Privacy Policy.

Preamble

This Privacy Notice is issued by Paritosh Pathak International LLP, a limited liability partnership incorporated under the Limited Liability Partnership Act, 2008, bearing LLPIN AAG-4674, having its principal office at Tower B2, Spaze I-Tech Park, 544, Sector 49, Gurugram, Haryana 122018 (“PPI”, “we”, “us” or “our”).

This Privacy Notice is the “Privacy Notice” referred to in the NRPN Terms and Conditions of Participation (the “Terms”), and forms part of them. It is made available on the Registration Page before any Personal Data is collected.

Definitions and scope

1.1 Definitions. In this Privacy Notice, unless the context otherwise requires:

• “Data Protection Law” means the law governing the processing of Personal Data in force from time to time, being, until the relevant provisions of the Digital Personal Data Protection Act, 2023 commence, Section 43A of the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and thereafter the Digital Personal Data Protection Act, 2023 and the rules made under it.
• “Personal Data” has the meaning given to it in the Terms, being the meaning given to it under the Data Protection Law.
• “Sensitive Personal Data” means sensitive personal data or information as defined under the Data Protection Law, including information relating to physical, physiological and mental health condition, and medical records and history.
• “you” and “your” refer to a Participant, a person who registers on behalf of a Participant, and any individual whose Personal Data is provided to us in connection with NRPN.

1.2 Terms. Capitalised terms used but not defined in this Privacy Notice have the meanings given to them in the Terms.

1.3 Scope. This Privacy Notice applies to Personal Data processed by PPI in connection with any Registration for, and participation in, a Workshop. It does not apply to any website, platform or service operated by a third party, including the payment gateway through which the Fee is paid, which is governed by that third party’s own privacy policy.

Personal Data we collect

2.1 Registration. When you register, we collect your name, email address, mobile number and city and, where a Registering Entity registers or pays, the name, address and GSTIN of the Registering Entity and the name and contact details of the person registering.

2.2 Payment. Payments are processed by third-party payment gateways. We receive confirmation of payment, the amount paid, the transaction reference and the payment mode. We do not collect or store card numbers, bank account credentials or UPI credentials.

2.3 Acceptance records. We record each acceptance of the Terms under Clause 3.1 and Clause 3.3 of the Terms, including your identity and contact details, the date and time of acceptance, the effective date of the Terms accepted, your signature or digital confirmation at the registration desk, and such technical identifiers as are reasonably available.

2.4 Attendance records. At the Workshop, we record your attendance at the start of each day and after each scheduled break, the times at which you leave or re-enter a session room, and any reminder given to you under Clause 9.2(b) of the Terms.

2.5 Onboarding Form. Where we issue an Onboarding Form, we collect the information you choose to provide about your business, professional background, objectives and networking practices. Questions marked optional need not be answered.

2.6 Emergency and accessibility information. We collect the name and contact details of an emergency contact, and any accessibility requirement that you choose to notify to us under Clause 14.7 of the Terms. Where any information you provide relates to your health, it is Sensitive Personal Data and is dealt with under Clause 4.3.

2.7 Photographs, recordings and Testimonials. We photograph and film each Workshop, and record sessions for internal records, as described in Clause 16.3 and Clause 18 of the Terms. We also collect any Testimonial you give or record for us under Clause 19.8 of the Terms.

2.8 Communications and grievances. We keep records of emails, messages and calls between you and PPI, and of any complaint made to the Grievance Officer and its outcome.

2.9 Technical data. When you visit the Registration Page or any website of PPI, limited technical data such as your IP address, device and browser type and pages visited may be collected through cookies and similar technologies, for the operation, security and improvement of that page.

2.10 Information about others. Where you provide the Personal Data of another person, including an emergency contact, a Transferee or an employee registered by a Registering Entity, you confirm that you are entitled to provide it and that you have informed that person of this Privacy Notice.

Personal Data we do not collect

3.1 What we do not collect. In particular:

• we do not collect information about food allergies, intolerances or dietary requirements, as stated in Clause 14.3 of the Terms;
• we do not photograph, film or record any Personal Disclosure, as stated in Clause 15.5 of the Terms, and we do not keep any written record of what a Participant shares in an exercise;
• we do not collect or store payment card, bank account or UPI credentials; and
• we do not knowingly collect Personal Data of any person below eighteen (18) years of age.

Purposes and consent

4.1 Purposes. We process your Personal Data only for the following purposes:

• to process and confirm your Registration, issue invoices and administer the Workshop and the Inclusions;
• to communicate with you about your Registration and the Workshop;
• to tailor the delivery of the Workshop on the basis of the Onboarding Form;
• to maintain records of acceptance and attendance, and to administer the Day One Guarantee, Transfers and Carry-Forwards;
• to ensure the safety of Participants, and to respond to any medical emergency or risk of harm under Clause 14.5 and Clause 15.9 of the Terms;
• to send you information about other programmes and services of PPI, including the Masters Networkers Programme, under Clause 16.3(a) of the Terms;
• to use photographs and recordings of the Workshop, and Testimonials, in promotional material under Clause 16.3(b) and Clause 19.8 of the Terms;
• to maintain internal records of sessions under Clause 18.2 of the Terms;
• to handle grievances, prevent misconduct and enforce the Terms; and
• to comply with law, and to establish, exercise or defend legal claims.

4.2 Consent. By selecting the Acceptance Checkbox, or otherwise accepting the Terms, you confirm that you have read this Privacy Notice and consent to the processing of your Personal Data for the purposes in Clause 4.1. Providing Personal Data marked as mandatory is necessary for Registration. Where you do not provide it, we may be unable to complete your Registration.

4.3 Sensitive Personal Data. Any health or accessibility information is provided by you voluntarily. By providing it, you give your express consent in writing, including by email or through a form, to its use only for the purpose for which you provided it and to its disclosure to the Venue Operator or medical personnel to the extent necessary for that purpose.

4.4 Marketing. You may stop receiving communications under Clause 4.1(f) at any time by using the unsubscribe or opt-out option provided in that communication. We shall give effect to your request within seven (7) Business Days. Opting out does not affect your Registration, or communications relating to your Registration or the Workshop.

4.5 Withdrawal of consent. You may withdraw your consent to the processing of your Personal Data by writing to the Grievance Officer. Withdrawal does not affect processing carried out before withdrawal, or processing that we are required or permitted by law to continue. Where processing is necessary for your Registration or the Workshop, withdrawal before the conclusion of the Workshop shall be treated as a cancellation by you under Clause 10 of the Terms.

Sharing of Personal Data

5.1 No sale. We do not sell your Personal Data. We do not share your Personal Data, or any list of Participants, with any person for that person’s own marketing.

5.2 Persons with whom we share Personal Data. We share Personal Data only to the extent necessary for the purposes in Clause 4.1, with:

• payment gateways and banks, to process payments, refunds and payment disputes;
• the Venue Operator, for access, security and the matters described in Clause 14 of the Terms;
• Facilitators, to the extent necessary to conduct sessions, subject to the confidentiality obligations in Clause 15.2 of the Terms;
• service providers who act on our behalf, including providers of email, messaging, customer relationship management, cloud storage, photography and videography services, under contracts that require them to protect it;
• our professional advisers, including lawyers and accountants;
• a Participant affected by a breach of Clause 15 of the Terms, to the extent permitted by law under Clause 15.7 of the Terms;
• a Participant’s emergency contact, medical personnel or a competent authority, where Clause 15.9 of the Terms applies;
• any court, tribunal, regulator, police or other authority, where required by law or for the establishment, exercise or defence of legal claims; and
• any successor to the business of conducting NRPN, subject to this Privacy Notice.

5.3 Participant groups. Where you join a messaging or online group under Clause 17 of the Terms, your name, telephone number and any content you post will be visible to the other members. This visibility results from your own decision to join, and PPI does not control the use of such information by other members.

Storage, transfer and security

6.1 Storage and transfer. Personal Data may be stored on servers operated by PPI’s service providers, which may be located in or outside India. Any transfer of Personal Data outside India shall be made only as permitted by the Data Protection Law.

6.2 Security. We implement reasonable security practices and procedures, including access controls, to protect Personal Data against unauthorised access, use, alteration and disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

6.3 Breach. In the event of a personal data breach, we shall take reasonable steps to contain it, and shall notify affected persons and the competent authorities, including the Indian Computer Emergency Response Team where applicable, within the time and in the manner required by Applicable Law.

Retention

7.1 Retention periods. We retain Personal Data only for as long as necessary for the purpose for which it was collected, as follows:

• registration, acceptance and attendance records: for three (3) years after the conclusion of the last Workshop attended by you;
• invoices, payment and accounting records: for the period required under the Central Goods and Services Tax Act, 2017, the Income-tax Act and other applicable laws;
• Onboarding Form responses: for two (2) years after the conclusion of the Workshop;
• emergency contact and health or accessibility information: for thirty (30) days after the conclusion of the Workshop;
• internal records of sessions under Clause 18.2 of the Terms: for twelve (12) months after the conclusion of the Workshop;
• photographs and recordings used in promotional material: for the period stated in Clause 16.3(b) of the Terms, and Testimonials: for so long as they are used under Clause 19.8 of the Terms;
• contact details used for marketing: until you opt out, after which we retain only the minimum information necessary to ensure that you are not contacted again; and
• grievance records: for three (3) years after the grievance is closed.

7.2 Longer retention. We may retain Personal Data for longer than the periods in Clause 7.1 where required by law, or where it is reasonably necessary for a pending or anticipated legal claim, investigation or dispute, until that matter is concluded.

7.3 Deletion. At the end of the applicable period, Personal Data shall be erased or anonymised, save that material already published before that time is not required to be recalled.

Your rights

8.1 Rights. Subject to the Data Protection Law in force at the relevant time, you may:

• obtain a summary of the Personal Data we process about you and the persons with whom it has been shared;
• review your Personal Data and request its correction, completion or updating;
• request the erasure of Personal Data that is no longer necessary for the purpose for which it was collected, subject to Clause 7;
• withdraw your consent under Clause 4.5;
• nominate another individual to exercise your rights in the event of your death or incapacity; and
• have your grievance redressed by the Grievance Officer and, after doing so, approach the Data Protection Board of India or any other competent authority.

8.2 Exercising rights. You may exercise these rights by writing to the Grievance Officer from the email address registered with PPI. We may ask you to verify your identity before acting on a request.

General

10.1 Changes to this Privacy Notice. We may update this Privacy Notice from time to time. Each update shall carry a new effective date and shall be published on the Registration Page and on PPI’s website. Where an update materially affects the processing of Personal Data already collected, we shall notify you by email.

10.2 Conflict. In the event of any conflict between this Privacy Notice and the Terms in relation to the processing of Personal Data, this Privacy Notice shall prevail, as provided in Clause 2.4 of the Terms.

10.3 Governing law. This Privacy Notice shall be governed by the laws of India, and Clause 26 of the Terms shall apply to any dispute arising from it.

10.4 Contact. For general queries about NRPN, you may write to support@paritoshpathak.com. For any matter relating to your Personal Data, please write to the Grievance Officer.