Indiaedge Education Private Limited is an entity, incorporated under the laws of India, classified as a wholly-owned subsidiary of a foreign company – registered under the name and style of Eduscope Pte Ltd (“Us”, “We”, “Company” or “Our”). The Company owns, operates and manages a Website having domain name www.libf.in (“Website”). The Website facilitates the online transactions for enabling its prospective customers (hereinafter referred to as “Users”, “You” or “Your”) to avail the services provided by the Company, as detailed herein, which inter alia includes marketing of courses offered by The London Institute of Banking & Finance operated and managed by the Company and/or its affiliates (“Service”), in accordance with the terms of use of the Website available at (“Terms of Use”).
1. Introduction
We attach great importance to the personal data Our customers share with Us and use a range of measures to protect this data and ensure it is used in line with Our customers’ expectations. We aim to make Our use of your personal data as transparent as possible and this notice sets out how We may collect, process, share and dispose of Your data and the individual rights that are available to You.
We respect Your need to understand how and why information is being collected, used, disclosed, transferred and stored. Thus, We have developed this policy to familiarize You with Our practices and demonstrate Our commitment to the protection of Your personal information. This Privacy Policy sets out the way in which We process Your information when You visit the Website or use the Service in accordance with applicable data protection laws. By accessing Our Website or availing the Service, You agree to be bound by the terms of this policy. It is important that You read this policy together with any other policies that We may provide on specific occasions when We are collecting or processing your personal data, so that You are fully aware of how and why We are using your personal data. This policy supplements other notices and is not intended to override them.
The information contained on this Website and the personal information collected by using/ logging in and or accessing this Website are stored at a secured server. It is stated by the server service provider that they have all the best security practices required for the server. The Website is owned by Us and is located in India. Hence, We are bound by duty to abide by the laws, including but not limited to, regulations, rules, circulars and notifications governing privacy in India.
We provide this Privacy Policy to inform You of Our policies and procedures regarding collection, storage, and processing and sharing of personal data that We receive from Users of the Website or those which are stored or accessed by Us at the time of availing the Service on the Website.
With regard to this Privacy Policy, the terms “using” and “processing” information include, without limitation; the use of cookies; and the collection, storage, transfer, evaluation, deletion, disclosure, management, handling, modifying and use of personal data.
This Privacy Policy applies only to personal data that You provide Us via the Website.
We hope You will find Our Privacy Policy answers any questions You may have, but if You require further help You can find our contact details at the bottom of this notice.
We may update this notice from time to time but will communicate any changes in advance where they may have a material effect on Your privacy rights. The latest version and date can be found at the end of the policy.
2. What is The London Institute of Banking & Finance and its association with the Company?
The London Institute of Banking & Finance (“LIBF”) is a provider of outstanding education and thought leadership in banking and finance for businesses, individuals and society.
The products and services include:
- Delivery of professional qualifications via distance learning or through our recognised training providers to individuals and businesses.
- Membership services providing a range of benefits including exclusive access to events, networking, industry insights and support to demonstrate ongoing professional development including Chartered Status.
The Company in association with LIBF (through its holding company), acts as a marketing extension of LIBF and caters to the need of the Customers in the territory of India.
3. What is your lawful basis for using my personal data?
Data protection legislation requires organisations to have a lawful basis for collecting and processing Your personal data. We have set out below the six lawful bases that can be used and examples where We will commonly rely on each:
Consent
We typically use consent for our marketing activities and where we process special category data (for example health information you provide to us to make a reasonable adjustment to your exam).
Contract
When you register with us to receive a product or service, such as studying a qualification or attending an event, we will normally process Your personal data on a contractual basis to fulfil the service or product You have requested.
Legal Obligation
This Privacy Policy shall apply to any person who visits, browses, uses or accesses the Website or use our Service on the Website. This Privacy Policy is an electronic record in terms of the Information Technology Act, 2000 and rules and regulations made thereunder. Further, this electronic record is generated by a computer system and does not require any physical or digital signatures. Any new features and/or services that are added to the Website at any point in the future shall also be subject to the terms set out in this policy.
We may rely on this basis where We are legally obliged or have a statutory obligation to process Your personal data.
In accordance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPI rules”) any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person is called “Personal Information”. Further, any personal information about that person relating to: (i) passwords; (ii) financial information such as bank accounts, credit and debit card details or other payment instrument details; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) Biometric information; (vii) any detail relating to the above clauses as provided to body corporate for providing service; and (viii) information received by body corporate under lawful contract or otherwise is called “Sensitive Personal Data or Information”.
Please note that the information collected by Us from You may constitute ‘Personal Information’ or ‘Sensitive Personal Data or Information’ in accordance with the SPI Rules. This may also include providing statistical information to the regulatory agencies in India.
The Company shall not be responsible for the authenticity of the Personal Information or Sensitive Personal Data or Information supplied by the Customer to the Company or any other person acting on behalf of the Company.
Vital Interests
We would only use this basis to process your data where we feel it is necessary to protect your life. For example, should you be taken ill whilst on our premises and are unable to give consent yourself, then we may share any health information we hold with the emergency services.
Public Task
This basis would usually be used by public authorities to carry out public functions and powers set in law or tasks by organisations within the public interest. We would not expect to have to process Your personal data on this basis.
Legitimate Interests
We may rely on this basis where We determine We have a legitimate interest in processing Your data. We would use this basis where We determine You would reasonably expect Us to process Your data in this way and it has minimal impact on Your privacy. For example, We may determine that it is in Our interests to communicate changes in regulatory requirements to previous customers, that You would reasonably expect this and that it has minimal impact on Your privacy.
We may use legitimate interest for some of Our marketing activities, particularly where You have recently made a transaction with Us. Please refer to section 12 below on how to change Your marketing preferences.
We may also rely on this basis to protect the integrity of Our qualifications and prevent fraudulent activity including but not limited to student malpractice and centre maladministration.
4. When do you collect my personal data?
When You first contact us we create a record in Your name and allocate You a unique ID number. Any information that You give us, or we generate, from then on is added to Your record. We endeavour to ensure the accuracy of all records, but we rely on You to keep your personal data up to date, either online via our contact form or by informing customer services team of any changes. The contact details of Our customer services team and the ‘Grievance Officer’ is listed at the end of the policy.
Information collected automatically
When You visit Our Website and agree to the terms of use that automatically pops up at the time of visiting the Website, We automatically collect anonymized data about Your visit and securely store it using Google Analytics. We use this to improve user experience, navigation of Our Website and the services we offer to You. The type of data we collect includes:
- session duration
- page views
- traffic source
- browser
- device
- IP address, and
- actions taken (e.g. PDF downloads, clicks, form submissions)
Option to the Customer
In accordance with above, the Company prior to the collection of information including Sensitive Personal Data or Information, provide an option to the provider of the information to not to provide the data or information sought to be collected. The provider of information shall, at any time while availing the services or otherwise, also have an option to withdraw its consent given earlier to the Company. Such withdrawal of the consent shall be sent in writing to the Company, as per the details mentioned below. In the case of provider of information not providing or later on withdrawing his consent, the Company shall have the option of not to provide goods or services for which the said information was sought.
Remarketing
Remarketing is a form of online advertising that enables Us to show You targeted adverts after You’ve visited our Website. It works by placing a tracking code – a cookie – on people’s browsers when they visit Our Website. It will then serve ads to those with that cookie, specifically, on the display and search networks on different web browsers. This code will last for six months and is then removed automatically.
To opt out of remarketing, You should decline our cookies when You first visit Our Website. You can also opt out by clearing the history on Your web browser and changing Your web browser settings so that they don’t allow third-party tracking.
Advertising Reporting Features
To help Us get a better understanding of Our users, we have enabled ‘advertising reporting’ features like:
- audience demographics and interests reporting
- DoubleClick campaign manager reporting
- DoubleClick bid manager reporting, and
- Google display network impression reporting.
You can opt out of Google’s use of cookies through Your browser settings or by visiting Google’s Ads Settings or Google Analytics’ currently available opt-outs.
Alternatively, You can opt out of third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.
Register your interest
You may register Your interest with Us, typically via a form on Our Website, to receive more information about Our qualifications and services. The information We send will be specific to the areas You’ve registered Your interest in.
5. What type of personal data do you collect?
We seek to only collect the personal data, which may include the Personal Information and/or the Sensitive Personal Data or Information, We require to respond to Your request, deliver a product or service or meet a statutory reporting obligation. We have provided some typical examples below:
New customer enquiries:
When You contact us for the first time We may ask you to provide some basic personal data (e.g. name and contact information) to allow us to respond to Your enquiry and send any links, forms, documents etc. A record will be created in Your name under a unique ID number (an LIBF number) and Your personal data stored securely.
Existing customer enquiries:
When You contact us again We may request information that will help Us to establish Your identity and prevent fraud. Once we have verified Your identity, any further personal data You provide will be stored securely on Your existing record.
Study and membership application/registration:
When You complete an application to study one of our programmes or become a member of The London Institute of Banking & Finance You will be asked to provide sufficient personal data to:
- Register you for a programme of study
- Allow distribution of study materials/correspondence
- Allow communication when required
- Confirm bank details and authorise to debit the account of the student
- Confirm your job title and employer (if applicable)
- Obtain statistics for future marketing campaigns (where did you hear about us etc.)
- Confirm that You meet any entry criteria (if applicable)
- Confirm that coursework assignments will be Your own work (if applicable)
Event registration:
When You register online to attend an event managed by us You will be asked to provide sufficient personal data to:
- Identify You
- Register You for the event
- Communicate with You regarding the event
Special category data:
Special category data is data that is more sensitive and requires extra protection, therefore coming under the purview of Sensitive Personal Information. This type of data includes: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation. We only collect and process special category data where necessary and will always seek Your consent to process it in terms of this policy. We currently collect ethnicity data to comply with statutory reporting requirements. We may process health information which You choose to share with Us to make reasonable adjustments to Your assessment for a short- or long-term disability, or to give special consideration of extenuating circumstances, for example should You be unable to take an assessment for health reasons.
If you have any concerns or questions over the personal data, We collect please do contact Us and we will be happy to discuss this with You.
6. How do you use my personal data?
Depending on the product or service you have requested from Us, we will use Your personal data:
- To process your application/registration for the study of modules and qualifications. This may also require Your personal information to be passed to a third party for the delivery of study materials, or the provision of teaching or examination facilities. We may also contact other institutions to confirm Your qualifications.
- To process any application You make for membership and to maintain that membership.
- To process and issue certificates and/or digital badges to eligible students and customers (please refer to section 9 for details of who we share data with for digital badges).
- To process any application for additional services, such as CPD, seminars or conferences.
- To process payments and undertake fraud prevention.
- To provide information about additional services and products that may be of interest to You.
- To undertake research in order to help Us plan and improve Our services.
- To provide information to government bodies, such as Ofqual in accordance with statutory and government requirements.
7. How do you protect my personal data?
We use a range of technical and organisational measures to protect Your personal data. This includes:
- Training all staff on the principles of data protection and including terms within contracts and annual compliance checks.
- Secure processing of all transactions via Our Website.
- Applying secure storage and encryption methods to personal data held on Our computer systems.
- Ensuring appropriate contracts are in place where we deliver our services with third parties and undertaking compliance audits where relevant.
- Industry standard security and encryption employed for the transfer of personal data between sites and third parties.
- CCTV used to monitor and record building entry and exit points, key card entry to office buildings and coded security access to server rooms.
- Monitoring our systems and undertaking annual penetration testing and monthly vulnerability scanning to identify and strengthen any vulnerabilities identified.
8. How long will you keep my personal data?
We will only keep Your personal data for as long as is necessary for the purpose it was collected. You can find some examples of this below:
Study records – we will keep personal data relating to Your studies (academic record) permanently. This forms part of Our core records and enables us to provide verification of any awards you achieve, issue replacement transcripts/certificates and meet any legal obligations including the prevention of fraud.
Reasonable Adjustments and Special Consideration – information You provide to request reasonable adjustments for a short- or long-term disability, or special consideration of extenuating circumstances will be kept for as long as required to support Your studies and meet the requirements of our assessment boards.
Financial transactions – we are legally obliged to keep a record of all financial transactions for six years.
9. Who do you share my personal data with?
We will share Your personal data with third parties where necessary to deliver Our products and services. This includes:
- Other organisations we work with to deliver training and qualifications.
- Couriers for delivery of study materials.
- Printing and scanning services for production and marking of assessment materials.
- Venues We use for the delivery of assessments to enable booking and identification of candidates.
- Digital badging and credential services
- Venues and speakers We use for the delivery of events
- Government and other regulatory departments where We have a legal obligation or legitimate interest to do so
Where we share personal data with third parties We will;
- have an appropriate agreement specifying how the data may be used;
- only share as much information as is required to deliver the specified service;
- require they have suitable technical and organisational measures in place to protect Your personal data, and;
- ensure your personal data is securely disposed of when it is no longer required to deliver the service or on termination of Our agreement with the third party.
We will not share or sell Your data to third parties to use for their own purpose. We do sometimes identify third party products or services that may be of interest to Our customers and may share this ourselves with customers who have opted-in to receive this information (see ‘marketing preferences’).
We will share Your data to any other body corporate or person, which maintains the same level of data protection that is required under the laws of India. Any such transfer of data will be made in terms of a legal contract and/or a legal obligation and shall not be made without the consent of such body corporate or person.
10. Where might my personal data be processed
The majority of personal data We collect is processed and stored within India or the UK/EU for processing undertaken within the LIBF group companies. However, We have students and members throughout the world and the personal data of those students and members is necessarily transferred overseas when fulfilling their applications for study, membership or other services.
In some cases, such as for the delivery of examinations through our suppliers, personal data may be stored and processed in the US on Our behalf. All data is transferred and held in compliance with applicable laws and appropriate safeguards such as the use of Standard Contractual Clauses to protect Your individual rights over Your personal data.
11. What are my rights over my personal data?
We respect the exercise of the rights You have in relation to the personal data, that We process or use. You can request access to or a copy of your personal data collected and processed by Us. You may also request the rectification and removal of personal data or the restriction of the processing of Your personal data. Users have the right to unilaterally change their e-mail and contact preferences at any time by logging into their “Account” on the Website and changing the account settings. If You have an objection to use of Your data under this policy, please write to Our customer services team. To prevent misuse, We will ask You to identify yourself.
You can exercise the following individual rights over your personal data:
To be informed how we will use your personal data
We will inform You of how we will use Your data by short processing statements, typically provided at the point You request a product or service from us, and in more detail via this Privacy Notice. We will also endeavour to answer any further questions You may have on how we use Your personal data.
To have access to your personal data
You can gain access to most personal data we hold for You by logging into Your MyLIBF account. You can also gain access to any further information We may hold by submitting a Subject Access Request (SAR), which is free of charge in most cases.
To correct your personal data
You can request we correct any personal data for You which may be inaccurate, incomplete or out of date. You can amend most of your personal data by logging into Your MyLIBF account.
To have your data deleted
You can request that we delete personal data that we hold for You. We will consider all requests for deletion and endeavour to fulfil the request where possible. We will not normally delete records of qualifications as this forms part of our core academic record and may be necessary to prevent fraudulent activity. We may also be legally obliged to retain some personal data for a specified period of time such as financial transactions and to meet statutory reporting requirements. We will highlight as far as possible the implications of deleting any personal data but may not be able to foresee all circumstances and the final decision to accept the deletion will need to be Yours. We will hold a record to be able to confirm We have processed a deletion request.
To have your personal data provided in a portable format
You can request that We provide a copy of your personal data in a format that can be easily shared with another organisation. We will normally provide this in a .csv (comma-separated values) format, compressed within a .zip file, but will endeavour to meet any other requests.
To restrict the processing of your data
You can request that we restrict how we process Your data. This may be used as an alternative to having data deleted, allowing Us to store your personal data but not process it. This may affect the products or services we can provide to You and there may be some limitations where We have a legal obligation to still process.
To object to the processing of your personal data
You have the right to object to direct marketing at any time. You can do this by logging into Your MyLIBF account and changing your preferences to opt-out or by clicking the link included at the bottom of all marketing emails We send. This will not affect transactional emails We send that are necessary for delivering any product or service.
12. How can I manage my marketing preferences?
You can change your preferences at any time by using the link at the bottom of all our marketing communications. This will only affect marketing communications and You will still receive transactional communications which are necessary to deliver the products and services You have requested.
You can opt out of Google’s use of cookies through Your browser settings or by visiting Google’s Ads Settings or Google Analytics’ currently available opt-outs. Alternatively, You can opt out of third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt out page.
13. Who is the regulator for data protection?
Should you be unhappy with the way we have used your personal data or how we have responded to a request, you have the right to lodge a complaint with the Ministry of Electronics and Information Technology (“Ministry”). The Ministry is responsible for administering the Information Technology Act, 2000 (“IT Act”) and issuing the rules and other clarifications under the IT Act. We ensure that your data and information shall be protected under the provisions of General Data Protection Regulation, Information Technology Act, 2000, Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 along with any amendments made to these acts, rules and regulations.
If you are based outside of India, You may have the right to lodge a complaint with the data protection supervisory authority in Your country of residence.
14. Who should I contact to exercise my rights or seek further information?
We do not control or endorse the content, messages or information placed on the Website by any third party and, therefore, We specifically disclaim any liability with regard to such information and Your participation/ engagement with our Payment Facilitators and any other third party service providers and services offered by them and You agree that you waive any claims against Us relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Us relating to the same.
You are responsible for maintaining the accuracy, truthfulness, correctness and completeness of the information You submit or provide to Us, on the Website; and shall hold harmless and indemnify the Company from and against all claims arising out of or in relation to the wrongful information posted, provided by You to Us, on the Website.
If Your personal information changes, You may correct, delete inaccuracies, or amend information by contacting Us at info@libf.in. If you wish to cancel Your account or request that We no longer use Your information, contact us at info@libf.in.
The Company shall address any discrepancies and grievances of their provider of the information with respect to processing of information in a time bound manner and to give effect to this purpose, the Company has designated its authorised person as a ‘Grievance Officer’ and the ‘Grievance Officer’ shall redress the grievances or provider of information expeditiously but within one month ‘ from the date of receipt of grievance.
If you have any questions, require further guidance or would like to submit a rights request, you can contact our Grievance Officer by;
- Name: Ms. Aastha Arora Arwin
- emailing info@libf.in or;
- Address: Indiaedge Education Pvt. Ltd. Unit 6, Skootr Offices, Infinity Tower A – Cyber City DLF Phase 2, Sector 24, Gurugram, Haryana 122002, India
V1.0 – March 2023