We, 10MS Limited, incorporated under the Bangladeshi Companies Act (Act XVIII), of 1994 (hereinafter referred to as “Company” or “10MS”), with the incorporation number C162578 / 2020, is committed to safeguarding your privacy in relation to the protection of your personal information. The Services are governed by this Policy, and any other rules, policies or guidelines published on the Platform as applicable to you.
Please read this Policy carefully prior to accessing our Platform and using the Services. By accessing and using the Platform, providing your Personal Information (defined below), or by otherwise signaling your agreement when the option is presented to you, you consent to the collection, use, disclosure, sharing and storing of information described in this Policy, Terms of Service and any other rules, policies or guidelines published on the Platform as applicable to you (collectively referred to as the “Platform Terms”), and 10MS disclaims all the liabilities arising therefrom. If you have inadvertently submitted any Personal Information to 10MS prior to reading this Policy statements set out herein, or you do not agree with the way your Personal Information is collected, stored, or used, then you may access, modify and/or delete your Personal Information in accordance with this Policy.
If any information you have provided or uploaded on the Platform violates the Platform Terms, 10MS may be required to delete such information upon informing you of the same and revoke your access to the Platform if required. If you have any questions about this Policy, please contact us [email protected].
10MS is the controller of Personal Information that it collects and processes in connection with the use of the Platform and the provision of the Services on the Platform. The kind of Personal Information we collect in connection with such use is detailed below.
C. Personal Information
“Personal Information” shall mean the information which identifies a User i.e., first and last name, identification number, email address, age, gender, location, photograph and/or phone number provided at the time of registration or any time thereafter on the Platform.
We request you to not provide 10MS with any Personal Information unless specifically requested by us. In the event you share with 10MS any Personal Information without us having specifically requested for the same, then we bear no liability in respect of such Personal Information provided by you.
D. Information We Collect
We only collect information about you if we have a reason to do so — for example, to provide our Services on the Platform, to communicate with you, or to make our Services better.
We collect this information from the following sources:
Information we collect from You:
Basic account information: In order to access certain features of the Platform, you will need to create an account and register with us. We ask for basic information which may include your name, an email address, state of residence, and password, along with a username and phone/mobile number.
Information you choose to provide: When you complete your profile within the Platform, you may choose to provide your profile photo, name of your current educational institution and current grade. We explicitly ask for your device camera permission if and when you want to update your profile picture. This is not mandatory. This information is not visible to anyone on or off the Platform.
Information when you communicate with us: When you write to us with a question or to ask for help, we will keep that correspondence, and the email address, for future reference; this may also include any phone/ mobile numbers if you have provided us the same as part of your communication either in writing (emails included), over a phone call or otherwise. When you browse pages on our Platform, we will track that for statistical purposes which may be to improve the Platform and the Services. You may also provide us your Personal Information or other information when you respond to surveys, enter any form of contests, tests, events, competitions, webinars, etc., hosted by 10MS, either on the Platform or otherwise, or when you otherwise communicate with us via form, e-form, email, phone, or otherwise, we store a copy of our communications (including any call recordings or emails, if any, as permitted by applicable law). When you use our paid doubt solving feature, we explicitly ask for your device camera permission so that you can share any associated image with us.
Information related to location: You may also choose to provide location related information, including but not limited to access to GPS, which will enable us, with your consent, to offer customized offerings for specific services where location data is relevant and/or applicable such as informing you whether services on the Platform that you have expressed interest in may be availed of at or near your location.
Information we collect automatically:
Device and Log information: When you access our Platform, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Platform — for example, when you create or make changes to your account information on the Platform.
Usage information: We collect information about your usage of our Platform. We also collect information about what happens when you use our Platform (e.g., page views, support document searches, features enabled for your account, interactions with other parts of our Services) along with information about your Supported Device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to provide our Platform to you, get insights on how people use our Platform so that we can make our Platform better, and understand and make predictions about User retention.
Location information: We may determine the approximate location of your Supported Device from your Internet Protocol (IP) address. We may collect and use this information to calculate how many people visit from certain geographic regions or to improve our Platform Services.
Information we collect from other sources:
We might receive and collect information about you from other sources in the course of their services to us or from publicly available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from a social media site or a Google service if you connect to the Services through that site or if you use the Google sign-in.
E. Basis of Collection and Processing of Your Personal Information
Basis for collection:
We collect and process your Personal Information based on the following legal parameters depending upon the nature of Personal Information and the purposes for which it is processed:
Consent: We rely on your consent to process your Personal Information in certain situations. If we require your consent to collect and process certain Personal Information, as per the requirements under the applicable Data Protection Laws, your consent is sought at the time of collection of your Personal Information and such processing will be performed where consent is secured.
Compliance with a legal obligation: Your Personal Information may be processed by us, to the extent that such processing is necessary to comply with a legal obligation.
Processing of your Personal Information:
We may process your Personal Information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
Because it is necessary to perform the Services you have requested or to comply with your instructions or other contractual obligations between you and us;
To comply with our legal obligations as well as to keep records of our compliance processes;
Because our legitimate interests, or those of a third-party recipient of your Personal Information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
Because you have chosen to publish or display your Personal Information on a public area of the Platform, such as a comment area;
Because it is necessary to protect your vital interests;
Because it is necessary in the public interest; or
Because you have expressly given us your consent to process your Personal Information in a particular manner.
We do not use Personal Information for making any automated decisions affecting or creating profiles other than what is described in this Policy.
Where the processing of your Personal Information is based on your consent, you have the right to withdraw your consent at any point in time in accordance with this Policy. Please note that should the withdrawal of consent result in us not being able to continue offering our Services to you, we reserve the right to withdraw or cease from offering our Services to you upon your consent withdrawal. You may withdraw consent by contacting us with a written request to the contact details provided in the ‘Grievances’ section below. Upon receipt of your request to withdraw your consent, the consequences of withdrawal may be communicated to you. Upon your agreement to the same, your request for withdrawal will be processed.
F. How we Use and Share the Information Collected
We use/process your information in the following manner:
To provide Services on our Platform: We use your information as collected by us to allow you to access the Platform and the Services offered therein, including without limitation to set-up and maintain your account, provide customer service, fulfill purchases through the Platform, verify User information and to resolve any glitches with our Platform. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us.
To improve our Platform and maintain safety: We use your information to improve and customize the Platform and Services offered by us, including providing automatic updates to newer versions of our Platform and creating new features based on the Platform usage analysis. Further, we also use your information to prevent, detect, investigate, and take measures against criminal activity, fraud, misuse of or damage to our Platform or network, and other threats and violations to 10MS’s or a third party's rights and property, or the safety of 10MS, its users, or others. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us.
To market our Platform and communicate with You: We will use your information to develop a more targeted marketing of our Platform, to communicate with you about our offers, new products, services or even receive your feedback on the Platform. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Platform, and/or the performance of a contract between you and us.
To establish, exercise, or defend legal claims: We may process any Personal Information identified in this Policy when necessary for establishing, exercising, or defending legal claims, whether in court, administrative, or other proceedings. The legal basis for this processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
To manage risk and obtain professional advice:We may process any of the Personal Information identified in this Policy to manage risk or obtain professional advice. The legal basis for this processing is our legitimate interest in the proper protection of our business and Platform
Consent:We may otherwise use your information with your consent or at your direction.
To Better Understand Our Users:We may use information we gather to determine which areas of the Services are most frequently visited to understand how to enhance the Services.
We share the information collected as per terms of this Policy only in the manner specified hereinbelow. We do not sell or otherwise disclose Personal Information we collect about you for monetary or other valuable consideration. Further, only authorized representatives of 10MS and on a need-to-know basis use any information received from you and as consented by you. In the event of any identified unauthorized use or disclosure of information or upon your complaint as stated under the ‘Grievances’ section below, we will investigate any such complaint and take the appropriate action as per the applicable Data Protection Laws.
Legal Disclosures: We may disclose information about you in response to a court order, or other governmental request. Without limitation to the foregoing, we reserve the right to disclose such information where we believe in good faith that such disclosure is necessary to:
comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests;
protect and defend 10MS’s or a third party's rights and property, or the safety of 10MS, our users, our employees, or others; or
prevent, detect, investigate and take measures against criminal activity, fraud and misuse or unauthorized use of our Platform and/or to enforce our Terms and Conditions or other agreements or policies.
To the extent permitted by law, we will attempt to give you prior notice before disclosing your information in response to such a request.
Advertising and Analytics Partners:We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies.
With Your Consent:We may share and disclose information with your consent or at your direction.
Your information may be shared for reasons not described in this Policy, however, we will seek your consent before we do the same or share information upon your direction.
G. Duration for which your Information is Stored
Mostly, when you delete any of the information provided by you or when you delete your account, on the Platform, the same will be deleted from our servers too. However, in certain cases, we will retain your information for as long as it is required for us to retain for the purposes stated hereinabove, including for the purpose of complying with legal obligation or business compliances.
Further, please note that we may not be able to delete all communications or photos, files, or other documents publicly made available by you on the Platform (for example: comments, feedback, etc.), however, we shall anonymize your Personal Information in such a way that you can no longer be identified as an individual in association with such information made available by you on the Platform. We will never disclose aggregated or de-identified information in a manner that could identify you as an individual.
Note: If you wish to exercise any of your rights (as specified in ‘Your Rights’ section below) to access, modify and delete any or all information stored about you, then you may do so by using the options provided within the Platform. You can always write to us [email protected] for any clarifications needed.
H. Your Choices
Limit the information You provide: You always have an option to choose the information you provide to us, including the option to update or delete your information. However, please note that lack of certain information may not allow you the access to the Platform or any of its features, in part or in full.
Limit the communications You receive from us: Further, you will also have the option to choose what kind of communication you would like to receive from us and whether you would like to receive such communication at all or not. However, there may be certain communications that are required for legal or security purposes, including changes to various legal agreements, that you may not be able to limit.
Reject Cookies and other similar technologies: You may reject or remove cookies from your web browser; you will always have the option to change the default settings on your web browser if the same is set to ‘accept cookies’. However, please note that some Services offered on the Platform may not function or be available to you, when the cookies are rejected, removed, or disabled.
I. Information Security
We work to protect the security of your information during transmission by using Transport Layer Security (TLS) or Secure Sockets Layer (SSL) software (depending on your browser/Supported Device), which encrypts information you input in addition to maintaining security of your information as required under applicable laws.
We maintain electronic, and procedural safeguards in connection with the collection, storage, and disclosure of Personal Information (including Sensitive Personal Information). Our security procedures mean that we may occasionally request proof of identity before we disclose Personal Information to you that belongs to you.
However, no form or method of data storage or transmission system is fully secure, and we cannot guarantee that security provided by such system(s) is absolute and that your information will not be accessed, disclosed, or destroyed in the event of a breach of any of our security measures.
It is important for you to protect your account against unauthorized access to or use of your password and to your computer and if you have any reason to believe that your password has become known to anyone else, or if the password is being, or is likely to be, used in an unauthorized manner, you must immediately change your password or inform us, so that we are able to help you stop or prevent such unauthorized access. Be sure to sign off when you finish using a shared computer.
J. Promotional Communications
You will always have the option to opt out of receiving some or all of our promotional communications by using the unsubscribe link in any email communications sent to you or by emailing [email protected].
If you opt out of promotional communications, we may still send you transactional communications, such as service announcements, administrative and legal notices, and information about your account, without offering you the opportunity to opt out of these communications. If you no longer wish to use our Platform or receive any communications from us (except for those that are legally required), then you may delete your account by using the option enabled within the Platform or by writing to us at [email protected].
Please note that opting out of promotional email communications only affects future communications from us. If we have already provided your information to a third party (as stated in this Policy) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party.
We do not sell your Personal Information to third parties, and we do not use your name or name of your company in marketing statements without your consent.
K. Interest-Based Ads
On unaffiliated sites, 10MS may display interest-based advertising using information you make available to us when you interact with our Platform and Services. Interest-based ads, also sometimes referred to as personalised or targeted ads, are displayed to you based on information from activities such as registering with our Platform, visiting sites that contain 10MS content or ads. We do not provide any Personal Information to advertisers or to third party sites that display our interest-based ads. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalised ad or content are part of the group that the ad or content is directed towards. Also, some third-parties may provide us information about you (such as the sites where you have been shown ads or demographic information) from offline and online sources that we may use to provide you more relevant and useful advertising.
Our business changes constantly and our Policy may change from time to time. We may, at our discretion (unless required by applicable laws to mandatorily do so), email periodic reminders of our notices and conditions, unless you have instructed us not to, but we encourage you to check our Platform frequently to see the recent changes. Unless stated otherwise, our current Policy applies to all information that we have about you and your account. We stand behind the promises we make, however, and will not materially change our policies and practices making them less protective of customer information collected in the past without your consent.
M. Privacy Grievances
If you have any questions about this Policy, wish to exercise your rights, have concerns about privacy of your data or any privacy related grievances in respect of the Platform, then please register your complaint with a thorough description via email to [email protected] or call our hotline at 16910.
Last updated on 3rd April, 2023