Introduction
FNG is committed to protecting the confidentiality and integrity of information collected from users of our website, programs, and services. This Privacy Policy explains what we collect, how we use it, when we disclose it, and the choices available to users. In India, entities operating online are required to publish a privacy policy describing data handling practices.
Information We Collect
- Personal Identifiers: name, email, phone number, postal address, date of birth.
- Financial Data: payment card details, billing address, transaction records (collected via our payment processor).
- Professional Data: employer, role, qualifications, CVs, and references.
- Usage Data: IP address, device identifiers, browser type, pages visited, session duration, and cookies.
- Communications: messages, feedback, and support requests.
How We Use Information
- To provide and manage programs, courses, and events.
- To process payments, issue receipts, and manage refunds.
- To communicate updates, marketing, and administrative notices.
- To improve services, personalize content, and analyze engagement.
- To detect, prevent, and respond to fraud, abuse, or security incidents.
Sharing and Disclosure
- Service Providers: We share data with payment processors, hosting providers, analytics vendors, and email platforms under strict contracts.
- Business Transfers: Data may be transferred in connection with mergers, acquisitions, or asset sales.
- Legal Requirements: We may disclose data to comply with laws, enforce our terms, or protect FNG’s rights and safety.
- Limited Third-Party Access: We do not sell personal data; any third-party access is limited, contractual, and monitored.
Cookies and Tracking
- We use cookies and similar technologies to enable site functionality, remember preferences, and measure performance. Users can control cookies via browser settings, though disabling cookies may affect site functionality.
Data Security and Retention
- We implement reasonable technical and organizational measures to protect data against unauthorized access, alteration, or destruction.
- Retention: We retain personal data only as long as necessary for the purposes described, for legal compliance, or for legitimate business needs. Specific retention periods are documented internally.
Your Rights and Choices
- Access, correction, deletion, and portability requests will be processed in accordance with applicable law.
- Marketing opt-out: Users may opt out of promotional communications via links in emails or by contacting us.
- Account controls: Registered users can update profile and payment details through their account settings.
Children and Sensitive Data
- We do not knowingly collect personal data from children under 18. Sensitive personal data is collected only with explicit consent and limited to necessary purposes.
Indian Data Breach Liability and Limitation
Scope and security commitment
Foundation for NextGen Governance (“FNG”) implements reasonable technical and organizational measures to protect personal data. FNG does not warrant that its security measures will prevent every unauthorized access or data breach. In the event of a Personal Data Breach, FNG will use commercially reasonable efforts to investigate, mitigate, and remediate the incident.
Notification and mitigation
- Prompt notification: FNG will notify affected individuals and any competent authority as required by applicable law without undue delay and will provide information about the nature of the breach, the likely consequences, and the measures taken or proposed to be taken.
- Mitigation efforts: FNG will take commercially reasonable steps to contain the breach, mitigate harm, and prevent recurrence.
Limitation of liability for data breaches
- Aggregate cap: To the maximum extent permitted by applicable law, FNG’s aggregate liability for direct damages arising from a Personal Data Breach shall be limited to the amount paid by the affected data subject to FNG for the specific service in the twelve (12) months preceding the claim, or INR [insert cap amount], whichever is lower.
- Exclusion of indirect damages: Except as required by law, FNG shall not be liable for indirect, incidental, special, consequential, or punitive damages, including loss of profits, loss of business, or reputational harm.
No waiver of mandatory legal obligations
Nothing in this clause excludes or limits liability for willful misconduct, gross negligence, fraud, or any liability that cannot be excluded or limited under applicable law, including statutory obligations and regulatory penalties under Indian data protection laws.
Indemnity and cooperation
- Indemnity: To the extent permitted by law, users agree to indemnify and hold FNG harmless from third‑party claims arising from the user’s breach of obligations, misuse of services, or provision of false information.
- Cooperation: The parties will cooperate reasonably in breach investigations, notifications, and remedial actions and will share information necessary to comply with legal obligations.
Changes to This Policy
We may update this policy; material changes will be posted with an updated effective date.
Contact
For questions, data requests, or complaints, contact:
Email: privacy@fng.org
Address: Foundation for NextGen Governance, K-11, 1-2 Floor, Hauz Khas Enclave, New Delhi -110016
Effective Date: 01-04-2025