This Privacy Policy describes how ICTC Learning Solutions Private Limited ("AviGation", "we", "us", or "our") collects, uses, and shares your personal information when you use our website, platform, courses, and services (collectively, the "Services"). By accessing or using our Services, you agree to the collection and use of information in accordance with this policy.
1. Personal Information We Collect
We may collect the following categories of personal information when you interact with our Services:
- Identification Information: Full name, date of birth, gender, photograph, and government-issued identification documents (such as Aadhaar, PAN, or passport details where required for course enrollment or certification).
- Contact Information: Email address, phone number, postal address, and city/state/country of residence.
- Account Information: Username, password (encrypted), and account preferences when you create an account on our platform.
- Payment Information: Billing name, billing address, and payment transaction details. Please note that payment card details are processed through secure third-party payment gateways and are not stored on our servers.
- Academic and Professional Information: Educational qualifications, employment history, resume/CV details, and aviation training records.
- Communications: Any information you provide when you contact us for support, submit a form, book a demo, or communicate with us via email, WhatsApp, phone, or any other channel.
2. Information We Collect Automatically
When you visit our website or use our platform, we may automatically collect certain information, including:
- Device Information: IP address, browser type and version, operating system, device type, screen resolution, and unique device identifiers.
- Usage Data: Pages visited, time spent on pages, click patterns, course progress, quiz scores, session duration, referring URLs, and exit pages.
- Location Data: Approximate geographic location based on your IP address.
- Cookies and Tracking Technologies: We use cookies, web beacons, pixels, and similar technologies to enhance your experience, analyze usage patterns, and serve relevant content. You can manage cookie preferences through your browser settings.
3. How We Use Your Information
We use the information we collect for the following purposes:
- To provide, maintain, and improve our Services, including course delivery, certificate issuance, and platform functionality.
- To process enrollments, payments, and refunds for our courses and programs.
- To communicate with you about your account, course updates, upcoming events, promotional offers, and respond to your inquiries.
- To personalize your learning experience, recommend relevant courses, and track your progress.
- To send administrative notifications, including changes to our terms, policies, or services.
- To detect, prevent, and address technical issues, fraud, and security vulnerabilities.
- To comply with legal obligations, resolve disputes, and enforce our agreements.
- To generate aggregated, anonymized analytics and insights about usage patterns to improve our offerings.
- To facilitate job placement assistance, including sharing your profile (with your consent) with airline and aviation industry partners.
4. Your Choices
You have the following choices regarding your personal information:
- Account Information: You may review and update your account information at any time by logging into your account settings on our platform.
- Marketing Communications: You may opt out of receiving marketing emails by clicking the "unsubscribe" link at the bottom of any marketing email. Please note that you may still receive transactional or administrative communications.
- Cookies: You can control cookies through your browser settings. Disabling cookies may affect the functionality of certain features of our Services.
- Data Sharing for Placement: You may opt out of having your profile shared with placement partners by notifying us at the contact details provided below.
5. Your Rights
Depending on your location and applicable laws, you may have the following rights with respect to your personal information:
- Access: Request a copy of the personal information we hold about you.
- Correction: Request correction of inaccurate or incomplete personal information.
- Deletion: Request deletion of your personal information, subject to certain legal exceptions.
- Portability: Request transfer of your personal data to another service provider in a structured, commonly used format.
- Objection and Restriction: Object to or request restriction of processing of your personal data in certain circumstances.
- Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.
To exercise any of these rights, please contact us using the details in the "Grievances and Contact Us" section below.
6. Data Protection and Security
We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to:
- Encryption of data in transit (SSL/TLS) and at rest.
- Regular security assessments and vulnerability scanning.
- Access controls and authentication mechanisms for internal systems.
- Employee training on data protection and privacy best practices.
- Incident response procedures for data breaches.
While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
7. Third Party Websites
Our Services may contain links to third-party websites, services, or applications that are not operated or controlled by AviGation. This Privacy Policy does not apply to such third-party services. We encourage you to review the privacy policies of any third-party websites you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
8. Cross-Border Data Transfer
Your information may be transferred to and maintained on servers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ. If you are accessing our Services from outside India, please be aware that your information may be transferred to, stored, and processed in India where our servers and databases are located. By using our Services, you consent to such transfers.
Where required by applicable law, we implement appropriate safeguards for cross-border data transfers, including standard contractual clauses or other legally recognized transfer mechanisms.
9. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Specifically:
- Account Data: Retained for as long as your account is active, plus a reasonable period after account closure for legal and administrative purposes.
- Course and Certification Records: Retained indefinitely for verification and alumni record purposes, unless you request deletion.
- Payment Records: Retained as required by applicable tax and financial regulations (typically 7 years under Indian law).
- Marketing Data: Retained until you opt out or request removal from marketing lists.
- Usage and Analytics Data: Retained in aggregated, anonymized form indefinitely, and in identifiable form for up to 24 months.
10. Modification of This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Effective Date" at the top of this page and, where appropriate, notify you via email or a prominent notice on our website.
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our Services after any modifications to this Privacy Policy constitutes your acceptance of such changes.
11. Grievances and Contact Us
If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, or if you wish to exercise any of your rights described herein, please contact our designated Grievance Officer:
We will acknowledge your grievance within 48 hours and aim to resolve it within 30 days from the date of receipt, in compliance with applicable Indian data protection laws including the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
12. Country-Specific Rights
12.1 Rights for Users in India
If you are located in India, your rights are governed by the Information Technology Act, 2000 and its associated rules, as well as the Digital Personal Data Protection Act, 2023 (DPDPA). You have the right to:
- Access your personal data and request information about how it is processed.
- Correct inaccurate or incomplete personal data.
- Erase your personal data where there is no legal obligation to retain it.
- Grieve any grievance regarding the processing of your personal data with our designated Grievance Officer.
- Nominate another person to exercise your rights on your behalf in the event of your death or incapacity.
Under the DPDPA, you also have the right to withdraw consent at any time where processing is based on consent, and we shall cease processing within a reasonable time of receiving such withdrawal.
12.2 Rights for Users in the United Kingdom, European Union, and European Economic Area
If you are located in the UK, EU, or EEA, your rights are governed by the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (GDPR). You have the following additional rights:
- Right of Access (Article 15 GDPR): You may request a copy of the personal data we hold about you.
- Right to Rectification (Article 16 GDPR): You may request correction of inaccurate personal data.
- Right to Erasure (Article 17 GDPR): You may request deletion of your personal data in certain circumstances.
- Right to Restriction of Processing (Article 18 GDPR): You may request that we restrict the processing of your personal data in certain circumstances.
- Right to Data Portability (Article 20 GDPR): You may request to receive your personal data in a structured, commonly used, and machine-readable format.
- Right to Object (Article 21 GDPR): You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
- Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection supervisory authority.
Our legal bases for processing personal data include: consent, performance of a contract, legitimate interests, compliance with legal obligations, and, where applicable, vital interests.
12.3 Rights for Users in California, United States
If you are a California resident, your rights are governed by the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA). You have the following rights:
- Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of collection, the business purposes for collection, and the categories of third parties with whom we share your information.
- Right to Delete: You may request that we delete your personal information, subject to certain exceptions.
- Right to Opt Out of Sale/Sharing: We do not sell your personal information as defined under the CCPA/CPRA. If this practice changes, we will update this policy and provide a "Do Not Sell or Share My Personal Information" link.
- Right to Correct: You may request correction of inaccurate personal information.
- Right to Limit Use of Sensitive Personal Information: Where applicable, you may request that we limit the use and disclosure of your sensitive personal information.
- Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
To exercise your CCPA/CPRA rights, please contact us at icoachthecoach@gmail.com. We will verify your identity before processing your request and respond within the timeframes required by law.