Privacy policy

We at the Company respect your privacy and care about how your personal information is used and shared. Therefore, we at the Company undertake best possible efforts to protect your privacy. Please read the following to learn more about our Privacy Policy (“Policy”). By using or accessing our Platform, you acknowledge that you accept and are subject to the provisions of this Policy.

This Policy forms part and parcel of the Terms of Use for our Platform and shall be read as a whole.For ease of reference, any terms used but not defined in this Policy have been defined in our Terms and Conditions and the Code of Conduct. Moreover, any terms not defined in the Terms of Use or in this Policy shall have the same meaning as defined under the relevant statutes.

We reserve the right to modify this Policy completely or in part, at any time. While making any modifications to this Policy, we will notify you of the modification, through the website. We will also send a notice to your email address about the modification if you have subscribed for any Program with us. You may terminate your subscription with us as per the provisions of the Terms and Conditions in case you feel the modified Policy adversely affects your rights. Any use of the Platform following the date on which we implement changes to this Policy constitutes your unconditional acceptance of all such modifications.

This Policy is in compliance of the statutory requirements under the provisions of the Information Technology Act, 2000, Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011, Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Digital Personal Data Protection Act, 2023 (“DPDP Act”).

What Information do We collect?

We collect information about you only if we need the information for a lawful purpose. We will have information about you only if (a) you have provided the information yourself, (b) We have collected the information automatically, or (c) We have legally obtained the information from a third party.

The Company collects the following type of information about You -

1. Information You provide to Us –

1.1. Personal information collected at the time of subscribing for any Program which would mean and include your personal data such as name, contact information, including addresses and email address, demographic information, photograph, signature and any other information collected at the relevant time. It is to be noted that in case any of the user subscribing to our Program is a minor, their parents’/guardians’ consent will be taken when collecting the personal information of the minor. In such circumstances, the personal information of the parent/guardian may also be collected.

1.2. When you subscribe for a Program from us, we ask you to provide your name, contact information, and credit card information or any other payment account information. You may be redirected on a separate payment gateway to make the payment. Such payment gateway provider may require and collect your details such as name, address, phone number, email address and credit or debit card information, net banking information or details of any web wallets maintained by you. Any/all payment(s) made/processed or details provided to or shared with such authorized payment gateway providers shall be stored directly by such payment gateway providers without any information passing through or relayed to us. We assume no liability in respect of such payments and/or information shared with or provided to such authorized payment gateway providers. It is further clarified that the aforementioned information is only used in accordance with the provisions of the applicable law and in strict adherence to this Policy.

1.3. Details about your health, mental wellbeing, disabilities, or other health related information such as past medical history which is collected as part of the PAR-Q form, all collected for your own safety and for proper discharge of our duties as a Company.

1.4. We may record, analyze and use your interactions with us, including postal letters, email, telephone, and chat conversations with our sales and customer support professionals which may include your email address, mobile number or postal address.

1.5. We may also store any personal information or other information which you provide when you respond to surveys, enter any form of contests, events, competitions, webinars etc hosted by the Company either on the Platform or otherwise.

1.6. You may also choose to provide location related information, including but not limited to access to GPS, which will enable us, with your consent, to offer customized offerings for specific programs where location data is relevant and/or applicable such as informing you whether programs on the Platform that you have expressed interest in may be availed of at or near your location.

1.7. When you authorize us to post testimonials or reviews on our Platforms about the Programs provided by us, we may include your name and other personal information in the testimonial or review. You will be given an opportunity to approve the same before we post it on our Platforms. If you wish to update or delete your testimonial, you can contact us as per the details provided in the “Complaints” section below.

2. Information We collect automatically -

2.1. When you access our Platform, we collect information that any web browsers, mobile devices and servers make available such as the browser type, internet protocol (IP) addresses, device identifiers, language preferences, time zones, date and time of access, referring URL, operating system, mobile network and mobile device manufacturer information. This information is collected in our log files.

2.2. We utilize standard technology called “cookies” to collect information about how our website is used. Cookies are identifiers we use to keep track of information such as your interaction with social media websites, the content you click on, download, upload or share and other activity on the Platform etc. It allows us to recognize your browser or mobile device and tell us how and when pages in our Platform are visited and by how many people. Cookies are only read by the server that places them and are unable to inter alia run programs on your computer, plant viruses or harvest your personal information. This information is collected on an aggregate basis. None of this information is associated with you as a user.

2.3. We collect usage information which includes information about your use of our Platform, number and frequency of visits, searches on the Platform and any other interactions on the Platform. This information also includes clicks, scrolls, performance data, storage utilised, errors, and user settings and configurations. This usage information gives us insights on how a user uses our Platform to help us improve the user experience.

3. Information We collect from other sources-

3.1. When you interact or engage with us on any search engines such as Google services or any social media sites such as Facebook, Instagram, Twitter or any other social media site through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information to allow us to connect with you.

3.2. If you attend or register for an event that is sponsored by the Company, the event organizer may share your information with us. We may also receive information about you from review sites if you comment on any review of our programs, and from any other third-party service providers that we may engage for marketing our programs.

Basis of Collecting and Using Information

1. Consent: We will rely on your consent to use your personal information in certain situations. If we require your consent to collect, store and process your personal information, your consent will be taken at the time of collection of your personal information and will be used for cases where consent is given. When you use your credit/ debit card to authorize a transaction or when you sign any authorization, consent will be assumed to have been taken. The methods of taking consent can be evolved, basis the DPDP Act. All such processes/methods would be deemed valid. All processes, mandated under the DPDP Act will be followed including serving of the Direct Notice.

2. Compliance with a legal obligation: Your personal information may be used by us, to the extent that such usage is necessary to comply with a legal obligation.

How We use this Information?

In addition to the purposes mentioned above, we may use your information for the following purposes:

3. To allow you access to our Platform and the Program(s) offered.

4. To communicate with you regarding our Programs that you have subscribed to, updates to our Platform and modifications to the Policy or other Terms of Use or regarding any other important news.

5. To keep you updated about our new Programs or services, upcoming events, offers, promotions and any other information that we think may be of interest to you.

6. To assist you reach your goals such as encouragement on Programs, schedules, advises, and other information to help you reach your desired goal.

7. To determine which areas of our Platform are most frequently visited to understand how to further enhance user experience of our Platform.

8. To better our Program(s) and Platform(s) for use.

9. To prevent, detect, investigate and take measures against criminal activity, fraud, misuse, of and damage to our Platform or network, report spams, prevent fraudulent transactions and any other threats and violations against the Company, our users or third party.

10. To defend legal claims whether in court, administrative, or other proceeding and to manage risk or obtain professional advice.

11. To analyse our records and for internal training and quality assurance purposes.

12. To serve other purpose for which we will provide notice at the time of collection, and as otherwise authorized or for any other lawful purpose.

Who we share this Information with?

We share the information collected as per terms of this Policy only in the manner specified in the Policy. We do not sell or otherwise disclose personal information we collect about you for monetary or other valuable consideration. Further, only authorized representatives of the Company and on a need-to-know basis use any information received from you and as consented by you. In the event of any identified unauthorized use or disclosure of information or upon your complaint as stated under the ‘Complaints’ section below, we will investigate any such complaint and take the appropriate action as per the applicable Laws.

1. Employees and independent contractors: We may provide access to your information to our employees and individuals who are independent contractors of the Company involved in providing the services so that they can better perform their services for you.. We communicate our privacy and security guidelines to our employees and contractors and strictly enforce privacy safeguards within the Company.

2. Third-party vendors/service providers: We may share information about you with third-party vendors or service providers (including consultants, payment processors, and other service providers and integrated services) who need the information to provide their support services to us or you, or to provide their services to you on our behalf either directly or through the Platform. These services may include but are not limited to providing customer support, performing business and sales analysis, supporting our website functionality, facilitating payment processing, and supporting contests, surveys, and other features offered on our Platform. Such third-party vendors are not allowed to use the information for any purpose other than what it was provided for, and they are required to process and use the information in accordance with this Policy.

3. Legal Disclosures: We may disclose information about you in response to complying with any legal obligations including but not limited to tax accounting, prevent abuse or in connection with any legal claim or proceedings. We further reserve the right to disclose such information where we believe in good faith that such disclosure is necessary to:

3.1 Protect and defend the Company’s or a third party's rights and property, or the safety of the Company, our users, our employees, or others; or

3.2 Prevent, detect, investigate and take measures against criminal activity, fraud and misuse or unauthorized use of our Platform and/or to enforce our Terms of Use. We will attempt to give you prior notice before disclosing your information in response to such a request.

4. Business transfers: In the event we undergo any merger, acquisition, or sale of company assets, in part or in full, with another company, or in the unlikely event that we go out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Policy.

5. Advertising and Analytics Partners: We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies. You can access their privacy policies at their respective websites.

6. With Your Consent: We may share and disclose information with your consent or at your direction.

Information Security

We are always committed to protecting the privacy and the confidentiality of your personal information. Whenever we obtain personal information from you, our Platforms uses commercially reasonable efforts and general industry standards to protect it from any unauthorized access or disclosure. Save as otherwise provided in this Policy, access to your personal information is limited to the Company’s personnel and such authorized third parties who may host your data on our behalf or may assist us in providing the services requested by you. We use best endeavours to maintain physical, electronic and procedural safeguards that aim to protect your information against loss, misuse, damage, modification, and unauthorized access or disclosure.

However, no form or method of data storage or transmission system is fully secure, and we cannot guarantee that security provided by such system(s) is absolute and that your information will not be accessed, disclosed, or destroyed in the event of a breach of any of our security measures. We cannot guarantee that information you supply won't be intercepted while being transmitted to us over the Internet. Any transmission of information by you to our Platform is at your own risk. We would inform you of any breach of system that allows unauthorised access to your information.

Links to Third Parties

The Platform may include links that redirect you to other websites or platforms. This Policy does not cover these third-party websites. You agree that once you leave our servers, any third-party websites that you go to or interact with, are at your own risk. We shall not be held liable for any default, loss of function or any risk that your personal information may be exposed to as a result of the same.

How does the Company address children's privacy?

We require that the user must be at least 18 years old to subscribe to any of our Programs or to avail of any other Service. However, if the user is below 18 years of age, they can only access the Program(s) if the user’s parent or guardian has consented it. If you are the parent or guardian of a child under 18 years of age and believe that they have disclosed personal information to us, please contact us at the details mentioned below in the “Complaints” section so that we may take immediate steps to delete the child's information.

While some of our services or Program(s) may require collection of a child’s personal information, we do not knowingly collect such personal information from a child and assume that information has been provided with consent of the parent/guardian. If you are a parent/guardian and you are aware that your child has provided us with any personal information without your consent, please contact us details mentioned below in the “Complaints” section, if we become aware that we have collected personal information from a child in the absence of consent of the parent/guardian, we will take steps to remove such information from our Platform.

Your Choice in use of Information

1. Limit the information You provide: You always have an option to choose the information you provide to us, including the option to update or delete your information. However, please note that lack of certain information may not allow you access to some of our Program(s) or some features of the Platform.

2. Limit the communications You receive from us: Further, you will also have the option to choose what kind of communication you would like to receive from us and whether you would like to receive such communication at all or not. However, there may be certain communications that are required for legal or security purposes, including changes to various legal agreements or changes to this Policy, that you may not be able to limit.

3. Limit the processing of information: You have the option to limit the information that is shared with employees, contractors, third-party vendors and service providers. However, this limitation of processing of information may hamper your use of the Platform and may not allow you access to some of our Programs or some features of the Platform.

4. Disable Cookie: You may reject or remove cookies from your web browser; you will always have the option to change the default settings on your web browser if the same is set to ‘accept cookies’. However, please note that certain features of the Platform may not function or be available to you, when the cookies are rejected, removed, or disabled.

Your Rights

As per the provisions of the statutes mentioned above, you have the following rights with respect to the information that we hold about you-

1. Right to access – You have the right to access the personal information that we hold about you, including the activities undertaken by us to process such information its purpose and period of processing, and the identities of persons with whom the personal information is shared.

2. Right to correction and erasure – You have the right to ask us to rectify your personal information that is with us that you think is inaccurate. You also have the right to ask us to update your personal information that you think is incomplete or out-of-date. You also have to right to request that we delete your personal information from our Platform if it is no longer necessary for the purpose for which it was collected. However, please note that such an erasure will remove all your personal information from our Platform (except as specifically stated in this Policy). In that case we might have to restrict they Program(s) offered to you or your access to certain features of the Platform(s).

3. Right to restrict processing – You have the right to request us to restrict the use of your information when you have objected to our use of your data.

4. Right of grievance redressal – You have the right to have available means of grievance redressal in respect of any acts or omissions on the part of the Company relating to use of your personal information. You may make a complaint by contacting us as per the details provided in the “Complaints” section below.

5. Right to nominate - You have the right to nominate, any other individual who shall in the event of your death or incapacity, exercise your rights as provided under this section and in accordance with this Policy.

We shall keep your personal information only as long as is required for the purposes for which it was originally collected as per this Policy. However, in certain cases we may retain your information for longer periods such as for complying with any legal obligations including but not limited to tax accounting, preventing abuse or in connection with any legal claim or proceedings.

We may not be able to delete all communications undertaken through our Platform or other information publicly made available by you on the Platform (for example: comments, feedback, etc.). However, we shall anonymize your Personal Information in such a way that you can no longer be identified as an individual in association with such information made available by you on the Platform.

If you wish to exercise any of your rights as has been specified in the ‘Your Rights” section above to access, modify or delete any or all information stored about you, then you may do so by contacting us as per the details provided in the “Complaints” section below.

Grievance Redressal/Complaints

In case you have any enquiries or concerns (including to request access to or correction of your personal information or to make a privacy complaint) including those pertaining to Terms of Use, Privacy Policy or any other policies, please contact our grievance redressal officer, whose contact information is detailed below:

Name: Shalabh Malhotra

Email: shalabh@apclub.co.in

Address: Prestige Kew Gardens, Yemalur Main Road, Bangalore, Karnataka, 560037