LearningMate does not sell or rent any of data subject’s personal information. However, LearningMate may store certain personal information with its appointed third parties in concurrence with this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7 Children under the age of 13

This website is not intended for children and we do not knowingly collect personal information from children under the age of 13.

If you are under 13, do not use or provide any information on this platform or on or through any of its features/register on the platform, make any purchases through the platform, use any of the features of this platform or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at communications@learningmate.com.

8 Your legal rights

You have rights towards your personal data subject to local data protection laws These include:

Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact dpo@learningmate.com.

At any time, you may unsubscribe from LearningMate’s marketing communications by clicking the Unsubscribe link at the bottom of our communications, or by sending a request to communications@learningmate.com .

9 How long we keep personal information for?

LearningMate will only hold your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.]

In some circumstances you can ask us to delete your data: see [section 8] above for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10 International Transfers

We store data collected from this website within the borders of the United States of America.

Any data transfers to other countries will be made only after taking the explicit consent of the data subject. LearningMate might not take consent from the data subjects if feels that such transfers are essential to protect the vital interests of the data subject or if such transfer is required to make the data available to a legal or regulatory body that has jurisdiction over it. Data subjects will be informed in case of such transfers.

11 How we secure your Personal Data

We take precautions which include security process, technical and physical measures to help safeguard your information against any accidental or unlawful destruction, alteration and unauthorized disclosure of the personal data we process,.

While we follow generally accepted security standards to protect your data, we also expect you to protect your password, limit access to your device and sign out of websites after your sessions.

12 Changes to This Privacy Policy

This Privacy Policy is effective as of Monday April 7th, 2019 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

LearningMate reserve the right to update or change Privacy Policy at any time.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided to us, or by placing a prominent notice on our website.

Annexure – 1

How to contact LearningMate:

email: communications@learningmate.com & dpo@learningmate.com

United States

LearningMate Solutions Inc.
880 Third Avenue, 18th Floor, New York, NY 10022

Canada

LearningMate Solutions (Canada) Ltd.
128 West Hastings Street, Suite 210
Vancouver BC Canada V6B 1G8

UK

LearningMate Solutions (UK) Ltd.
1 Doughty Street, London WC1N 2PH, United Kingdom

India:

LearningMate Solutions Pvt Ltd.
74 Techno Park, Level 7-10, 74/II, ‘C’ Cross Road, M.I.D.C. Marol, Andheri (East),
Mumbai 400 093, India

Annexure – 2

Regulatory agency contact in the UK

Supervisory Authority: Information Commissioner officer
Email: casework@ico.org.uk

Annexure – 3

Data Protection Officer Details

Name: Ajay Mendes
Email: dpo@learningmate.com

CORPORATE SOCIAL RESPONSIBILITY POLICY

Definitions

Board means the Board of Directors of the Company.

Company means ‘LearningMate Solutions Private Limited’

CSR Activities means the activities which are undertaken or to which allocation is made by the Company under this CSR Policy, as amended from time to time.

CSR Committee means the Corporate Social Responsibility Committee of the Board of Directors of the Company.

CSR Policy means this Corporate Social Responsibility policy of ‘LearningMate Solutions Private Limited’ as amended from time to time.

CSR provisions means the regulatory provisions governing the CSR activities including the relevant section, rules and schedule under the Companies Act, 2013 or any other act or law as is applicable from time to time.

The Philosophy

As the world’s largest supplier of education technology solutions to the education industry, LearningMate knows how to deliver unique solutions and innovations that facilitate learning. One of the handful CMMI Level 3 certified companies in this space, LearningMate has developed world class processes to help deliver your education technology solutions from start to finish.

Since our inception in 2001, we have focused on education as our primary market. Today we have over 500+ professionals across three countries focused on solving complex learning, content and technology problems. This creates a powerhouse of ed-tech experience that we bring to bear on every customer engagement.

It has always been the endeavour of the Company to be at the forefront with regard to Social and Environmental responsibility. As a responsible corporate citizen, we aim to contribute to social and environmental causes on a regular basis. For us Corporate Social Responsibility (CSR) is an added opportunity to bring value to our stakeholders’ lives and in a small possible way bring about a difference that we all want to see and be. We have been contributing to society since various years. 3

Scope and Applicability

The Policy shall be applicable to all CSR initiatives and activities undertaken by the Company for the benefit of the different segments of the society.

Allocation of Funds

The Company shall spend not less than 2 % of its average net profits for the immediately preceding three financial years or such other minimum amount as specified under the CSR Provisions.

Provided further that the allocation of the funds for CSR activities shall not be at the cost of or in place / stead of the statutory / contractual obligations of the Company towards the government, banks and financial institutions.

Provided further that the surplus arising out of the CSR Projects or Programs or Activities shall not form part of the business profits of the Company.

Provided further that for building up CSR capabilities of its own or that of an outside agency, the Company shall not spend more than 5% of the amount allocated for CSR activities.

Constitution of the CSR committee

Keeping in line with Section 135 of the Companies Act, 2013 (hereinafter referred to as ‘the Act’) read with the applicable rules thereon and any statutory amendments thereto, the Corporate Social responsibility Committee of the Company would consist of the Board of Directors of the Company in light of the private character of our organization.

The Board shall carry out the following functions:

To formulate and recommend to the Board, a Corporate Social Responsibility Policy;
To recommend the amount of expenditure to be incurred on the activities;
To monitor the Corporate Social Responsibility Policy of the Company from time to time.
To formulate action plans to undertake CSR initiatives from time to time as per prescribed specified schedule.
To also decide on the amount of expenditure to be incurred on the initiatives referred to above.
To take stock of the progress of the initiatives and to monitor the implementation of the scheduled initiative.

CSR Initiatives and programs

The CSR committee of the Company will keeping in view, the Companies Act,2013, the Companies (Corporate Social Responsibility Policy) Rules, 2014, any amendment(s) thereto and also pursuant to Schedule VII to the Act recommend and proceed to carry out any of the following activities from time to time as the Committee deems fit:

Eradication of hunger, poverty and malnutrition, promoting healthcare including preventive healthcare and sanitation and making available safe drinking water.
Promoting Education including special education and employment enhancing vocation skills especially among children , women, elderly, and the differently abled and livelihood enhancement projects
Promoting gender equality , empowering women , setting up homes and hostels for women and orphans ; setting up old age homes , day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups
Ensuring environmental sustainability ecological balance protection of flora and fauna , animal welfare , agroforestry , conservation of natural resources and maintaining the quality of soil, air and water
Protection of national heritage , art and culture including restoration of buildings and sites of historical importance and works of art ; setting up of 6 public libraries ; promotion and development of traditional arts and handicrafts
Measures for the benefit of armed forces veterans , war widows and their dependents
Training to promote rural sports, nationally recognized sports, Paralympic sports and Olympic Sports
Contribution to the Prime Minister’s National relief fund or any other fund set up by the Central government for socio economic development and relief and welfare of Scheduled Castes , the Scheduled Tribes , Other backward classes , minorities and women;
Contributions and funds provided to technology incubators located within academic institutions which are approved by the Central Government.
Rural Development Projects

Fields of Operation of CSR Activities

Within the framework of the CSR provisions, especially schedule VII of the Companies Act, 2013, the CSR Committee shall have full authority to choose and Implement CSR activities / projects / programs even if such activities / projects /programs do not fall within the preferred fields as mentioned above.

CSR in collaboration or through a medium

The CSR Committee will decide the mode of execution of such activities /projects i.e. whether such activities will be carried out by a registered and approved trust or society or a company with an established track record of not less than three years in undertaking similar programs or projects or they will be carried out by team of persons specifically formed for such purpose(s) or such other mode as is within the scope of the CSR Provisions and most suitable for execution of that particular activity / project.

The CSR Committee may also decide to contribute the entire or part of the amount to any fund as is within the scope of CSR Provisions

Prohibited Fields of Operation for CSR Activities

The Company shall not make any allocations to or undertake any CSR activities, programs or projects which are :

For the benefit of any particular political party, front or ideology.
For the benefit of any particular religion, religious belief or religious sect. – For the benefit of any particular caste or community.
For the sole benefit of employees of the Company.

Also, the Company shall not make any allocations to or undertake any CSR activities which are outside the scope of the CSR provisions, especially schedule VII of the Companies Act, 2013.

REPORTING AND MONITORING OF CSR ACTIVITIES

In case of closed ended projects / activities, the CSR Committee will, in consultation with the trust / society / team carrying out the implementation of the CSR activity (the Implementing agency) decide about the time limit within which the CSR activity / project is to be completed.
Depending upon the time period for completion of the activity / project, the CSR committee will decide upon the reporting frequency. For instance for shorter project / activity (say for one year or less) the reporting frequency may be quarterly or even monthly. For a project / activity of a medium duration (say for two to three years) the reporting frequency may be half yearly. The reporting frequency may be yearly for a project or activity of a longer duration (say three years or more). In case of a continuous CSR activity, the frequency of reporting shall be half yearly.
In case of contribution to certain funds, it may not be possible to insist on segregated reporting. In such a case, the reason shall be recorded by the CSR Committee.
The implementing agency shall report the progress in the format annexed to CSR Policy.
Wherever feasible, the CSR Committee shall depute one of the senior employees of the Company to make site visits, check the records of the Implementing agency or undertake any other due diligence activity to ensure the veracity of the information reported by the Implementing agency and / or generally to verify the progress of the CSR activities. REMOVAL OF DIFFICULTIES
Any term not defined in the CSR Policy shall have the meaning ascribed to it under any of the CSR Provisions.
The Board shall have power to amend / modify any of the clauses of the CSR Policy and they may do so either at a Board Meeting or by way of a Circular Resolution.
The interpretation of any of the terms / clauses etc. of the CSR Policy shall rest with the CSR Committee

DEI POLICY

LearningMate is an equal-opportunity employer. We commit to celebrating diversity, equity, and inclusion in the workplace. We do not tolerate discrimination and harassment of any kind based on race, color, sex, religion, sexual orientation, national origin, disability, genetic information, pregnancy, or any other protected characteristic as outlined by federal, state, or local laws. LearningMate makes hiring decisions based solely on qualifications, merit, and business needs at the time.

POSH POLICY

LearningMate is committed to maintaining high standards of workplace safety through sound people practices, policies, and measures. We have a zero-tolerance policy against sexual harassment and a dedicated internal complaints committee is appointed to extend guidance and help for any incident of sexual harassment regardless of gender, age, seniority, or any other such particulars. We follow the law that we operate in and comply with the same with the utmost level of caution and attention. Our policy is gender-neutral, and the ICC committee is trained to handle PoSH cases with competence. To create a workplace that safeguards the dignity and respect of every member against unlawful discrimination is our foremost priority. In case of any concerns please drop an email to posh.committee@learningmate.com