Skip to main content

The NeTT Platform Privacy Policy

The NeTT Platform is the Accessible Learning Management System for the benefit of Students and Teachers of educational projects run by Humana People to People India. The NeTT Platform is an initiative of Humana People to People India (later referred as Humana in this document) - a development organization registered as a not-for-profit company under section 25 of the Companies Act, 1956. Users of The NeTT Platform can access content for learning on the web at https://dmm.humana.school/ and The NeTT Platform mobile application.

The privacy and protection of data of The NeTT Platform’s Users is of utmost importance and shall be ensured at all times. This Privacy Policy shall cover details of data protection and management on The NeTT Platform, including how personal data of users of The NeTT Platform is managed, used and processed. Users are individuals who access and use The NeTT Platform and broadly comprise (i) Students of Teacher Training Schools who access and use The NeTT Platform after registering themselves with Humana (“Registered Users”), (ii) Teachers of Teacher Training school who access and use The NeTT Platform after registering themselves with Humana (“Registered Users”), (iii) Students of other educational projects run by Humana who access and use The NeTT Platform after registering themselves with Humana (“Registered Users”) and (iv) users who are registered with Humana and are authorised to be administrators on behalf of Humana People to People India (“Administrators”). More details on the rights and responsibilities of Registered Users and Administrators are set out in the Term of Use.

By accessing and using The NeTT Platform, and by providing your information with Humana, you consent to the collection and use of the information you disclose on The NeTT Platform by Humana and relevant Administrators of The NeTT Platform in accordance with the policies and guidelines of The NeTT Platform as applicable from time to time, including the Terms of Use and this Privacy Policy. If you do not agree with the contents of this policy, please do not access or use The NeTT Platform.

This Privacy Policy should be read in conjunction with the Terms of Use. Defined terms used but not defined herein shall have the meaning ascribed to them in the Terms of Use.

•   1. Rights of Registered Users:

a.    Right to fair, transparent and lawful collection of your data and information on The NeTT Platform

b.   Right to be informed about the ways in which your data and information that is collected on The NeTT Platform will be understand

c.    Right to receive all the information you need to provide informed consent before collection of your personally identifiable information or sensitive personal data or information on The NeTT Platform and sharing of the same with relevant Administrators

d.   Right to revoke such consent

e.    Right to privacy and confidentiality regarding your personal data and information

f.     Right to proper use of your personal data and information by Administrators for specified and legitimate purposes related to your use of The NeTT Platform

g.   Right to keep your personal information accurate and up to date

h.   Right to secure collection, handling and storage of your personal data and information

i.     Right to protection from unauthorised or unlawful use of your personal data and information

j.     Right to view and access The NeTT Platform’s privacy policy

•   2. Responsibilities of Administrators with respect to Registered User data and information

a.    To respect the privacy and data protection rights of Registered Users

b.   ensure the security of and use of data (especially any personal information) shared by Registered Users is limited solely to the uses and purposes mentioned here

c.    To know that any use of data for purposes outside of the proper use shall be considered violation of the terms of the policies of The NeTT Platform as well as applicable laws and policies of India and they shall be responsible and liable for such actions and for any loss or damage arising from failure to comply with this obligation

d.   To ensure their communication (if any) with Registered Users is explicitly limited and relevant to the purpose of their usage of The NeTT Platform. To ensure that their Content and programs on The NeTT Platform are not used for any of the Prohibited Uses set out in the Terms of Use

•   3. What User data and information is collected on The NeTT Platform?

a.    All Registered Users can expect the following data and information of theirs to be collected by Humana or on The NeTT Platform:

b.   Basic Information: Name, Email Address/Mobile Number, User Type (eg. teacher, student, other) and The NeTT Platform Password

c.    Geographical Information: State and District

d.   The NeTT Platform Usage: Usage history, time spent on Content, Content created/ contributed / published and its usage, progress in trackable collections of Content (eg. courses), scores & assessment results, question-wise answers and other telemetry data in relation to usage of The NeTT Platform, badges generated, certificates issued.

e.    IP Address: The IP address of a User is collected once for the limited purpose of determining your approximate location - the State, City and District of origin. The IP address is not stored in the database of Registered Users and the precise location of any Registered User cannot be determined. The User can confirm or modify the State and District details determined on the basis of the IP address.

f.     No other personally identifiable information or sensitive personal data or information of the Registered User is collected.

g.   All Registered Users (using The NeTT Platform mobile app/website to access The NeTT Platform) have a profile which specifies the User type and Geographical Information and Preferences. They may choose to customise their profile by changing these details at any time as well as providing their name. Only Registered Users can view their profile on both The NeTT Platform mobile app as well as The NeTT Platform web portal, and their profiles specify all the additional information provided by such a Registered User.

h.   Students, Teachers and others as Registered Users: Humana collects the ‘year of birth’ of a Registered User in order to determine whether a User is below 18 years. In the event a person under 18 years of age is registering with Humana, Humana prompts the User to provide the email address or mobile number of a parent / guardian for the purposes of registration. Students under 18 years of age are neither required to nor encouraged to provide their personal information.

i.     You represent to us that the data and information you provide to Humana for registering on The NeTT Platform from time to time is and shall be correct, current and updated and you have all the rights, permissions and consents to provide such data and information. Your providing the information or data and the consequent storage, collection, usage, transfer, access or processing of the same in accordance with the Terms of Use and this Privacy Policy shall not be in violation of any third party agreement, laws, judgments, orders and decrees.

•   4. How is Registered User data and information collected?

a.    Basic Information, Geographical Information and Preferences are collected when a User registers with Humana for the first time. These details can be updated by the User from their profile.

b.   Usage data of Registered Users is collected as and when a Registered User accesses, uses and navigates The NeTT Platform.

c.    The additional information provided by Registered Users, namely, Password, is collected when a Registered User logs in to The NeTT Platform for the first time to update the password created by Humana at the time of registration or when a Registered User updates their profile.

d.   Declared Information of Registered Users is collected with their explicit consent when they choose to provide the same on The NeTT Platform, through their profile or otherwise.

•   5. Who has access to User data and information?

a.    The NeTT Platform Usage data (including Usage across the States and Districts) is a part of anonymised and aggregated data sets that is accessible to relevant Administrators of The NeTT Platform and to the employees, contractors or subcontractors of the technology service providers of The NeTT Platform.

b.   If you are a Registered User, your Basic Information, Geographical Information, Preferences, and Usage data is accessible to the employees, contractors or subcontractors of the technology service providers of The NeTT Platform (under strict confidentiality obligations) if they need to access the data to process it on behalf of Humana or an Administrator or to provide the services available on The NeTT Platform.

c.    Registered Users have an option to explicitly consent to give relevant Administrators access to their Name, Basic Information, Preferences, Usage data, and Declared Information for specified purposes such as implementation of programs on The NeTT Platform like courses. Note that Institutional Users are required to ensure that their respective Administrators comply with and Administrators are responsible to comply with the relevant policies and guidelines of The NeTT Platform as applicable from time to time, including the Terms of Use and this Privacy Policy.

d.   To provide and improve The NeTT Platform, a limited number of third-party services require access to some of your personal data and information, eg. OpenEdx, Google PlayStore, AppStore. Third party services are contractually prohibited from using your information except to provide the service.

e.    Your data and information are only accessible outside of The NeTT Platform when it is necessary to offer the service, comply with law, or with your permission.

•   6. What is User data and information used for?

a.    The NeTT Platform processes your data and information when necessary for providing access to Content for educational purposes and running programs on The NeTT Platform. These purposes are legitimate. The uses of your data are set out below:

b.   To create a profile for you to have a customised experience on The NeTT Platform,

c.    To suggest relevant Content for you to conveniently discover Content based on your preferences, activities on The NeTT Platform, and Content you are viewing on The NeTT Platform;

d.   To enable you to access and use Content on The NeTT Platform;

e.    To enable you to participate in programs run by Institutional Users on The NeTT Platform;

f.     To provide you push notifications on your hand-held devices, only if you have provided permission for the same during app installation;

g.   To track your progress in collections of Content for which progress is tracked / recorded such as courses, points, textbooks;

h.   To generate badges for or issue certificates to you upon completion of milestones;

i.     To maintain records of your progress and certificates/badges in relation to collections of Content you have accessed and used;

j.     To measure interest in the offerings on The NeTT Platform and to improve The NeTT Platform over time;

k.   To track and analyse usage of Content on The NeTT Platform by Administrators and Content providers to improve The NeTT Platform and its offerings over time;

l.     To contact you and deliver information, administrative notices, seek feedback or other communications in connection with your usage of The NeTT Platform. By accepting the Terms of Use including the Privacy Policy, you expressly agree to receive this information;

m. To suggest details for your profile such as your declared State and District;

n.   To resolve disputes, troubleshoot problems, detect and protect you against fraud and other criminal activity, enforce the Terms of Use and any other agreements;

o.   At times multiple users may be looked at to identify problems or resolve disputes, and in particular may examine your information or data to identify users using multiple User IDs or aliases. Your information or data may be compared or reviewed for errors, omissions and for accuracy; and

p.   For any other use that may be described to you at the time of collection.

a.    The technology support providers of The NeTT Platform may use third parties as service providers to facilitate or outsource one or more aspects of service operations that are provided on The NeTT Platform (e.g., search technology, discussion boards, technical service providers, affiliate) and therefore some of your information or data may be provided directly to these service providers. These service providers are subject to confidentiality and other legal restrictions that prohibit their use of the information provided to them for any purpose other than to facilitate specific website related operations.

b.   If we wish to use your data and information for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing, unless authorized by law.

c.    In any event, your data will not be used for any of the following purposes:

a.    Rent or sale or other commercial purposes;

b.   Advertising or marketing;

c.    Phone calls or other forms of unsolicited communication that is not related to your usage of The NeTT Platform;

d.   Building a personal profile, other than for educational purposes on The NeTT Platform;

e.    Any of the Prohibited Purposes set out in the Terms of Use; and

f.     Any purpose that is not disclosed in this policy or on The NeTT Platform.

a.    Administrators are responsible for any use of data and information outside the proper use and shall be held accountable for the violation of the terms and policies of The NeTT Platform, as well as applicable laws and policies of India for any misuse. Administrators shall be liable for such actions and for any loss or damage arising from failure to comply with the obligation of proper use of your data and information. Should you believe that your data or information is being used in a manner inconsistent with this Privacy Policy, please contact The NeTT Platform support team with the details of your concern by sending an email to devops@humana-india.org

b.   As a Registered User, you understand, agree and acknowledge that the collection, storage and processing of your information or data on The NeTT Platform is for a lawful purpose connected with a function or activity of The NeTT Platform. You further understand, agree and acknowledge that your information or data which is classified as personal information as per applicable laws is considered necessary for us to provide various services on and in relation to The NeTT Platform to you and for your usage of The NeTT Platform.

•   7. How is User data and information stored?

a.    Reasonable and appropriate security practices and procedures are being adopted to secure your personal data and information in accordance with Indian laws currently in force, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. These measures include administrative, physical security, and technical controls in order to safeguard your personal data and information.

b.   Your data, including your Declared Information, any personally identifiable information or sensitive personal data or information is securely stored using Amazon AWS cloud services which have its servers in India. Your data and information will primarily be stored in electronic form however certain data may also be stored in physical form.

c.    Third party service providers are engaged to store and process your data. These service providers are contractually bound to follow reasonable security standards to safeguard your data.

d.   Your email address and mobile number and any other personally identifiable information is only collected should you choose to provide the same and it is encrypted and stored securely. Personally identifiable information is only shared with Administrators for purposes specified to you, with your explicit consent and under the obligation that the Administrators will use such information only in connection with your usage of The NeTT Platform.

e.    Your IP address is only collected once for the limited purpose of ascertaining and suggesting your State and District. Your IP address is not stored on The NeTT Platform at any time.

f.     Additionally, a variety of methods such as network and infrastructure security, encryption and manual security procedures are used to secure your information and data against loss or damage and to help protect the accuracy and security of your personal information / general information / usage data and to prevent unauthorized access or improper use. If you think that The NeTT Platform or any of your personal information / general information / usage data is not secure or that there has been unauthorized access to The NeTT Platform account or your personal data, please contact devops@humana-india.org immediately.

g.   Although The NeTT Platform strives to protect your personal information and data, it cannot guarantee the security of your data while it is being transmitted to its site; any transmission is at your own risk. Once your information has been received, reasonable procedures and security features are in place to reasonably endeavour to prevent unauthorized access in accordance with Indian law.

•   8. How long is User data and information stored?

a.    Your data will not be retained for a period more than necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or for directly related legitimate purposes.

•   9. What are the system permissions required by The NeTT Platform?

a.   Microphone - Your system Microphone will be used if voice recording is explicitly requested as part of a Content for the purposes of practice. This voice recording is only stored locally on your system. Your system Microphone will be used if a Registered User creating Content wants to add a voice recording to Content. This voice recording will become part of the Content.

b.    Camera - Your system Camera will only be used if you want to scan QR codes to access Content on The NeTT Platform.

c.   Access to file manager / files - This is used by The NeTT Platform android / iOS applications (as may be applicable) to transfer Content to an external storage space. Additionally, on The NeTT Platform desktop app, this is used to transfer Content to and from an external storage device like a pendrive or SD card.

•   10. Cookies: How are they used? What types of cookies are used? How to manage your cookies?

a.    Only The NeTT Platform web portal uses cookies. The NeTT Platform only uses session cookies, none of the other types of cookies. The NeTT Platform session cookies are used to store URLs in order to better redirect users to the right pages. For example, when a User signs-in to The NeTT Platform from the courses page, they'll need to be redirected back to the courses page at the end of sign-in for a cleaner user experience. Session cookies are also used to store whether to use the Content Delivery Network (CDN) to pull images, plugins and other assets that are shown on the user interface. This is to enable faster loading of the pages the User interacts with. No personal information, or user preferences are stored in cookies.

b.   Registered Users can clear their cookies by going to their browser settings and clearing their browsing data (by specifically checking off the option to clear cookies). Doing so, does not impact their user experience on The NeTT Platform as usage of The NeTT Platform sets the cookies again. Registered Users can also choose to block cookies from the settings as well. Doing so, will mean that certain things on The NeTT Platform will not function properly. For eg., images/plugins may take a long time to load and the user will not be taken to the right pages after login.  

•   11. Data and information Humana is not responsible for

a.    Humana is not responsible for the privacy practices of other websites/plug-ins and registered users need to be aware of the data privacy practices of such sites/plug-ins should they choose to use these links.

•   12. Compliance with laws and law enforcement

a.    The administrators and technology support providers of The NeTT Platform cooperate with governments and law enforcement agencies or any third party by any order under law for the time being in force to enforce and comply with the law. Any information about you will be disclosed to the government or law enforcement officials or private parties as, in the sole discretion of the administrators and technology support providers, if they believe necessary or appropriate to respond to claims and legal process, to protect their property and rights or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity.

b.   Your information or data may also be provided to various tax authorities upon any demand or request from them. You acknowledge that The NeTT Platform can be accessed from anywhere in the world and it will have users from all over the world and therefore governments, judiciaries or law enforcement authorities in various parts of the world may have or assume jurisdiction over The NeTT Platform and The NeTT Platform may be subject to the laws, rules, regulations and judgments of various countries, states, municipalities or provinces where it may not have a direct presence to store, process, collect, use or keep your information or data. You acknowledge that government or law enforcement authorities in the countries where your data or information is stored may have the right to decrypt, collect, monitor or access your data or information, which actions are completely out of the control of the administrators and technology support providers of The NeTT Platform. The administrators and technology support providers of The NeTT Platform do not take any responsibility for such actions.

•   13. Deleting your information

a.   If you wish to have the information or data that you have provided deleted, you can always do so by sending an email request to devops@humana-india.org. You may note that deletion of certain information or data may lead to cancellation of your registration with The NeTT Platform and your access to certain features of The NeTT Platform. You also agree and acknowledge that certain data or information cannot be deleted or may be prohibited to be deleted as required under any applicable law, law enforcement requests or under any judicial proceedings.

•   14. Changes to this Privacy Policy

a.   The NeTT Platform reserves the right to modify this privacy statement at any time, so please review it frequently. If a material change is made to the practices regarding your personally identifiable information, you will be notified, by means of a notice on The NeTT Platform.

•   15. How to contact us?

 If you have any queries, comments, or requests, please contact us by sending an email to devops@humana-india.org.