Privacy Policy

Privacy Policy for LearninGT Website Effective Date: 23 January 2026

1. Introduction

Grant Thornton Bharat LLP ("we", "our", or "us") is committed to valuing your relationship with us and recognizes the importance of respecting and protecting the privacy and security of personal data processed through our LearninGT ("the Website"). This Privacy Policy outlines how we collect, use, disclose, and protect personal data in accordance with the Digital Personal Data Protection Act (DPDPA), 2023, and other applicable standards and laws.

2. Scope

This policy applies to all users of the Website, including employees, administrators, and third-party stakeholders whose data may be processed through the platform (collectively referred to as “you” or “user”). By using the Website, you agree to our use of your information as described herein. The use of this Website, along with all applicable terms and conditions including this statement, shall be governed by the laws of India and subject to the exclusive jurisdiction of the courts in Delhi, India.

3. Definitions

In reference to this policy: “Personal Data” means any data about an individual who is identifiable by or in relation to such data. “Data Fiduciary” means we, the entity which alone or in conjunction with others, determines the purpose and means of processing of Personal Data. “Data Principal” means the individual to whom the Personal Data relates, including but not limited to employees, administrators, and third-party stakeholders using the Website. “Website” means the LearninGT tool, including its mobile Website, platform, portal, software, and related services. “User” means any natural person who registers for or accesses our Website.  

4. Personal Data We Collect

We may collect the following categories of personal data:

• Identification Data: Name, email address, employee ID, job title.
• Contact Data: Phone number, office address.
• Usage Data: Login timestamps, IP addresses, browser type, and activity logs.

5. Purpose of Processing

We process personal data for a range of business, operational, and legal purposes, including but not limited to:

• To deliver, manage, record and monitor compliance activities.
• To fulfill legal and regulatory obligations.
• To improve system performance and security.
• To build, deliver and maintain professional relationships and scope of services and work.

6. Legal Basis for Processing

Under the DPDPA, we rely on:

• Consent: Free, informed, specific, and unambiguous consent from data principals.
• Legitimate Uses: As defined under Section 7 of the Act.
• Legal Obligation: To ensure compliance with applicable laws and regulations.

7. Rights of the Data Principal

We adhere to the Digital Personal Data Act, 2023 (DPDA), which grants the Data Principal (you) specific rights regarding the processing of your Personal Data. These rights include:

• Right to Access Information: To obtain a summary of the Personal Data being processed, the processing activities carried out, and the identities of all other Data Fiduciaries/Data Processors with whom the data has been shared.
• Right to Correction and Erasure: To require the Data Fiduciary to correct inaccurate or misleading Personal Data, complete incomplete Personal Data, update Personal Data, or erase Personal Data when retention is no longer necessary for the specified purpose.
• Right of Grievance Redressal: To have readily available means of grievance redressal provided by the Data Fiduciary.
• Right to Nominate: To nominate an individual who shall exercise your rights in the event of your death or incapacity.
• Right to Withdraw Consent: To withdraw your consent at any time.

Requests can be submitted by contacting our Data Protection Officer at DPOGT@IN.GT.COM

8. Duties of the Data Principal

As a Data Principal, you have the duty and responsibility to:

• Comply with the provisions of all applicable laws while exercising your rights.
• Not register a false or frivolous grievance or complaint with the Data Fiduciary or the Data Protection Board of India.
• Not furnish any false or frivolous information or suppress any material information.
• Furnish information that is verifiably authentic while exercising the right to correction or erasure.

9. Children’s Data

This Website is intended for use exclusively by individuals aged 18 and over. Users are strictly prohibited from submitting any personal data related to individuals under the age of 18. Our services are not designed for or directed at children. We do not knowingly collect or maintain personal data from anyone under the age of 18. In line with our commitment under the Digital Personal Data Protection Act (DPDA), we do not engage in any data processing that could be detrimental to a child's well-being, nor do we conduct tracking, behavioural monitoring, or targeted advertising aimed at children. If it comes to our attention that we have inadvertently collected personal data from an individual under 18, we will promptly take all reasonable measures to delete it.

10. Data Sharing and Transfers

We shall not intentionally disclose your Personal Data to third parties without your permission, subject to the following exceptions:

• We may share data with authorized personnel within your organization and our other network entities or affiliates/related parties of us to fulfill the purposes described in this policy.
• We may disclose your Personal Data to third-party service providers under strict contractual safeguards to support the Website's functionality and our business operations.
• We may disclose your Personal Data to third parties as required or permitted by applicable laws, rules, or regulations.

Cross-border data transfers are conducted in compliance with the DPDPA.

11. Data Retention

We will retain Personal Data for the period necessary to fulfil the business purposes outlined for this Website unless a longer retention period is required or permitted by law.

12. Your Responsibility/Declarations

• You guarantee that the information furnished to us is true, accurate, complete, and up-to-date.
• You are responsible for the truthfulness of all the data communicated and will keep the information updated, so that said information reflects your actual situation.
• You guarantee that you have informed all such persons/parties on whose behalf you may have provided information, where applicable, of the aspects contained in this Privacy Policy. You also guarantee that you have obtained their authorization to provide their information to us for the purposes indicated herein.
• You will be responsible for false or inaccurate information provided through the Website and for damages, whether direct or indirect, that this may cause to us or other users.

 

14. Security Measures

We have implemented generally accepted standards of technology and operational security to protect Personal Data from loss, misuse, alteration, or destruction. Only our authorised personnel are provided access to Personal Data, and such personnels  are required to treat this information as confidential. Our security safeguards includes:

• Role-based access control (RBAC)
• Data encryption (at rest and in transit)
• Regular audits and vulnerability assessments

• Incident response and breach notification protocols breach notification protocols in accordance with DPDPA requirements.

 

15. Cookies and Tracking

A cookie is a small piece of data that is sent from a web server to your web browser and is then stored on your device. When you use our Website, we use cookies to make your experience smoother and more personalised.

• Types of Cookies We Use: The Website uses Essential Cookies required for the Website to function properly (e.g., for authentication, security, and session management). We do not use advertising, targeting, or tracking cookies.
• Managing Your Preferences: Since we only use essential cookies, there are no preferences to manage. Disabling these cookies through your browser settings may affect how the Website functions.
• Duration of Cookies: We use Session Cookies, which expire when you close your browser, and Persistent Cookies, which remain on your device for a set period or until you delete them, to maintain your login status and preferences.

 

16. Changes to This Policy

We may alter this Privacy Policy to incorporate necessary changes in technology, applicable law, or any other variant from time to time by posting revisions within the Website. Such changes will be effective upon posting, and you will be notified via email or in-app notifications. We suggest that you regularly check this Privacy Policy to apprise yourself of any updates. Your continued use of the Website or provision of information thereafter will imply your unconditional acceptance of such updates.  

17. Grievance Redressal and Contact Us

If you have any comments, questions, or concerns about this Privacy Policy or how your personal information has been handled, you can contact our Data Protection Officer:  Data Protection Officer Email: DPOGT@IN.GT.COM Phone: 011 45287070 Address: L 41, Connaught Circus, Outer Circle, New Delhi - 110 001 Website: www.grantthornton.in   For any queries or complaints, you may contact the Data Protection Officer.  Consent Notice Form We Value Your Privacy ☐ I have read and agree to the terms of the Privacy Policy. By using this Website, I consent to Grant Thornton Bharat LLP processing my personal data to manage compliance activities, ensure security, and fulfill its legal obligations as described in the Privacy Policy. I understand that I can withdraw my consent at any time. For more details, please read our Privacy Policy.