WHAT DOES COURSE5 INTELLIGENCE DO?
Course5 Intelligence (hereinafter “Company” or “We”) is a global analytics provider that drives digital transformation through analytics, insights, and Artificial Intelligence (AI). Course5 Intelligence helps businesses make the most effective strategic and tactical moves relating to their customers, markets, and competition. Course5 Intelligence helps clients achieve a 360-degree view of their customers through data integration from multiple data sources and a disciplinary approach.
Course5 Intelligence leverages rapid advances in Artificial Intelligence and Machine Learning to create disruptive technologies and accelerators for analytics, digital, and research solutions that provide significant and long-term value to their clients. Course5 Intelligence is a trusted partner for leading global firms and empowers clients with industry-leading products and solutions in customer analytics, digital analytics, and marketing analytics.
As a part of its activities, Course5 Intelligence undertakes the following activities involving the collection and processing of personal data of individuals:
- Provision of a website under www.course5i.com to interact with prospective customers and the general public for dissemination of information related to its business activities and services offered to different segments of the market.
- Enrolling individuals to different survey programs for conducting market research as required by its clients.
- Conducting primary market research for information available in public domains and aggregating the fragmented information into productive forms of data sets.
The Policy gives general direction to the organization to establish and maintain its data privacy framework to protect PII (Personally Identifiable Information). Additionally, specific parts of the policy may be applicable to specific types of data subjects whose personal data may be processed by the Company.
The terms of this policy will be applicable to all the data subjects including those residing and located in the European Union and would replace the existing EU Data Protection Directive (46/95/EC). The intent of this policy is to make you are aware of the rights that have been granted to you as data subjects whose personal data may come to the possession of the Company either because you are visiting the website of the Company or availing various services that are being provided by the Company.
HOW DO WE COLLECT PERSONAL INFORMATION?
- Visitors to the Website:
- Individuals who are enrolled for participation in specific surveys:
- Information Collected from Third parties
- Information Collected from Public Domain
When a visitor browses through the website, https://www.course5i.com/, the server automatically collects certain technical information such as the IP address, the type of the browser and device used for browsing, the referral page, the time spent on the website, the different pages visited on the website, the hyperlinks clicked etc. Such information does not include the identity of the visitor.
The information so collected is used for the purpose of improving the browsing experience of visitors and for statistical purposes.
During the course of a visit to our website, if the visitor opts to receive any content over e-mails and submits his name and e-mail address, such information of the visitor submitted voluntarily is recorded and used for the purpose of communicating with the visitor as required to meet the request of the visitor.
The name of the visitor as declared by the visitor and the e-mail address as declared by them for receiving the information are stored as long as required to identify multiple requests being made by the same person which could have a degrading effect on the service to the detriment of other visitors.
As part of the activities of the Company, Course5 Intelligence enrolls individuals for participating in different surveys. In such surveys, specific queries may be made and answers obtained from the participants of the surveys. Such information is processed to understand the responses based on different parameters of the respondents such as gender, age, occupation, location etc. The aggregated information without the identity of the respondents may be collated into a research report and shared with the customers of the Company.
The information so processed would be retained in the Company as long as required to prevent duplication of similar efforts.
The responses of the individual respondents are in aggregated, anonymized state and are not associated with any specific data subject.
We use 3rd party services and tools to execute various marketing research & analysis initiatives. You are requested to visit the respective privacy policies wherever required.
The Company collects personal information about an individual through third parties as per instructions provided by such third parties who act as “Data Controllers” and assume responsibilities for regulatory compliance through a contractual document. In such cases, our responsibilities are limited to that of a contractual data processor and every effort is taken to ensure that the privacy of the individuals is protected as required under the applicable law.
The Company uses information available in public domain such as social media platforms or other public repositories of data as part of its research process. Information so gathered in such research exercises are treated as information made available by the data subject in public domain.
The Company has designed its processes in such a manner that when personal information collected from public domain is desired to be used for any services of the Company, a request for the consent would be sent obtained where the contact information is available.
Where the request for consent sent in such cases remain unresponded, the information which appears like personal information is deemed to belong to a non-existent individual will not be processed.
Subject to the above general principles, the Company brings to the notice of the data subjects the following additional information as a measure of abundant caution.
WHAT INFORMATION WE COLLECT
- We may collect your contact information such as full name, company name, email address, postal address and telephone number when you email or call us with an enquiry or an application for work.
- We may process your information on behalf of our clients who have lawfully collected your information for the purpose of asking you whether you would like to participate in market research, consultancy projects, advisory boards, or events. This information may include your full name, job title, company name, email address, telephone number, postal address, and may also include information about your area of specialization or health status.
- We may also collect your details from publicly available sources or purchase lists from suppliers operating within data protection regulations.
- When we conduct market research we may collect additional information from you with your valid consent. You will be provided with the full details of the information we wish to collect at the time we ask for your consent.
- In addition to the above, we collect information automatically about your visit to our website. Please see our Cookies Policy for more details.
The personal information we collect would be used for the following purposes:
- Dealing with enquiries and requests about our services submitted to us via email or call.
- Sending you information about our services that is applicable to you in your role.
- Requesting information about your services that is applicable to you, your company, our company and our clients.
- Conducting market research surveys; we will always ask for your consent to do so.
- If the law requires us to do so.
- If we have a legitimate interest in processing your data such as direct marketing, market research, data analytics, business intelligence, data engineering etc.
- To send you newsletters, e-mails relating to participation in any of our events or surveys, our proprietary product-related information, promotional events.
- To assess applications for jobs we have on offer.
We process this information to ensure that you receive the relevant aspects of our services and also to identify and stop the misuse of any data shared with us.
Our legal basis for processing your personal information is:
- Where you have given consent for the processing of data for a specific purpose.
- Processing is necessary to meet contractual obligations entered by you.
- Processing is necessary for purposes of ‘legitimate interest’ pursued by our company where these interests are in relation to goods and services that you use in your role, or are in relation to your application for a job.
‘Legitimate interest’ pursued by us would include:
- Response to an enquiry from you about our products and services.
- Enquiring about your products and services which are applicable to our company or our clients. We will always confirm how your personal information was obtained and always offer an opt-out from marketing communications.
- Response to your application for a job that we have advertised or contacted you about.
You, as a data subject, may register on our website and, in doing so, may share your personal data with us. The personal data that is communicated to us is determined by the respective sign-up form used for the registration. The personal data entered by you is collected and stored in accordance with GDPR (General Data Protection Regulation). We may transfer your data to one or more processors for legitimate purposes by keeping you informed of the purpose for which we are sharing the information. By registering on our website, the IP address assigned to you by your internet service provider (ISP) is stored with us along with the date, and time of the registration. The storage of this data takes place against the background.
Your registration on our website is intended to enable us to offer you content or services that may only be offered to registered users due to the nature of the matter in question. You, as a registered user, are free to change the personal data specified during the registration at any time or to have the data completely deleted from our database.
We shall, at any time, provide you with information upon request as to what personal data is being stored about you. In addition, we shall correct or erase personal data, insofar as there are no statutory storage obligations. The Designated Data Protection Officer (DPO) can be contacted by the data subject in this respect as contact persons.
As a part of our services offering, you may be sent our newsletters or product and services related information. We keep our customers and vendors informed by means of a newsletter about any enterprise offers or latest developments in the area of our expertise including but not limited to any upcoming events that we may be attending on a global scale. You may receive our newsletters only if (1) you have a valid e-mail address and (2) you register for the newsletter mailing. A confirmation e-mail will be sent to the e-mail address registered by you for the first time for receiving the newsletter through e-mail via a double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
You may terminate the subscription to our newsletter at any time. The consent to the storage of personal data, which you have given for e-mailing the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link (unsubscribe) is found in each newsletter.
SOCIAL MEDIA INTEGRATION
In order to enhance your experience while accessing this website, we have assimilated certain aspects of LinkedIn into our platform. LinkedIn being a professional networking site uses its proprietary technology to connect businesses and professionals.
LinkedIn is based out of California USA and its Ireland based-entity is responsible for handling privacy matters outside the USA. We have integrated a LinkedIn plugin into our website which enables you to directly register and log into the website through your LinkedIn account. By doing so LinkedIn would gather knowledge around the specific pages that you have visited on our website during the entire time of your browsing on our platform if you are logged into your LinkedIn account during the time of your browsing.
We also have integrated as well into our website Google Remarketing Services which is an extension of Google AdWords. By having these services integrated with our platform, Google would be capable of displaying relevant advertisements to you based on your preferences and browsing habits.
HOW DO WE PROTECT YOUR INFORMATION?
We regularly review our compliance with our privacy practices. We also adhere to regulatory framework including GDPR (General Data Protection Regulation) and other applicable regulations around private data protection.
Course5 Intelligence is an ISO:27001:2013 certified company and we take adequate steps to help protect your personal information; however, you acknowledge that no company can fully prevent security risks and we do not under any circumstances represent that the website is free from any harmful elements including but not limited to viruses, spyware, cancelbots, Trojans and such application which may be placed on the website without the knowledge of the Company; however the Company shall take all necessary and reasonable steps mentioned below to ensure that the website is free from the above-mentioned programs.
Couese5 Intelligence has implemented necessary Administrative, Management and Technology controls to secure the data. In pursuance to the GDPR and CCPA, we would be taking the below steps to ensure that your data is safe and secure while it is with us:
- We use pseudonyms to encrypt sensitive & special categories of personal data.
- We maintain ongoing confidentiality, integrity, availability and resilience of processing systems and services.
- We have the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
- We have a dedicated process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of processing your data.
- We have contracts with third parties to ensure that the same level of protection is accorded to the data transferred to third countries or international organizations.
- In case if your data is being shared with any third party then you would specifically be made aware of the names of such third party to whom your data is being shared after receiving explicit consent from you.
Where we have given you (or where you have chosen) a password that enables you to access all or certain parts of our website, you are responsible for keeping this password confidential. We strongly suggest that you do not share your passwords with anyone.
Course5 Intelligence complies with the privacy requirements as set forth by the European Union’s data protection regulation GDPR (General Data Protection Regulation) regarding the collection, use, and retention of personal information. Course5 Intelligence ensures adherence to principle listed below,
- Personal information is processed lawfully, fairly and in a transparent manner in relation to the data subjects (“Lawfulness, fairness and transparency”)
- Personal Information is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (“Purpose limitation”)
- Personal information is adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed (“data minimization”)
- Information is accurate and where necessary, kept up to date; every reasonable step is taken to provide that personal information which is inaccurate, having regard to the purpose for which it is processed, is erased or rectified without delay (“accuracy”)
- Information is kept in a form which permits identification of data subjects for no longer that is necessary for the purpose for which personal data is processed (“storage limitation”)
- Information is processed in a manner that ensures appropriate security of the personal data, including protection against the unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organization measures (“Integrity and confidentiality”)
We believe in being open, honest and transparent with our clients and suppliers and want you to feel comfortable about your decision to give us your personal information and how we use it.
We will use the details you provide to us to communicate with you about how we can help you in your role and help your company achieve its objectives.
We promise that we will only communicate with you in the way you wish us to and we will always respect your privacy. You can change your mind at any time and it’s quick and easy to let us know that you no longer want to hear from us by contacting our Data Protection Officer (contact details at the bottom of the page).
Please be assured that we will take appropriate measures to keep your personal information safe and secure and we promise not to over contact.
We will never pass your personal information on to other organizations for them to use for their marketing purposes.
However, we may disclose your personal information in the following circumstances:
- To third parties who provide a service to us such as market research fieldwork agencies, email services providers or data processors. We require these third parties to comply strictly with our instructions and data protection laws and we make sure that appropriate controls are in place. We enter into Data Protection contracts with all our third parties and regularly monitor their activities to ensure they are complying with our policies and procedures.
- To third party client companies. We will have strict agreements with these companies to limit what they can do with the data we give them. We will always ask for your consent before passing on your personal information in this way.
- Where we are under duty to disclose your personal information in order to comply with the law or the disclosure is ‘necessary’ for purposes of national security, taxation, and criminal investigation or we have your written consent.
SHARING OF PERSONAL INFORMATION
We may share your personal data:
- Within our company in order to manage and provide our services, and for other legitimate business purposes;
- As required by law, including competent regulatory and governmental agencies;
- As part of any re-organization, or merger of all or a portion of the Course5 Intelligence
DURATION OF RETAINING YOUR PERSONAL INFORMATION
We keep your personal information for up to 7 years to operate the service in accordance with legal requirements and tax and accounting rules. Where your information is no longer required or is no longer relevant, we will ensure it is disposed of in a secure manner.
DATA SUBJECT RIGHTS
At any point while we are in possession of your personal information, you have the following rights:
- The right to access your personal information
- The right to edit and update your personal information
- The right to request to have your personal information deleted
- The right to restrict processing of your personal information
- The right to object/opt-out
- The right to lodge a complaint with a supervisory authority
- The right to request for deletion of your personal information.
- The right to request for portability/transfer of personal information
You also have the right to obtain from us confirmation as to whether or not your personal information is being processed and where this being the case, you have the right to access your personal data and know the following:
- The purpose of the processing.
- The categories of personal data concerned.
- The recipient or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations.
- Where possible, the envisaged period for which the personal data will be stored or if not possible, the criteria used to determine the period.
- The existence of the right to request from us the rectification or erasure of personal data or restriction of processing of your personal data or to object to such processing.
- The right to lodge a complaint with a supervisory authority.
- The right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have rights to transmit to another controller without hindrance from the controller to which personal data have been provided.
- The rights to object, on grounds relating to his or her particular situation, at any time, to the processing of personal data concerning him or her including profiling based on those provisions. The controller shall no longer process personal data unless the controller demonstrates controlling legitimate grounds for the processing which override the interests, rights, and freedoms of the individual or for the establishment, exercise or defense of legal claims.
- The rights not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
- The right to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed and where that is the case, access to personal data and the following information is provided.
Please provide as much information as possible about the nature of your contact with us to help us locate your records. Any changes you have requested may take up to 28 days before they take effect.
WHERE DO WE STORE YOUR PERSONAL DATA?
Given that our business operates across the EU and the USA, the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by our staff or staff at one of our suppliers operating outside the EEA. By submitting your personal data, you agree to this transfer, storing or processing.
Unfortunately, the transmission of information across the internet is not completely secure. Although we will do our best to protect your personal data by using technical measures like encryption, we cannot guarantee the security of your data transmitted to our site and therefore any transmission is at your own risk. Once we have received your information, we will use strict procedures and security measures to protect your data from unauthorized access or disclosure.
We recognize the need to provide additional privacy protections with respect to personal information we may collect from children. We do not target children with our products and services; however, occasionally we run market research projects which involve collecting personal data from child participants. When we collect personal information from children, we take additional steps to protect children’s privacy, including:
- Notifying parents about our information practices regarding personal data about children, including the types of personal information we will collect, the uses to which we may put that information, and whether and with whom we may share that information.
- In accordance with applicable law, obtaining consent from parents for the collection of personal information from their children
- Limiting our collection of personal information from children to no more than is reasonably necessary to participate in the market research study
- Giving parents the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.
The cookie is a tiny text file stored on your computer. Cookies store information that is used to assist in the proper rendering of the pages to the visitor. When the visitor visits the website on a subsequent occasion, the server detects the cookie and renders the web page in a manner that the user experience is enhanced.
The visitor has the option to control the cookies at the browser level including disabling the cookies and deleting the cookies after the visit. Disabling the cookies may however cause some degradation of some of the functions of the website as available to the visitor.
- Necessary cookies – These cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – These cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – These cookies are used to track the use and performance of our website and services
If at any time you require us to cease processing your personal data, you may write to us (contact details at the bottom of the page). By following the appropriate directions, your record will be marked as “do not contact”, and you will no longer receive communications from Course5 Intelligence. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
SECURITY OF PERSONAL DATA
Compliance and cooperation with regulatory authority:
We regularly review the compliance of our privacy notice. We also adhere to regulatory framework including GDPR (General Data Protection Regulation) and other applicable regulations around private data protection.
When we receive formal written complaints, we will contact the person who made the complaint to follow-up. We will work with the appropriate regulatory authorities, including local data protection authorities to resolve any complaint about personal data that we cannot resolve with the data subject directly. By accessing this Website and its contents, you understand that data privacy laws may vary across various jurisdictions and you would be subjected to the laws of the country under which you reside.
PRIVACY NOTICE AND DISCLOSURES FOR CALIFORNIA RESIDENTS
This Privacy notice is applicable in-conjunction with above policy clauses.
The California Consumer Privacy Act provides consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.
You have the right to request that Course5 Intelligence discloses certain information to you about personal data collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting or selling that personal information;
- The categories of third parties with whom we share that personal information,
SALE OF PERSONAL INFORMATION
We do not sell any personal information under any condition.
HOW DO WE EVALUATE AUTHENTICITY OF REQUEST?
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
RESPONSE TO CUSTOMER REQUEST
We strive to respond to a verifiable consumer request within 45 days of its receipt of your request. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month look-back period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We will not discriminate against you for exercising any of your rights, unless permitted by the California Consumer Privacy Act.
We will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including;
- Through granting discounts or other benefits, or imposing penalties;
- Provide you with a different level or quality of goods or services;
This policy and the terms herein shall be applicable to you in the event that Course5 Intelligence undergoes any functional changes in the way it operates. Such changes may include the Company being re-branded or undergoing the process of a merger or de-merger etc. On the occurrence of any of these events, your rights as data subjects would remain intact without any changes.
DATA PROTECTION OFFICER
Course5 Intelligence has a ‘Data Protection Officer’ who is responsible for matters related to privacy and data protection. This Data Protection Officer can be reached at the following address. To exercise the rights described above or if you have any questions related to the policy, please submit a verifiable consumer request to us: firstname.lastname@example.org
Or you could write to:
Data Protection Officer,
Building 2A, Aster- East Tower, Lower Ground Floor,
Embassy Tech Village (Formerly Vrindavan Tech Village),
Marathalli, Sarjapur Outer Ring Road,
Devarabeesanahalli, Bangalore-560 103.
[Policy version: 2.0, Revision date: 13 April 2020]