Effective date: July 12th, 2019
Introduction and Scope
EU-U.S. Privacy Shield Frameworks
Aspiring Minds complies with the EU-U.S. Privacy Shield Framework, as adopted and set forth by the U.S. Department of Commerce, regarding the processing of Personal Information transferred from the European Union, the European Economic Area, and the United Kingdom, to the United States or otherwise receives in reliance on Privacy Shield. Aspiring Minds commits to adhere to and has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to all Personal Information that Aspiring Minds receives in reliance on the Privacy Shield. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
In the context of this Policy, Aspiring Minds acts as a data processor for the Personal Information we process.
Information We Collect
We may collect the following Personal Information about you (wherein “you” refers to students, candidates, and other data subjects using the Apps provided by Aspiring Minds):
- Biographical data, such as first name and last name;
- Contact information, such as your email address and phone number;
- Photographs, audio, and video recordings of you;
- Test results containing subjective information about your performance;
- Any other information that our clients solicit from you via our Apps, such as date of birth, current address, permanent address, education details, or any other information, as determined by our client in their sole discretion; and
- The tests you are registering for and their date.
How We Receive Personal Information
We may receive your Personal Information when:
- You create an account with us;
- You register for and complete a test; or
- Our client submits your Personal Information to the Apps.
How We Use Your Personal Information
We use your Personal Information for the following purposes:
- To enable your use of our Apps;
- To assess your skills and competencies and provide assessment results to our client; and/or
- To complete any test registrations, purchases, or other transactions you request online.
In addition, Aspiring Minds may automatically collect certain non-personally identifiable information to:
- Improve our Apps, and identify, develop, and offer new or expanded products and services;
- Personalize your user experience in the Apps, and customize the content and/or format of the pages you visit;
- Notify you about updates, products, services, and/or special offers from Aspiring Minds; or
- Generate aggregate statistical studies and conduct research related to our products and services and the use of our
Disclosure of Your Personal Information
We disclose your Personal Information to certain third parties with whom we have a direct or indirect business or contract relationship, to provide the products and services you have requested.
We may use third-party vendors to perform certain services for us or on our behalf, such as hosting our Apps, or providing us with IT services. We may share your Personal Information with these third-party vendors solely to enable them to perform such services for us. In providing such Personal Information, we require that those third-party vendors maintain at least the same level of data protection that we maintain for such Personal Information. We do not provide your Personal Information to parties unconnected with the services we provide.
We may also disclose your Personal Information:
- To the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
- If we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; or
- To our subsidiaries or affiliates only if necessary for business and operational purposes.
If we must disclose your Personal Information in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Information will maintain the privacy or security of your Personal Information.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any Personal Information, about our services' users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.
Our Apps are not directed at nor intended for use by children under the age of 13. We do not knowingly allow anyone under 18 to provide any Personal Information on our Apps. Children should always get permission from a parent or guardian before sending Personal Information over the Internet. If you believe your child may have provided us with Personal Information, you can contact our Privacy Officer using the information in the Contact Us section of this Policy and we will delete the Personal Information or notify our client so that they can delete the Personal Information.
Data Security and Integrity
Aspiring Minds has implemented and will maintain technical, organizational, and physical security measures that are reasonably designed to help protect Personal Information from unauthorized processing, such as unauthorized access, disclosure, alteration, or destruction.
When the purposes of processing are satisfied, we will retain your Personal Information for up to 1 year unless instructed otherwise by our client.
Erasing, Accessing, Changing, or Updating Your Personal Information
If you are a data subject about whom we store Personal Information, you may have the right to request access to, and the opportunity to update, correct, or delete, such Personal Information. If we have received your Personal Information in reliance on the Privacy Shield, you may also have the right to opt out of having your Personal Information shared with third parties and to revoke your consent to our sharing your Personal Information with third parties. You may also have the right to opt out if your Personal Information is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized.
To submit such requests or raise any other questions, please contact the organization (our customer) you were assessed for as part of recruitment process and they will reach out to Aspiring Minds Team for the same. Aspiring Minds Team has limited rights to access Personal Information your organization submits to us. Therefore, if you contact us with such a request, please provide the name of the organization who submitted your Personal Information to us. We will forward your request to that organization, and provide any needed assistance as they respond to your request.
If you registered directly with us on myamcat.com, kindly reach out to us on firstname.lastname@example.org
Accountability for Onward Transfers
Aspiring Minds, Inc. remains liable for the protection of Personal Information that we transfer to our service providers within the scope of our Privacy Shield certification, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.
If a privacy complaint or dispute cannot be resolved through Aspiring Minds, Inc.’s internal process, Aspiring Minds, Inc. has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Privacy Shield Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
If your dispute or complaint can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.
Aspiring Minds, Inc. is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
If you have a complaint, dispute, or questions regarding this Policy or our treatment of your Personal Information, please write to us by:
Grievance Officer: Sidharth Nayak
Aspiring Minds, Inc.
75 E Santa Clara St
CA 95113, USA
Please allow up to 10 days for us to reply.