Questo Wellbeing Private Limited (hereinafter referred to as "we", "our", "us" and “Questo” and shall include any affiliates) understands the privileged position we are in while providing the Programs through the Stoa Community and are committed to protecting the information and data shared by all of our users (hereinafter referred to as “you”, “yourself” and “Fellow”) with Questo. In light of the same, we have created this privacy policy (“Privacy Policy”) which is in compliance with the Information Technology Act, 2000 (“IT Act”) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the "SPI Rules"). The privacy mechanism outlined in this Privacy Policy, as amended from time to time, identify personally identifiable or personal information that may be collected, how such information is used, and the choices you have regarding our use of this information.
Please read this privacy policy carefully as by participating in the Programs and joining the Stoa Communities as defined in the T&C, you agree to be bound by the terms described herein and all the terms incorporated by reference. Any information provided to us is subject to this Privacy Policy. Should you continue to participate in the Programs or join the Stoa Community and provide your personal information, such act would constitute your consent to the terms contained herein.
- Your Consent
A prerequisite for participating in the Programs and obtaining access to the Stoa Communities is the acceptance of this Privacy Policy. This Privacy Policy shall apply to all users that join the Programs or Stoa Communities. You grant your consent to be bound by the terms of this Privacy Policy by:
- Joining the Programs or Stoa Communities as per the Terms of Use;
- submitting any information to Questo;
- by participating as part of a Program or on any Stoa Communities;
- During your continued participation in a Program, we may need to send routine communications to you and other administrative messages through email and notifications posted on the Stoa Communities or through other means available, including text and other forms of messaging. You agree to receive our phone calls related to your participation in the Program or Stoa Community or any other mode of communication as may be deemed appropriate.
- When you also consent to allowing us to periodically send emails about new products, special offers or other information, which you may find interesting and in line with your interests. If you do not wish to receive promotional information from us, you can, at any time, choose to opt out of receiving such promotional communications by following the process mentioned in the promotional communication.
- You must ensure to provide us with the correct or up-to-date personal information at the time of registration for the Programs. This will allow us to contact you for further correspondences with respect to the Program. We are not responsible for any inaccurate information you provide to us, which may affect your experience on the Program and Stoa Communities.
- If, at any time, you want to access, update, modify or eliminate any information provided by you during the onboarding process or which is part of any profile maintained by Questo, you may do so by writing to us at cohortops@stoa.com with a request for updating, modifying or deleting any information shared by you.
- We may, in future, request other optional information from you in order to provide a better experience for you on the Program
- Personal Information
- While participating in the Program you will provide Questo with certain personal information which are required as part of the onboarding process for a Program or for any other purposes as Questo may intimate from time to time. The term “personal information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available with Questo, is capable of identifying the person concerned and includes amongst other things age, phone number, email id, location etc. You may also share certain “sensitive personal information” which includes within its ambit personal information of any individual relating to financial information such as bank account or credit card or debit card or other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; any detail relating to the above as provided to or received by Questo for processing or storage. Any data that is freely available to the public or made available to Questo through public sources or by way of right to information will not be considered as sensitive personal information. We do not knowingly ask for sensitive personal information on the Stoa Communities, and Fellows should not disclose any sensitive personal information on the Stoa Communities. Questo shall have no liability for any information uploaded on Stoa Communities by the Fellows on their own. While using Stoa Communities you shall also be bound by the terms and conditions of the privacy policy of the respective Stoa Community. Please ensure that you read through the said privacy policy before submitting any sensitive personal information to a third party on Stoa Communities. All information upload by a user shall be deemed to be uploaded in compliance of all applicable laws.
- Questo has implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. While we try our best to provide security that is commensurate with the industry standards, because of the inherent vulnerabilities of the internet, we cannot ensure or warrant complete security of all information that is being transmitted to us by you. However, Questo will take all reasonable measures to ensure that your information is not modified or used for any unauthorised purposes.
- You have the right to request for edits, modifications or deletion of any personal or sensitive personal information provided to Questo. When editing or deleting personal information shared by you at your request, we may ask you to verify your identity before we can act on your request. However, we do not assure that we will delete all residual copies and archives made by any third party service providers without our knowledge and consent.
- During the course of participation in the Program the following information may be collected from you:
- Name
- Gender
- Date of birth
- Email Address
- Phone number
- Link to Your LinkedIn profile
- Twitter profile
- Work Profile
- Annual Salary
- Current Designation
- Financial Information (including details for payments)
- Residential Address
- Questo may also keep records of telephone calls received and made to their personnel for regarding the Program and your enrolment and onboarding in the Program as well as recordings of calls and sessions conducted on any Stoa Community.
- The Stoa Communities may enable users to communicate with other users or third-party service providers to post information to be accessed by others, whereupon other users may collect such data. Questo hereby expressly disclaims any liability for any misuse of such information that is made available by Fellows on Stoa Communities in such a manner.
- Questo shall not be responsible in any manner for the authenticity of the personal information or sensitive personal information supplied by the user to Questo. If a user provides any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or Questo has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, Questo has the right to suspend access to Stoa Communities or the Program.
- Use of personal information
- Questo will collect and retain your personally identifiable information only to the extent that it is necessary to fulfil our services to you and for regulatory purposes. Any personal information submitted by you to Questo or collected by us will be used only for the purposes mentioned below:
- for onboarding of the Fellow as part of the Program
- to carry out our obligations arising in relation to the Programs;
- To improve the Program's functionality, and to customise your experience with us;
- To communicate with you about the Program and Stoa Communities;
- To verify your identity and perform checks to prevent fraud;
- Non-personally identifiable information, exclusively owned by Questo may be used in an aggregated or non-personally identifiable form for internal research, statistical analysis and business intelligence purposes, and Questo may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates;
- Dealing with grievances, complaints and queries raised by the users or other Fellows
- Ensuring that the provisions of the Terms of Use and Privacy Policy are complied with by all users.
- Disclosure of personal information
- Questo in the course of providing access to the Programs or Stoa Communities may need to disclose/ transfer certain personal information to third parties for the purposes mentioned in this Privacy Policy and the Terms of Use or as may be required for the use of Stoa Communities. The parties to whom such information may be disclosed include:
- To the third-party service providers. Any information that a user may provide on a Stoa Community may be subject to the Stoa Communities own privacy policies;
- to our payment service partners and websites;
- To our affiliates in India or in other countries who may use and disclose your information for the same purposes as us;
- To our employees for the purpose of ensuring that the Program is made available to you, subject to the fact that our employees shall be bound by obligations of confidentiality;
- To government institutions/ authorities to the extent required a) under the laws, rules, and regulations and/ or under orders of any relevant judicial or quasi-judicial authority; b) for the purposes of prevention, investigation and prosecution of cyber incidents; c) for reporting any offences committed by users; iv) to protect and defend the rights or property of Questo; d) to fight fraud and credit risk; e) to enforce Questo's Terms of Use (to which this Privacy Policy is also a part); f) for verification of any information provided by users; or g) when Questo, in its sole discretion, deems it necessary in order to protect its rights or the rights of others;
- where substantially all our assets are acquired by a third party, such information may be one of the assets that is transferred or acquired by a third party. Under such circumstances, Questo would attempt to ensure that the third party acquiring Questo follows the provisions of this Privacy Policy and process your personal information as set forth in this Privacy Policy
- How long will personal information be retained
- Under normal circumstances the personal information collected by Questo will only be retained for such periods of time as may be required for completion of the Program or throughout the term of your use of the Stoa Community. We may retain the other information for such other period as may be prescribed by applicable laws. Confidentiality of such information shall be maintained during the period of retention.
- Security Policy
- Questo takes careful precaution to protect our user's personal information from unauthorised access, improper use or disclosure or unauthorised modification. To prevent unauthorised access, we have put in place the latest industry-standard security technology and procedures to safeguard the information we collect online including technical, operational and physical security controls. Your personal information is encrypted and is protected with the most secure encryption software, which encrypts all information you input. We store your personally identifiable information on the computer servers placed in a secure environment. Questo also attempts to ensures that all third-party service providers to whom personal information is provided take similar precautions with the information. Even though we have taken significant steps to protect your personally identifiable information, no company, including Questo can fully eliminate security risks associated with personal information. We further disclaim any responsibility for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
- Third Party Links
- The links to third-party advertisements, third party websites or any third party electronic communication services (referred to as “Third Party Links”) may be provided on Stoa Communities which are operated by third parties and are not controlled by, or affiliated to, or associated with Questo unless expressly specified by Questo. If you access any such Third Party Links, we request you review the website’s privacy policy. We are not responsible for the policies or practices of Third Party Links.
- Cookies
- The Questo website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by Us for maintenance of the website and its features as well as research and development. We do not store personally identifiable information in the cookies
- Amendment of Privacy Policy
- Questo may update or amend this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way Questo treats the user's personal information, Questo will send users an email.
- Notwithstanding the above, Questo shall not be required to notify the users of any changes made to the privacy policy. Should you have any concern or reject the changes in the Privacy Policy you can refuse to accept the amendments and opt for withdrawing your personal information by writing to the Grievance Officer.
- Grievances
- If you have any compliant or grievances or concerns with respect to Platform or this Privacy Policy, please inform such matters to cohortops@stoa.com in writing or through electronic mail