1.   Who are we?

Kenworld Education Pvt Ltd, a company incorporated and registered in India, is the data controller for the personal data collected through this Platform.

2.   What data do we collect about you?

2.1.1 Data provided through direct interactions

Registration and other account information

When you register to use our Services, we may collect the following information about you:

• If you register using your Email: your first and last name and email address.

Depending on the choices you make during the log-in to our Services or during the process of engaging our Services, you may opt to give the following additional personal data:

• Your name;
• E-mail address;
• Mobile number;

Validation of your Kenworld account

We validate the accounts of Kenworld users by using Email verification to ensure that each account is associated with a real and unique user. This validation process is initiated once you proceed with posting your first listing on our Services. In order to validate your account before posting your ad listing, we will send you an Email on a valid email address provided by  you. This process is entirely free of charge.

If you do not agree to validate your account, then your account will remain active and you will be able to use our Services with limited functionality. This limited functionality of an account implies that you cannot publish new ad listings or edit, update, promote, extend, reactivate, deactivate or delete existing ad listings until your account is verified by Email.

Once you have validated your Kenworld account, it will remain associated with the email address used for the email verification. If you wish to change the email address associated with your kenworld account, you will need to contact our Customer Support team.

2.1.2 Data we collect automatically when you use of our Services

When you interact with our Services, we automatically collect the following information about you:

Client and Log data

• Technical details, including the Internet Protocol (IP) address of your device, time zone and operating system. We will also store your login information (registration date, date of last password change, date of the last successful login), type and version of your browser.

Clickstream data

• We collect information about your activity on our Platform, which includes the sites from which you accessed our Platform, date and time stamp of each visit, searches you have performed, listings or advertisement banners you clicked, your interaction with such advertisements or listings, duration of your visit and the order in which you visit the content on our Platform.

3.     Why do we process your personal information?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests to improve our Services and to provide you a safe and secure Platform.
• Where we need to comply with a legal or regulatory obligation.

In certain circumstances, we may also process your personal data based on your consent. If we do this, we will let you know the purpose and the category of personal data to be processed at the time we seek your consent.

We have set out below a description of the reasons for which we use your personal data, [and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate].

3.1 For providing access and delivering Services through our Platform

1. If you log in using your email id, we use your first name and last name, or e-mail address to identify you as a user and provide access to our Platform.
2. We use third party payment service providers to process any payment you make to our Services. Depending on the method of payment, you may be requested to provide us with your payment and credit card details which we will then provide to the payment service provider in order to process your payment. We do not store your credit card information, unless you choose the option to save such information in order to make recurring payments easier without having to re-enter your details each time. In such cases, we only store your card holder name, the card expiry date, your card type and the last four digits of the card number. We do not store any credit card code verification values and merely forward such values and your credit card number in an encrypted manner for the purpose of processing your payment by our payment service provider.

We process the above information for adequate performance of our contract with you.

3.2  For improving your experience on the Platform and developing new functionalities of the Platform

1. We use clickstream data to:

• Offer you tailored content, such as giving you more relevant search results when using our Services.
• To determine how much time you spend on our Platform and in what manner you navigate through our Platform in order to understand your interests and to improve our Services based on this data. For example, we may provide you with suggestions on content that you can visit based on the contents you have clicked.
• To monitor and report the effectiveness of the campaign delivery to our business partners and internal business analysis.
•  If you choose to provide us with your location data, we use your location data for following purposes:

• To compile anonymous and aggregated information about the characteristics and behaviour of Kenworld users, including for the purposes of business analysis, segmentation and development of anonymous profiles.
• To enhance the performance of our Services and to personalise the content we direct towards you. For example – with the help of location data we display ad listings which are in your vicinity to improve your buying experience. For this purpose, Google Maps is integrated into our Platform. This means that both Google and we are responsible for the processing of your location data in the context of Google Maps. In any case, we will not process your location data for any other purposes but those explained in this Privacy Statement. However, Google might process such location data for their own purposes as explained in the Google Privacy Policy which can be reviewed Your use of Google Maps through our Platform is subject to Google Maps’ Terms of Service.
• To measure and monitor your interaction with the third-party advertisement banners, we place them on our Platform.

3. We use the images you upload, the descriptions and prices you provide in your ad listings to train machine learning models to personalise search results in relation to ad ranking and user interest, to improve the identification and presentation of ad listings, to improve the search function and to increase the likelihood of a successful sale. This helps us to improve our Services and to provide you with a better user experience.                                                                                                                                              
4. To show and recommend ad listings on our Services that may be of interest to you, we make use of algorithms that use information related to your browsing behaviour, items you bought, clickstream data, your user ID and your location data if you have given us permission to use this. We use this form of automated decision-making on the basis of our legitimate interest in improving our Services and provide a better user experience by offering you more relevant ad listings.

3.3 To take your feedback, promote and offer you Services that may be of your interest 

1. 1. We use your mobile number, log data and unique device identifiers to administer and protect our Platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting and hosting of data).
2. 2. We collect certain information from and in relation to the electronic device from which you are accessing our Services on the basis of our legitimate interest in preventing fraud on our Services. The information we collect includes your user ID (depending on whether you are logged in), Kenworld country domain, IP address, device language settings, device brand and type, device operating system and version, browser type and version, and device specific software information such as fonts, system and browser Time zone, available video and audio formats. The device related information is used to determine whether the same device is being used when users interact with our Services. We associate such information with a user fraud score on the basis of which we may ban certain users. For more information on this, please be referred to our Policy for Cookies and Similar Technologies. If you think that your account was wrongfully banned, you can contact us through our customer support helpline in which case our team will review the decision to ban your account.                                                                                         

3.4 To take your feedback, promote and offer you Services that may be of your interest

1. We may contact you through your registered mobile number or email id in order to take feedback from you about our Services.
2. We use your email address and mobile number (by SMS) to make suggestions and recommendations to you about our Services that may be of interest to you.
3. We use clickstream data to monitor and report the effectiveness of the campaign delivery to our business partners and internal business analysis.
4. If you choose to provide us with your location data, we may use your location data to measure and monitor your interaction with the third-party advertisement banners we place on our Services.

We process the above information based on our legitimate interest in undertaking marketing activities to offer you Services that may be of your interest. Specifically, you may receive certain marketing communications from us:

• By any preferred means of communication if you have requested such information from us.
• By email or phone, regarding similar products and services, if you already use our Services or acquired some of our products. 
• By phone or email, if you provided us with your details when you entered a competition; or 
• By phone or email if you registered for a promotion. 
• By phone or email, if you have provided your feedback for our Services through our Platform, social media, or any other means.

Being a registered user on our Platform, please note that if you have registered yourself on DND/DNC/NCPR services, you will still receive the above communications.

You can ask us to stop sending you such marketing communication at any time by clicking on the opt-out link in the email sent to you or by changing your notification settings in your account or by stating our calling agent that you do not wish to be contacted for the above marketing communications.

4. How will we inform you about changes in our privacy statement?

We may amend and update this privacy statement from time to time. We will notify you of material changes to this privacy statement as appropriate under the circumstances and as required by applicable laws, e.g. by placing a prominent notice within our Services or by sending you a message via our Services or by sending you an email. If you do not agree with the way we are processing your personal data and the choices we are providing to you, you may close your account at any time by going into your account settings and select delete account.

5. Communication

We will communicate with you by email, SMS or in the app notification in connection with our Services/Platform to confirm your registration, to inform you in case your ad listing has become live/expired and other transactional messages in relation to our Services. As it is imperative for us to provide you such transactional messages you may not be able to opt -out of such messages.

6. Who do we share your data with?

We may have to share your personal data with the parties set out below for the purposes set out in section 3 above.

Corporate affiliates: We may share your data with our group companies, which are located within as well as outside India and help us in providing business operation services such as product enhancements, customer support and fraud detection mechanism.

Third Party Service Providers:  We use third party service providers to help us deliver certain aspects of our Services for example, cloud storage facilities.

We conduct checks on our third-party service providers and require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow them 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.

Advertising and analytics providers: In order to improve our Services, we will sometimes share your non-identifiable information with analytics providers that help us analyse how people are using our Platform/Service. We share your information with them in non-identifiable form for monitoring and reporting the effectiveness of the campaign delivery to our business partners and for internal business analysis. For further details about our advertisers and analytics providers, please refer to our <Policy for Cookies and similar Technologies>.

Law enforcement authorities, regulators and others: We may disclose your personal data to law enforcement authorities, regulators, governmental or public bodies and other relevant third parties that comply with any legal or regulatory requirements.

We may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy statement.

Publicly available information: When you post an item for sale using our Services, you may choose to make certain personal information visible to other Kenworld users. This may include your first name, last name, your email address, your location and your contact number. Please note, any information you provide to other users can always be shared by them with others so please exercise discretion in this respect.

7. Where do we store your data and for how long?

The data we collect about you will be stored and processed in secure servers in order to provide the best possible user experience. For example – for fast website or mobile application build up.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

8. Your rights – data deletion requests

 To exercise your privacy rights and choices, if you do not want us to process your data, then you can use the Data Deletion Requests feature to issue a request for its removal. The option to request data deletion is visible under Account > Settings> “Deactivate account and delete my data”

There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and Kenworld is legally obligated to keep a record of that transaction to comply with law.

9. Technical and organisational measures and processing security

All the information we receive about you are stored on secure servers and we have implemented technical and organisational measures that are suitable and necessary to protect your personal data. Kenworld continually evaluates the security of its network and adequacy of its internal information security program, which is designed to (a) help secure your data against accidental or unlawful loss, access or disclosure, (b) identify reasonably foreseeable risks to the security of the Kenworld network, and (c) minimise security risks, including through risk assessment and regular testing. In addition, we ensure that all payment data are encrypted using SSL technology.

Please note, despite the measures we have implemented to protect your data, the transfer of data through the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorised third parties.

10. Links to third-party websites

Our Platform may contain links to third party websites or apps. If you click on one of these links, please note that each one will have its own privacy policy. We do not control these websites/apps and are not responsible for those policies. When you leave our Platform, we encourage you to read the privacy notice of every website you visit.