Effective: May 18, 2022.
- Commward is the data controller of your personal information.
- Purpose and who we are
- What You Agree to by Using Our Site
- What Information We Collect
- How We Use the Information
- External Links
- Retention of Personally Identifiable Information
- Confidentiality and Security of Your Personally Identifiable Information
- Updating or Deleting Your Personally Identifiable Information
- Questions, Suggestions, and Complaints
- California Privacy Rights
- International Privacy Practices
- No Information From Children Under 13
Purpose and who we are
“Personally Identifiable Information” (i.e., information that can be used to identify you). Personally Identifiable Information can include information such as your name and email address, among other things. If you reside or are located in the EEA, it can also include your IP address or device identifier. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Commward. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
What You Agree to by Using Our Site
- our use of your personal information is necessary for complying with our legal obligations; or
- where neither of the above apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our Site and provide our services;
- select appropriately skilled and qualified suppliers;
- build relationships with partners and academic institutions;
- carry out research and statistical analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent or delete your account and we will stop doing so. However, if you withdraw your consent, this may impact our ability for us to be able to provide our services to you.
What Information We Collect
We gather two types of information about users through the Site:
- Information relating to your use of our Site. When users come to our Site, we may track, collect and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.
- Personally Identifiable Information provided directly by you or via third parties. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates or Online Courses, participate in our public forums, send us email messages, and/or participate in Online Courses or other services on our Site. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific course and/or services you select, send you updates about Online Courses offered by Commward or other Commward events, and send you email messages about Site maintenance or updates.
- Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name and email address.
- Updates. Commward may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name and email address.
- Participation in Online Courses. Commward offers users the opportunity to participate in an Online Course on or through the Site. If you desire to participate in a course, you will be asked to provide us with certain information necessary to conduct such a course. This information may include, among other things, your name and email address.
If you participate in an online course, we may collect from you certain student-generated content, such as assignments you submit to instructors, peer-graded assignments, and peer grading student feedback. We also collect course data, such as student responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate or submit such assignments, exams, or surveys.
- Identity Verification. Commward may offer you the ability to verify your identity for selected classes. In order to enroll for these services, you may be required to provide us or our third-party identity verification vendor with Personally Identifiable Information such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document. Additionally, if you apply for financial aid in connection with these services, you may be required to provide information regarding your income.
- Communications with Commward. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
- Third Party Sites. We may receive Personally Identifiable Information when you access or log-in to a third party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.
- Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us. This may include details about your race, your education history, and your employment.
- Partner sites. Partner sites providing Online Course related tools and services to Commward users may collect nonfinancial individual level user data regarding the individual’s use of that partner site while engaged with such Online Course related activities, and the partner sites may share that data with Commward for the purpose of improving Commward’s services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.
- Third Party Credit Card Processing. Commward provides you with the ability to pay for Online Courses and other services using a credit card through a third party payment processing service provider. Please note that our service provider – not Commward – collects and processes your credit card information.
How We Use the Information
- Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our services and the Site.
- Providing the Site and our services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or services that you request from us.
- Technical support and security. We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of our services and the Site.
- Updates. We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Site or an Online Course. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Forums. You should not post any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post Personally Identifiable Information, such Personally Identifiable Information may be collected during your use of the Forums. We may publish this information via extensions of our Platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain Personally Identifiable Information in future versions of the courses we offer, and to enhance future course offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the University partner, business partner, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using Personally Identification Information.
- Participation in Online Courses. We use the Personally Identifiable Information that we collect from you when you participate in an Online Course through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of an Online Course. We may also share your Personally Identifiable Information and your performance in a given Online Course with the instructor or instructors who taught the course, with teaching assistants, or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the course, and with the institution or institutions with which they are affiliated. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Identity Verification. For services that require identity verification, we use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.
- Communications with Commward Business Partners. We may share your Personally Identifiable Information with University partners and other business partners of Commward so that Commward business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.
- Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our business partners so that our business partners may use the data for research related to online education.
- Disclosure to Commward Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Online Course. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.
- Disclosure to Acquirers. Commward may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Commward to which your Personally Identifiable Information relates.
- e-Readers. If we receive any Personally Identifiable Information related to the extent to which you use designated e-Readers to access Commward materials, we may archive it, and use it for research, business, or other purposes.
Retention of Personally Identifiable Information
If you reside or are located in the EEA, we keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
Confidentiality & Security of Personally Identifiable Information
Updating or Deleting Your Personally Identifiable Information
You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site and visiting your user account page.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via [email protected]. If you reside or are located in the EEA, you have the right to request that we:
- provide access to any Personally Identifiable Information we hold about you;
- prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
- update any Personally Identifiable Information which is out of date or incorrect;
- delete any Personally Identifiable Information which we are holding about you;
- restrict the way that we process your Personally Identifiable Information;
- provide your Personally Identifiable Information to a third-party provider of services; or
- provide you with a copy of any Personally Identifiable Information that we hold about you.
We try to answer every email promptly where possible and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation.
When you email us with a request, we may ask that you provide us with the information necessary to confirm your identity.
Questions, Suggestions and Complaints
If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via [email protected].
If you reside or are located in the EEA, our Data Protection Officer and Privacy Team may assist with all queries regarding our processing of Personally Identifiable at [email protected].
If you reside or are located in the EEA, you may also make a complaint to our supervisory body for data protection matters or seek a remedy through local courts if you believe that your rights have been breached.
To contact Commward, please use the following contact info:
Attn: Privacy Request
Apartment No-9/A (Level-9), House No – 30 CWN (A), Road No – 42/43 Gulshan-2, Dhaka-1212
Phone: +880 1712 732 124
Bangladesh Privacy Rights:
The Digital Security Act
Under the Digital Security Act, if any data or information published or propagated in digital media regarding a subject that comes under the purview of the Director General which threatens data security, then the Director General can request the relevant regulatory authority to remove or block said data or information as appropriate.
The Consumers’ Rights Protection Act, 2009
As per Section 52 of the Consumers’ Rights Protection Act, 2009, whoever, in violation of any prohibition under any law for the time being in force, does any act which is detrimental to a service receiver’s life or security, shall be punishable to imprisonment for a period not exceeding three years and/or a fine not exceeding BDT 200,000 (approx. €1,980). Under Section 53, any service provider who by its negligence, irresponsibility, or carelessness damages the service receiver’s finances or health, or causes death, shall be punishable to imprisonment for a period not exceeding three years and/or a fine not exceeding BDT 200,000 (approx. €1,980). In addition, the consumer may be entitled to claim damages.
These provisions implicitly impose responsibility over the person or body corporate that is possessing, dealing, or handling any sensitive personal data or information for the consumer, to implement and maintain reasonable security practices in order to avoid wrongful loss or wrongful gain to the owner of such data.
International Privacy Practices
Commward’s Sites are primarily operated in Bangladesh and managed on servers located within United States of America. In order to provide our products and services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located, including Bangladesh. Accordingly, if you reside or are located outside Bangladesh, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law. We participate in and commit to adhering to the EU-U.S. Privacy Shield Framework when transferring data from the EEA to the United States. Please see our Privacy Shield Policy for further information.
No Information from Children Under 13
Commward strongly believes in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personally Identifiable Information.
Commward is a unique platform for the Bangladeshi Brand to acquire new skills and ideas relevant to the fast-moving industries & entrepreneurship.
©2022 Commward. All rights reserved.