We regard the lawful and correct treatment of personal information as important to our successful operations and to the maintenance of confidence of those with whom we deal.Common Room respects your concerns about privacy and values the relationship we have with you. This Privacy Policy describes our privacy practices with respect to information collected through our websites, email newsletters, social media pages, mobile and other applications owned and operated by us, our offline contacts, and any other services that link to this Privacy Policy (collectively referred to as the “Services”).

Please carefully review this Privacy Policy below before using our Services. By using our Services, you are accepting the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Services.  We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice.  Your continued use of our Services following the posting of changes to these terms will mean you accept those changes. 

What Personal Information We Collect About You

When you use the Services by, for example, purchasing a downloadable worksheet bundle, providing registration details, subscribing to a newsletter, browsing our sites, completing a survey, entering a sweepstakes, requesting information from us or otherwise interacting with our Services, we gather personal information. “Personal Information” is information that identifies you as an individual or relates to an identifiable individual. Several different types of Personal Information can be gathered when you interact with the Services. Collection of Personal Information is necessary to provide the Services to you or to enhance your consumer experience.

If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We and our service providers collect Personal Information in a variety of ways, including: 

Through the Services 

• Product purchases: When you purchase a course or other product through our Services, we collect Personal Information such as your name, mailing address, telephone number, email address, credit or debit card information and other billing information.
• Loyalty Program: When you register for our Loyalty Program, we collect Personal Information such as your name, email address and proof of purchase documentation you provide to us. 
• Newsletter subscriptions: We collect your email address when you subscribe to our newsletters. For certain newsletters, we collect additional personal information that may be relevant including your name, job title, interests and similar information.
• Sweepstakes, contests and other promotions: We collect personal information such as your name, email address and mailing address when you participate in sweepstakes, contests or similar promotions.
• Registration for programs and events: When you register for our programs, events or conferences, we collect personal information such as your name and email address.
• Course preferences and market research: We collect personal information from you including your course preferences (e.g., academic/ creative writing) you provide through the Services and any information you provide through voluntary surveys or feedback conducted through the Services, through our service providers’ platforms, by phone or during in-person interviews or focus groups.
• User-generated content: We collect personal information when you submit user-generated content through online communities and other publicly available sections of the Services, including comments, reviews, or any other material that you submit. Any personal information you submit through these public forums may be viewed by other users of these Services. We are not responsible for the personal information you choose to submit and we have no responsibility to publish, take down, remove or edit any of your submissions (except as required by applicable laws). For more information, please refer to the User Submissions section of our Terms of Use.
• Job applications: We collect personal information in connection with your application for a job at Common Room.
• Contact with our Customer Service: We collect personal information for you in offline contexts, including, for example, when you place an order over the phone or contact customer service.

From Other Sources

• Publicly available databases, including marketing and data analytics resources. For example, we may receive email addresses, mailing addresses and demographic information (e.g., age, sex, household income) from these sources.
• Authors and joint marketing third parties, when they share the information with us.
• Social media platforms and other third party service platforms.
• Third party business customers, clients and partners, when they share the information with us (e.g., sales data).
  

How We Use Your Personal Information

We and our service providers use Personal Information for the following purposes:

Providing the functionality of the Services and fulfilling your requests

• To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
• To respond to your inquiries and fulfil your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
• To enable you to participate in surveys, panels or research, and public forms on our websites.
• To complete your transactions, verify your information, fulfil your orders, and provide you with related customer service.
• To send administrative information to you, such as changes to our terms, conditions, and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Providing you with our newsletter and/or other marketing materials and facilitating social sharing

• To send you marketing related emails, with information about our services, new products and other news about our company. To opt out of these emails, please see the section labelled Choices and Access.
• To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

Analysing Personal Information for business reporting and providing personalised services

• To analyse or predict our users’ preferences so we can improve our Services.
• To better understand your interests and preferences, so that we can personalise our interactions with you and provide you with information and/or offers tailored to your interests.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalised services based on our legitimate interests, and with your consent to the extent required by applicable law.

Allowing you to participate in sweepstakes, contests or other promotions

• We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
• Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.  Please read those additional rules before choosing to participate.
  

We use this information to manage our contractual relationship with you.

Accomplishing our business purposes

• For data analysis, for example, to improve the efficiency of our Services;
• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
• For developing new products and services;
• For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests. 
  

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

Aggregating and/or anonymising Personal Information

• We may aggregate and/or anonymise Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

Combining Personal Information

• To perform the above functions, we may match information collected from you through different means or at different times, including Personal Information and Other Information (as defined below, see the section labelled Other Information and use such information along with information collected from other sources, such as demographic information and updated contact information.  We or our third party service providers may also use your information to assess the level of interest in, and use of the Services, our emails, and our other campaigns both on an individual basis and in the aggregate.  We may also use and/or combine information we collect off-line or from third party sources to check the accuracy of, enhance and supplement your user records, and to better customise your experience with us.
  

Other Uses

We also use your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations
• This may include laws outside your country of residence.
• To cooperate with public and government authorities
• To respond to a request or to provide information we believe is necessary or appropriate. These can include authorities outside your country of residence.
• To cooperate with law enforcement
• For example, when we respond to law enforcement requests and orders or provide information we believe is important.
• For other legal reasons
• To enforce our terms and conditions; and
• To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
• In connection with a sale or business transaction
• We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
  

With Whom We Shall Share Your Personal Information

We disclose Personal Information:

• To our third party service providers, to facilitate services they provide to us
• These can include providers of services such as website design and hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, ad serving, research survey/interview/focus group management and analysis, marketing, auditing, and other services.
• By using the Services, you may elect to disclose Personal Information.
• On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content.  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
• With other third parties
• We may also disclose your Personal Information for the other uses described above (e.g., to comply with applicable laws, cooperate with law enforcement, and in connection with a sale or business transaction).

Other Information Collected Using Technology

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

• Your browser or device 
• Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using.  We use this information to ensure that the Services function properly. 
• Cookies
• Cookies are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalise your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.  Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services.  We may also use cookies or other technologies in online advertising to track responses to our ads.  We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. 
• Pixel tags and other similar technologies
• Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, compile statistics about usage of the Services and response rates, and identify similar audiences to whom we can market our Services.
• Analytics. We use Google Analytics and Adobe Analtyics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  We also use Localytics to track analytics on our mobile apps. These services may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. 
• Physical Location
• We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals.  We may use your device’s physical location to provide you with personalised location-based services and content. 
• We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalised content and to study the effectiveness of advertising campaigns.  In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalised services and content.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined

Third Party Advertising

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties.  These companies place or recognise a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognise you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. 

HOW TO OPT OUT OF RECEIVING EMAIL NEWSLETTERS, AND YOUR CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  You may opt out from: 

• Email newsletters.  If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking the email footer link to unsubscribe or by emailing admin@commonroom.in. You may not be able to unsubscribe from communications that are not related to marketing; otherwise, you might miss important information about your account, the Services, or transactions you engage in on the Website.
• Joint marketing promotions. As described above (see section labelled With Whom We Disclose Your Personal Information), you may withdraw your consent to our sharing of your Personal Information with our joint marketing partners at any time by sending us an email at admin@thecommonroom.in.
• Mail promotions. We do not currently send direct mail solicitations (e.g., catalogues) without your consent. If, at any time, you prefer not to receive mail solicitations from us, please email us at admin@commonroom.in.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change, or delete your Personal Information

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us. We will respond to your request consistent with applicable law.  

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background) on or through the Services or otherwise to us.

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  The criteria used to determine our retention periods include: 

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

Security

We seek to use reasonable organisational, technical and administrative measures to protect Personal Information within our organisation.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by sending an email to admin@commonroom.in.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organisations, such as LinkedIn, Facebook, Google, or any other social media platform provider.

Use of Service by Minors

Except for a few of our child- and teen-directed Services, these Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

For more information on Common Room’s privacy practices for child-directed Services please refer to the Code of Conduct and Child Protection Policy below. The Privacy Policy on our child-directed Services will automatically link to this section.

Code of Conduct and Child Protection Policy

Common Room recognises that we have a fundamental duty of care towards all children we engage with, including a duty to protect them from all forms of bullying and abuse. We strive to create a safe environment in which no child will experience harm or exploitation during their contact with us. To achieve this, we have created a Code of Conduct and Child Protection Policy, to be adhered by the trainer and learners alike, inside our classrooms. 

Common Room is committed to:

• valuing, respecting and listening to all learners.
• creating inclusive classrooms free of any form of bullying.
• ensuring confidentiality and protecting personal data collected from the clients.
• be culturally sensitive and respect the diverse backgrounds of its learners.
• responding quickly and effectively to grievances. 
• Inside our classrooms, Common Room requires the learners to:
  not share their personal information such as e-mail id, phone number, or address to peers without the knowledge of the trainer.
• not make comments about their peers’ skin colour (dark, fair etc), physical appearance (pretty, ugly, thin, fat etc.) or personal traits (shy, chatterbox, bossy etc.), to prevent any form of bullying.

What Information We Collect and How We Use It

We do not require children to share any Personal Information in order to participate on this Site.  On occasion, however, we may collect Personal Information, such as an email address from a child as part of an activity, in accordance with our Code of Conduct and Child Protection Policy.  For example:

• Email address: We may collect a child’s email address in order to respond to a one-time request from the child, such as if the child asks us a question.  In such cases, we promptly delete the child’s email address from our system once we have responded, and we do not use the child’s email address for any other purpose. 
• Send-a-friend: In the case of send-a-friend email or card, we only collect a child’s first name and the friend’s email address to send the friend the email or card.  We do not store the friend’s email address for any longer than reasonably necessary to send the email or card to the friend.
• Contests or Sweepstakes: We may collect a child’s email address to enter the child in a sweepstakes or contest or to notify the child that he or she has won or lost a contest or sweepstakes or contest.  We will not keep the child’s email address after the promotion or use the child’s email address for any other purpose other than for the promotion.  For certain promotions, we may ask that a child give us his/her parent’s email address so we can obtain more personalised information for prize fulfilment purposes if the child wins the promotion or to notify the parent if we need more than the child’s email address to enter the child in the promotion. In the latter event, parents will be sent a notice along with instructions on how they may provide their consent for their child to participate in such promotion.

We may also collect Other Information automatically from your child’s computer or device, such as the frequency with which the child visits our Site and the pages visited, to support the internal operations of the Site.  We collect this information so we can understand and monitor usage of the Site, customise content on the Site and improve the performance of the Site. This information is collected using technologies such as cookies, web beacons, and similar technologies.  This information is not used to behaviourally target children and we do not permit behavioural targeting on any of our Services that are directed to children. 

Special Circumstances for Information Sharing and Security

We may share children’s personal information with “Third Party Service Providers” and “Other Third Parties When Required by Law” as disclosed above.

Parent’s Rights

Parents have the right to review and have any of your child’s information deleted from our records.  You also have the right to tell us to stop collecting or using your child’s personal information. If you have questions concerning our information practices with respect to children, or if you would like to review, have deleted, or stop the further collection of your child’s personal information in connection with the transaction for which it was originally collected, you may email us at admin@commonroom.in.

Governing Law

The Sites are created and controlled by Common Room. These disclaimers, terms, and conditions of use are governed by the Indian Law. If any portion of these terms is held to be unenforceable, the unenforceable portion shall be construed in accordance with applicable law to the greatest extent possible to reflect the original intentions of the parties, and the remainder of the provisions shall remain in full force and effect. Common Room’s failure to insist upon or enforce strict performance of any provision of these Terms of Use shall not be construed as a waiver of any provision or right.

Collection of Personal Information

We plan to collect the following categories of Personal Information:

• Identifiers.” Identifiers, such as name, alias, contact information, unique personal identifiers, and online identifiers;
• “Customer Records Information.” Personal information such as financial information (credit and debit card information and billing information);
• “Protected Class Information.” Characteristics of protected classifications such as sex, age and race;
• “Transaction Information.” Commercial information, such as transaction information, purchase history, financial details and payment information;
• “Online Use Information.” Internet or network activity information, such as browsing history, interest data and interactions with our websites;
• “Geolocation Data.” Geolocation data such as device location and approximate location derived from IP address;
• “Audio/Video Data.” Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities;
• “Employment Information.” Professional or employment-related information, such as job title and work history; and
• “Inferences.” inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, [an individual’s preferences and characteristics.

Where We Obtain Personal Information From

As described above, we collect this Personal Information from you and from other categories of sources, including publicly available databases, authors and joint marketing partners, social media platforms and third party service platforms, and our business customers, clients and partners, when they share this information with us.

Our Use of Personal Information

Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalise, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

Disclosure and Sale of Personal Information

We share Personal Information with the following categories of third parties:

• “Affiliates.”  We share with our affiliates for the purposes described in this Privacy Policy.
• “Service Providers.” We share with our trusted third-party service providers, to facilitate services they provide to us, such as internet services, website hosting, data analytics, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, background checks, and other services.
• “Ad Networks.” We share with third-party ad networks and online advertising partners to permit them to send you marketing communications.
• “Marketing Partners.” We share with our marketing partners to permit them to send you marketing communications, consistent with your choices.
• “Social Networks” We share with social network platforms, who use the data we share in accordance with their own privacy policies.
• “Business Partners.” We share with our trusted business partners.
• “Contest Sponsors.”  With your consent, we share with third-party sponsors of sweepstakes, contests, and similar promotions.
• “Legal Authorities.”  We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.
• “Other Parties in Litigation” We share information in the context of litigation discovery and in response to subpoenas and court orders.
• We generally do not “sell” your Personal Information except in a few limited cases to support our business operations (e.g., email addresses to correct and enhance our contact lists). We do not knowingly sell the Personal Information of minors under 16 years of age.