Tsaroconsulting (“Tsaaro”, “Tsaaro Academy”, “we” or “us”) offers training for privacy-oriented courses (Services). tsaroconsulting owns and operates Tsaaro Academy and academy.tsaaro.com (website). Tsaaro Academy collects and processes personal data for providing efficient services to its customers. We at Tsaaro Academy understand the importance of your (“visitors” or “You” or “students”) privacy and are dedicated to secure your personal data.
Scope of this Privacy Statement
This policy applies to personal information collected by the Tsaaro Academy in its capacity as a controller. This Privacy Statement aims to inform you how we collect, use, disclose, and store information or data that may identify you as an individual (“Personal Information”) when you:
• interact or use our Website or request us to contact you, and
• provide information while buying a training course from the website.
It is important to note that this website is not intended for children under the age of 16 years and we do not knowingly collect data relating to children.
What type of information does Tsaaro Academy collect?
Information you provide to us:
We may collect identifiers that you choose to send to us or provide to us through the website, for example, you ask us to contact you concerning services we provide or register for the courses at Tsaaro Academy. We will maintain a record of our correspondence. Categories of personal data we may process about you are as follows:
• Email address
• Contact number
• Payment details
• Any other information shared by you at your willingness, for example any comment or message.
Information we automatically collect:
How and on what grounds do we use the information?
We will use the information we collect through our website:
• To administer our website, our events, and for internal operation, including troubleshooting, data analysis, and testing purposes
• To improve our website to ensure that content is presented most effectively for you and your computing device
• For trend monitoring, marketing, and advertising, and
• As part of our effort to keep the website secure.
We will use this information provided by you while purchasing training courses
• To communicate with you.
• To provide invoices.
• To provide you all promised training benefits, for example, sending you the study materials.
Our use of your personal information may be based on our legitimate interest to ensure network, information security, and business performance improvement.
Our direct marketing purposes are based on user consent (for instance, when you share your information in the contact us section, agree to receive communications after an event, and so on). We may also rely on a legitimate interest to improve business and marketing practices, or contact you to offer similar services that you might have bought from us or negotiated for with us.
Do we share and disclose information to third parties?
We share and disclose information (including personal information) about our customers in the following limited circumstances:
Vendors, consultants, and other service providers.
We may share your information with third-party vendors, consultants, and other service providers who we entrust to perform tasks on behalf of the Tsaaro Academy including website analytics companies (e.g. Google Analytics), Platform as a service platform (e.g. AWS), and Email hosting like (e.g. Zoho Mail).
Third-party data may also be shared, insofar as reasonably necessary, with any other service used by our marketing and sales teams. We are free to use your name across our social media platforms for the purpose of celebrating your success, and sharing testimonials, etc. No specific consent will be obtained again once it is given to us during the sign-up process, unless otherwise revoked.
Transaction data is shared with our payment service providers, only to the extent necessary for the purposes of facilitating your payments, processing your refunds, and dealing with complaints/queries regarding such payments and/or refunds.
Also, we share personal information of our students with our training partner, IAPP to provide invoices, study material, scheduling exams, and certification.
If Tsaaro Academy receives your personal information in the European Union and subsequently transfers that information to a third party agent or service provider, it ensures that the third party processes your personal information to the standard required by the applicable privacy laws, including the GDPR. These transfers will be typically based on our legitimate interest or agreed upon in the contract.
Disclosures for national security and law enforcement:
Under certain circumstances, we may be required to disclose your personal information in response to valid requests by public authorities, based on our legitimate interest or legal obligation.
Transfer of business:
If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party. We will ensure through the contract that a third party ensures the security of the data involved.
For how long do we store your personal information?
Tsaaro Academy will process and store your personal data only as long as necessary to fulfill the purposes that the data was collected.
How do we secure your data?
We use appropriate technical, organizational, and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
International Data Transfers
Personal information shared by you with us on the website may be sent to India and processed by us there or in other countries, on our service provider’s cloud servers (AWS) or it can be sent to the servers of IAPP in the United States of America. We will always take appropriate safeguards and protect your information under this Privacy Statement wherever it is processed.
General Data Protection Regulation provides several privacy rights to the data subjects. You can access your rights by mailing us at firstname.lastname@example.org. The rights you may enjoy include:
1. Access your personal data
You have a right to access and receive a copy of your personal data. We will provide this information free of charge unless your request is unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. To access your personal data stored with us, you can send us a Data Subject Access Request through email. We will provide the information you request at the earliest. To ensure we provide the information to the right person, we may ask you for some particulars to prove your identity.
2. Rectification of your data
If you believe that the person we hold about you is inaccurate or incomplete, you can ask us to rectify the concerned data. We will rectify your data within a month of receiving the request for rectification.
3. Erasure of your data (Right to be forgotten)
You can use your right to erasure in certain circumstances by asking Tsaaro Academy to erase the personal data we hold about you. You can access this right when we have collected your personal data on the legal basis of consent and you withdraw the consent, we no longer need the data for the purpose we collected for, where you object to the processing and we do not have any overriding legitimate interests to continue the processing of the data. Under certain circumstances, we will not be able to comply with your request. If any of those circumstances apply, we will inform you.
4. Restriction of processing
You have the right to restriction. If you believe that the personal data we hold about you is inaccurate or incomplete or the processing is unlawful or Tsaaro Academy does not require your data for the original purpose or if the verification of overriding grounds is pending in the context of an erasure request, you can ask us to restrict the use of your personal data. This right will block the use of your personal data by the Tsaaro Academy for a particular time period.
5. Right to Withdraw Consent
If you do not want to receive marketing messages, updates, or non-transactional communications by Tsaaro Academy, you may opt-out or withdraw your consent at any time by unsubscribing to our e-mails or by sending a request to the above-mentioned e-mail ID. The withdrawal of your consent will not dispute the lawfulness of processing done in past based on consent. Tsaaro Academy is committed to ensuring that the information we collect and use is appropriate for the above-mentioned purposes and does not constitute an invasion of your privacy.
As mentioned above, we do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Information, please contact us at email@example.com.
Changes to the Privacy Statement
We’re constantly trying to improve our Websites and Services, so we may need to change this Privacy Statement from time to time as well. We will inform you regarding material changes, for example, placing a notice on our Websites when we are required to do so by applicable law. You can see when this Privacy Statement was last updated by checking the date at the bottom of this page. You are responsible for periodically reviewing this Privacy Statement.
If you wish to make a complaint about how your personal data is processed by Tsaaro Academy, email us at firstname.lastname@example.org. We at Tsaaro Academy respect the personal data and privacy of every user equally, irrespective of their jurisdiction. We promise to abide by this Privacy Statement and secure your privacy. For us, you all are equally valuable and your trust is our asset. If you are unhappy about how a complaint has been handled by Tsaaro Academy, you have a right to complain directly about your local supervisory authority.
Last updated: 24th December 2021.