Hurix Systems Pvt. Ltd. (“Hurix”, “us”, “we”) helps organizations from across the world achieve their business goals through its learning content, digital marketing, and technology services. We design and build our solutions on core principles of innovation, end-user experience, and customer satisfaction, such that they work across traditional and newer mobile platforms, formats and devices to deliver and manage highly compelling and engaging digital content.
It is Hurix’s policy to respect your privacy regarding any information we may collect while you use or access our software applications and websites.
Hurix operates web-based applications such as Kitaboo and ePub3Automation, that are part of the services that we offer. These products are offered through domain www.kitaboo.com. All such products, applications, websites are collectively called “Services”.
This document is an electronic record in terms of the Information Technology Act, 2000 and the rules framed thereunder, as applicable and amended from time to time, pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
Data Controller and Data Processor
We process two main types of personal data.
- Customer Data – Personal data that forms part of the data that is provided by our customers and their end-users for processing.
- Other Data – Personal data about our customers, Website visitors and other individuals that is collected and processed directly by us.
Our Customers are the controller of ‘Customer Data’. Hurix is the processor of ‘Customer Data’ and the controller of ‘Other Data’.
Domains and Websites for this Policy
For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.hurix.com, www.kitaboo.com as well as the other websites that the Hurix Group operates and that link to this Policy.
Information We Collect
Customer Data that you provide
As customers, you provide data to us for processing as part of usage of our Hurix applications
‘Customer Data’ may be processed by us as a result of customer’s use of the Services when our customers, or their end-users, input or upload information into the Service. For example, customers who use our Kitaboo application may upload ‘Customer Data’ about themselves or their employees, institutional partners or schools.
- We collect personal information from you when you create an account, such as your first name, last name, email address and phone number.
- We collect any personal information that you include in your user profile and public profile, public contents, and during use of our services such as annotations, file uploads and notes.
If you are a school, you should contact your publisher about their privacy practices. If you are a school student, you should contact your school or teacher to understand your school’s privacy practices.
Other Data that we collect
Hurix also collects data when you use our Websites, Social Media, Blogs and applications:
- We collect information related to your use of our products and services, such as your touch gestures, highlights, bookmarks, page views, and other applications you may use with our products and services. Our products provide information to us about its status, such as uptime, available memory, and errors that may have occurred.
Website Visitor Data
- Users on Hurix website may voluntarily provide certain personal data, not limited to first and last name and email address, to Hurix when choosing to participate in various activities regarding its services such as surveys, webinars, forums, downloads of whitepapers, videos, case studies, and other documents, requests for demonstrations or pricing information, uploads of job resumes, and subscription of various services provided by Hurix. This will be used by Hurix to operate, maintain, and provide you the features and functionality of Hurix’ services.
- Log Data – Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address
- Product Demo and Subscription – You provide personal data to us as part of signing up for our newsletters or to request for product demos.
- Contact Us Data – When you enquire about our products and services, we collect and store this data to communicate with you and respond to your enquiry. Example of such data include First Name, Last Name, Email Id.
Data from Others
User registration services that you use
You may also use third-party registration services or applications to sign up with Kitaboo. We then get data from these applications.
We currently use Google Analytics to collect information anonymously and reports website trends without identifying individual visitors.
As our customer, you have an option to decide if following personal data can be captured by Google Analytics:
- Which user access/download ebook. (Username/email Id only)
- User location & Device Type
- What reader feature user is using more
We use Google Analytics for analytics and measurement to understand how our services are used. For example, we analyse data about your visits to our sites to do things like optimise product design.
We collect data through cookies.
How We Use Your Data
How we use your personal data will depend on which Services you use and how you use those Services.
Customer Data will be used by Hurix in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. Hurix is a processor of Customer Data and Customer is the controller.
Other Data is used by us to provide our services, send our newsletters, send promotional material and to communicate with you by responding to your requests, comments and questions.
We may collect personal data from you when you seek educational services from us. Such collection often occurs through your use of, or interaction with, the site. When you express interest in our platform/services, for example, by creating an account for your/your child/children’s use, on our site, we may collect your name, email address, phone number and any other information we may deem necessary to provide the requested services. We may collect additional information from you depending on you/your child’s requirement, purchase or use, including your identification or Social Security Number, home address, other similar identification details. We may use this information to: (1) to provide the requested services, (2) to facilitate any transaction by the services you use, (3) to provide you with access to the service, (4) to provide customer support, (5) to contact you or your designated contacts about the services being used, (6) to analyse your interaction with our services, (7) to improve our site and/or services, (8) for security, credit or fraud prevention purposes, (9) to invite you to participate in surveys and provide feedback to us, (10) to better understand your/your child’s needs and interests, (11) for any other purpose identified in the site’s terms and conditions, or (12) otherwise as necessary for complying with applicable laws and regulations.
We may process your personal data with your consent or without your consent, where (a) processing is necessary for the performance of a student, with you or notified measures at your request; (b) processing is necessary for compliance with a legal obligation to which Kitaboo is subject; (c) processing is necessary in order to protect your vital interests or those of another natural person; or (d) processing is necessary for Kitaboo’s legitimate interests (such as, managing, improving or promoting services).
If you create an account on the Kitaboo website or express interest in setting up an account for your child/children, in either case whether online through the site or through third party websites, we many collect your name, email address, phone number and other personal data. We may use this information to contact you about your request for account setup, to verify information you provided in your account setup request, and in the event being setup/enrolled with Kitaboo, for the administration of benefits and maintaining your back up contact in our files till such time that your child/children are enrolled with Kitaboo or using our platform services. You may unsubscribe from these communications by letting us know via email or call. Finally, we also may use the information described above in any other manner as described to you at the point of collection or pursuant to your written consent.
Lawful bases for processing
We have lawful bases to process your personal data. We also use your consent as bases for lawfully processing your personal data.
We process your personal data only when we have a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the EU General Data Protection Regulations. If you believe certain services are not in your interest, you have a right to object.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where you have consented to a particular processing, you have a right to withdraw the consent at any time by sending an email to our product support team at firstname.lastname@example.org .
DISCLOSURES AND TRANSFERS
Disclosure to legal authorities:
We may share any of the information described in this Privacy Statement, in connection with any lawsuit or proceeding, or in response to legally valid requests or demands from courts, law enforcement, regulators and other government agencies, including for audit purposes by government agencies. Furthermore, we may disclose any of the aforementioned information, if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraudulent activities.
How we use Customer data
We use your data to authenticate you and authorize access to our services
We only process Customer Data on behalf of our customers and in accordance with their instructions provided in the applicable Services agreement with us. We use the data that we have about you to provide our services and provide support to you. In each case, Hurix collects such information only in so far as is necessary or appropriate to fulfil the purpose of the interaction with our services.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services and our Services offerings. These communications are considered part of the Services and you may not opt out of them. We may use your information in the following ways:
- to send you a welcome e-mail and to verify ownership of the e-mail address provided when your user account was created;
- to identify you as a user in Hurix’s system;
- to provide access to the Website;
- to facilitate the creation of and secure your user account;
- to provide improved administration of the Website;
- to notify you about updates to the Website;
- to improve and customize the quality of experience when you interact with the Website;
- to send you administrative e-mail notifications, such as security or support and maintenance advices;
- to engage with or contact inactive users of the Website;
- to direct certain content and advertisements to you so that you are more likely to see content and advertisements that are relevant to you;
- to analyze the data submitted by you;
- to send offers and promotional materials related to the Website and those of third parties for marketing and other purposes.
- Aggregated Analytics. We also use our Customer’s end user data to derive aggregated analytics such as duration of book reading, Book Opened / Assigned, Reading Time, Pages Read, Reading Sessions, Avg. Reading Time / Session, Avg. Pages Read / Session, Notes Shared / Created, Highlights Shared / Created, Resources Viewed / Available etc.
- Customer Support. If you send us a request (for example via a support email or via one of our feedback mechanisms), we respond to your request or to help your issues.
- For any other purpose as provided for in the Services Agreement between us and the customer, or as otherwise authorized by the customer;
- In accordance with or as may be required by law.
How we use Other data
We may set up product demos or send you marketing / promotional materials. You may choose to restrict the collection or use of your personal information
We will update you with improvements in our services, new features and from time to time also carry out direct marketing of our products and services. Direct marketing is carried out only if you consent to receive such communications from us.
We also send invitations to our events or conferences.
Users under 16 years of age
The Sites and Services do not knowingly collect personal information from users under the age of 16. If you are under the age of 16, you are not permitted to use the Sites and Services except as an end-user student.
In compliance with Children’s Online Privacy Protection Act (“COPPA”) regulations, services directed to children under the age of 13 years require verifiable parental consent prior to the use of our services.
If you are a parent and would like more information on parental rights with respect to a child’s educational record under the U.S. Family Educational Rights and Privacy Act (FERPA), please contact us at email@example.com.
Data Retention Policy
Customer Data – We retain your information for as long as you have an active Services account. We may also retain your personal information for extended period under applicable statutory laws.
Hurix will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement, or for two years if there are no such instruction, and as required by applicable law. When you decide to close your account, we delete all personal information about you including any user generated content save and except the personal information required to be retained under applicable law and order.
You can request to access, update or correct your personal information. You also have the right to object to direct marketing. For all requests relating to your rights, you can contact us at “firstname.lastname@example.org.”
You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the GDPR, and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.
Customer’s Rights to Control Data
Whenever you use our services, we aim to provide you easy means to access, modify, delete, object to or restrict use of your personal information
We strive to give you ways to access, update/modify your data quickly or to delete it unless we have to keep that information for legal purposes. Some rights can be access from within the Hurix application. For visitors, these rights can be exercised by contacting us with your specific request.
- Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
- Delete Data: You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to provide Services to you).
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g. if we have no legal right to keep using it) or to limit our use of it (e.g. if your personal data is inaccurate or unlawfully held).
- Withdraw your consent – Any consent that you provide, including for direct marketing, can be withdrawn at any time, by contacting us or by changing your preferences in the application.
- Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
We keep some personal data even after account closure
Once you choose to close your account, we generally delete your personal information within 30 days of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained as necessary.
Your information shared with others
Recipients of your data
Your data will be shared with other recipients in order to provide you with services.
While we aim to limit the sharing of your data, at times, it is necessary to share your data with certain service providers. Examples of when and for what purpose your data is shared include data center / hosting services, email marketing services, etc.
The following categories of recipients will most likely receive your data in order for us to provide services to you
- Third Party Data Center Services
- Third Party SMTP Services
- Third party temporary file upload tools
- Salesforce /Pardot CRM for direct marketing
- Third party analytics tools and services
To comply with laws. If we receive a request for information, we may disclose if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
Your data that is publicly accessible may be seen by others.
Your username, public profile information, and public content may be seen by other users of our products and services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
Hurix may disclose your information to third parties if it determines that such disclosure is reasonably necessary to: (a) comply with the laws; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of its name, brands, trademarks or such other rights belonging to it or its other users; or (d) protect its rights.
Stewardship of your data is critical to Hurix and a responsibility that Hurix embraces. Hurix believes that its users’ data should receive the same legal protections regardless of whether it’s stored on its servers or on your home computer systems or devices. Hurix will abide by the following principles when receiving, scrutinizing and responding to government requests for its users’ data:
- Be transparent,
- Fight blanket requests,
- Protect all users, and
- Provide trusted services.
Cross-Border Data Transfers
Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region.Your data will be processed within Third Party Data Centers in USA, India and Germany. Data of our customers operating from European Union and United Kingdom is located at Frankfurt, Germany. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer which you hereby agree and acknowledge.
Hurix offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between Hurix and its Clients, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.
Security Measures to Protect your Data
We implement security controls to prevent breaches and unauthorised access to your data. We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access controls, encryption, HTTPS, restricted access to data, monitoring for threats and vulnerabilities etc.
We also subject our services to internationally recognised certification and attestation standards.
Protection of personal information
Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information. Hurix takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
However, no method of transmission over the internet, or method of electronic storage, is 100% secure so Hurix cannot fully ensure or guarantee the security of any information you transmit to Hurix or guarantee that information on the Website may not be accessed, disclosed, altered, or destroyed by any person.
Retention and Security:
Kitaboo may retain personal data and other information as long as it is needed to provide services that you or your child/children have enrolled into, to communicate with you about requests you have made, to manage your choices and rights you have exercised pursuant to this Privacy Statement, to comply with our legal and regulatory obligations, to demonstrate compliance, and to enforce Kitaboo’s rights and agreements.
We put in efforts to take appropriate security measures to protect personal data against loss, misuse and unauthorized access, alteration, disclosure, or destruction. Although we take reasonable measures to protect the confidentiality, integrity and security of your personal information, we cannot guarantee the security of your personal information. For this reason, we urge users to take every precaution to protect their personal information. In addition, we train our employees about the importance of information security, privacy and data protection.
Information about Children:
Kitaboo collects information from children only to the extent required to provide them the services that they have enrolled for. We ask that minors below the age of 18, do not submit any personal data to us or use the services offered through our site unless their parents have provided the written consent to Kitaboo for such use.
We use a number of mechanisms like encryption and passwords, to protect the security and integrity of your personal information against unauthorized access and disclosure. Unfortunately, no data transmission over the internet can be guaranteed to be completely secure. While we strive to protect such information, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once any personal information comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure.
Where applicable, you may exercise certain rights of access, rectification, erasure and portability of personal data, as well as restriction of, or objection to, the processing of your personal data in the conditions determined by applicable law. Contact us to exercise your rights or ask for additional information.
If you have questions or complaints regarding this Policy, you may contact us through email at email@example.com. You may contact us at our mailing address below
Hurix System Private Limited
Unit #102, 1st Floor,
Seepz-SEZ, Andheri (East)