1. Introduction

Wartens Automation Pvt Ltd (Brand: EDWartens India), with its registered office at NVR Complex, GS Palya Road, Electronic City, Bangalore, Karnataka 560100 ("Company," "we," "us," or "our"), is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit our website edwartens.co.in, enroll in our programs, or interact with us in any capacity. This policy applies to all students, prospective students, website visitors, and any other individuals whose data we process.

We act as the "Data Fiduciary" (as defined under the DPDP Act, 2023) and the "Data Controller" (as defined under the GDPR) for the personal data described in this policy.

2. Data We Collect

We may collect the following categories of personal data:

2.1 Information You Provide

Full name, date of birth, and gender
Email address, phone number, and postal address
Educational qualifications, college/university name, and academic transcripts
Government-issued identification (Aadhaar, PAN, passport) for verification purposes
Photographs and video recordings taken during the program
Payment information (processed through secure third-party gateways)
Resume/CV and professional details submitted for placement assistance
Assessment results and program performance data
Communication records (emails, chat messages, phone call summaries)

2.2 Information Collected Automatically

IP address and approximate geolocation
Browser type, device type, and operating system
Pages visited, time spent on pages, and navigation patterns
Referral source and search terms used to find our website
Cookie identifiers and tracking data (see Section 8)

2.3 Information from Third Parties

Information from educational institutions for verification of qualifications
Information from placement partner companies regarding interview outcomes
Publicly available information from professional networking platforms

3. Purpose of Data Collection

We collect and process your personal data for the following purposes:

Enrollment & Program Administration: To process your application, verify eligibility, manage enrollment, and administer the program.
Placement Assistance: To share your profile, resume, and relevant details with potential employers and placement partner companies.
Certification: To issue your certificates and let anyone you give the certificate code to verify them.
Communication: To send you program updates, schedules, placement opportunities, and important notices.
Marketing: To send promotional materials, newsletters, and information about new programs (with your consent).
Website Improvement: To analyze usage patterns and improve our website, services, and user experience.
Legal Compliance: To comply with applicable laws, regulations, and legal processes.
Quality Assurance: To monitor and improve the quality of our programs and services.

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

Consent: Where you have provided explicit consent for specific processing activities (e.g., marketing communications).
Contractual Necessity: Where processing is necessary to perform our obligations under the enrollment agreement (e.g., program administration, placement assistance).
Legitimate Interest: Where processing is necessary for our legitimate business interests (e.g., improving services, preventing fraud), provided these interests do not override your rights.
Legal Obligation: Where processing is necessary to comply with applicable laws and regulations.

6. Data Retention

We retain your personal data for the following periods:

Student Records: For a period of 7 years from the date of program completion or last interaction, whichever is later.
Placement Records: For a period of 5 years from the date of placement.
Financial Records: For a period of 8 years as required by applicable tax and accounting regulations.
Website Analytics Data: For a period of 26 months.
Marketing Data: Until you withdraw your consent or unsubscribe.

After the retention period expires, your data will be securely deleted or anonymized.

7. Your Rights

Under the GDPR and the Indian DPDP Act 2023, you have the following rights regarding your personal data:

Right of Access: You have the right to request a copy of the personal data we hold about you.
Right to Correction: You have the right to request correction of inaccurate or incomplete personal data.
Right to Erasure: You have the right to request deletion of your personal data, subject to legal retention requirements.
Right to Restrict Processing: You have the right to request restriction of processing of your personal data in certain circumstances.
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format.
Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing.
Right to Nominate: Under the DPDP Act, you have the right to nominate another person to exercise your rights in the event of your death or incapacity.
Right to Grievance Redressal: You have the right to file a complaint with the Data Protection Board of India or the relevant supervisory authority.

To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 14 below.

8. Cookies & Tracking

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and personalize content. For detailed information about the cookies we use and how to manage your cookie preferences, please refer to our Cookie Policy.

9. Third-Party Services

We use the following third-party services that may collect or process your data:

Google Analytics: Website traffic analysis and user behavior tracking.
Google Tag Manager: Management of website tracking tags.
Razorpay: Secure payment processing for enrollment fees.
Stripe: Payment processing for learners outside India who pay in US dollars; the seller for those payments is Wartens Ltd (UK).
AI providers: Groq, Cerebras, NVIDIA (NIM), GitHub Models (Microsoft), Mistral, Google (Gemini) and OpenRouter, only for text you enter in an AI tool, a CV you upload or the course advisor chat. Anything carrying your personal details (a CV, résumé, cover letter or your profile) is sent only to providers that do not use what they are sent to train their models (Groq, Cerebras, NVIDIA and GitHub Models). A CV you upload to build your personal plan is read in memory and the file is not stored. The course advisor, which talks about the course catalogue, may also use Mistral, Google Gemini and OpenRouter, whose free tiers may use prompts to improve their models, so please do not type personal details into it.
Meta Pixel (Facebook): Advertising measurement and optimization.
LinkedIn Insight Tag: Advertising measurement and website demographics.
WhatsApp Business API: Customer communication and support.
Google Workspace: Email communication and document management.

Each of these services has its own privacy policy governing the use of your data. We encourage you to review these policies.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

SSL/TLS encryption for data in transit
Encrypted storage for sensitive data at rest
Access controls and role-based permissions
Regular security audits and vulnerability assessments
Employee training on data protection and privacy

While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security.

11. Children's Privacy

You must be 16 or over to create an account. If you are 16 or 17, you need a parent's or guardian's consent, which you confirm when you sign up. We do not knowingly collect personal data from anyone under 16. If we become aware that we have, we will delete it promptly.

12. International Data Transfers

As part of our operations, your personal data may be transferred to and processed in countries outside of India, including the United Kingdom (Wartens Ltd, our UK group company, which runs the platform with us and sells certificates outside India). Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws, including:

Standard Contractual Clauses (SCCs) approved by the European Commission
Adequacy decisions by the relevant data protection authority
Other legally recognized transfer mechanisms

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this policy periodically. Continued use of our services after changes constitutes acceptance of the updated policy.

Your Rights Under DPDPA 2023 (India)

Under the Digital Personal Data Protection Act 2023 (India), you have the right to:

Access your personal data held by us
Correct inaccurate personal data
Withdraw consent for data processing at any time
Request erasure of your personal data

To exercise these rights, email info@wartens.com with subject line: "Data Rights Request"

Data Breach Notification

In the event of a personal data breach, we will notify the Data Protection Board of India and affected individuals within 72 hours of becoming aware of the breach.

Orders, Payments, Cart & Site Analytics

Orders and receipts. When you take a free course or buy a certificate we create an order record with your name, email, phone, the items, the amount and the receipt number, and we email you the receipt. Order and receipt records are kept for eight years to meet the Income-tax Act and GST record-keeping requirements, even if you delete your account.

Payments. Card, UPI and net-banking payments are processed by Razorpay Software Private Limited under its own privacy policy. We receive the payment reference, amount and status; we never receive or store your card number, CVV or banking password.

Your cart. The cart, saved-for-later list and any discount code you type are stored in your browser's local storage on this device only, until you place the order or clear them. They are not sent to us until you check out.

Learning records. We record which modules you complete, quiz and assessment attempts and scores, certificates issued, reviews you publish (under the display name you choose) and, if you are signed in, the pages of the Website and portal you open. This is used to run your portal, issue certificates, show your progress to our staff who support you, and understand how the free courses are used.

First-party analytics. Page views on the public site are counted by our own server without third-party trackers. For visitors who are not signed in we store the page, the referring site, the device type and a visitor key that is a one-way hash of your address and browser salted with a value that changes every day, so it cannot follow you across days. If you are signed in, the pages you open are recorded against your account (see Learning records above), and views earlier the same day from the same browser may be linked to it too. No IP address is stored. Cookie-based analytics, where enabled, are described in the Cookie Policy.

Course creators. Video lessons in free courses play from YouTube. When a lesson loads, YouTube (Google) receives the technical data its embedded player normally collects, under Google's privacy policy; we use the privacy-enhanced embed, which does not set tracking cookies until you press play.

Grievance

If you have a complaint about how we handle your data, contact our Grievance Officer at info@wartens.com. Unresolved complaints may be escalated to the Data Protection Board of India.

14. Contact & Data Protection Officer

For any questions, requests, or complaints regarding this Privacy Policy or our data practices, please contact:

Data Protection Officer

Wartens Automation Pvt Ltd

NVR Complex, GS Palya Road, Electronic City, Bangalore, Karnataka 560100

Email: info@wartens.com

Phone: +91 96 06 86 86 86

You also have the right to lodge a complaint with the Data Protection Board of India or the relevant supervisory authority in your jurisdiction.

Privacy Policy

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