Privacy policy

MSM Global Education Private Limited, CIN U68200GJ2021FTC123627, having its registered office at Flat No. 207, S.F. Sachet-2, Near Reliance House, Near Maradiya Plaza, Navrangpura, Ahmedabad, Gujarat – 380009, India (“MSM Unify India”, “we”, “us” or “our”), operates MSM Unify India Campus (the “Portal”). Our corporate office is at Plot No. 28, Institutional Area, Sector-32, Gurugram, Haryana – 122003, India.

This Policy explains how we collect, use, disclose, retain and protect personal data when you visit the Portal, register, submit an enquiry or application, communicate with us, or use our education-related services. MSM Global Education Private Limited is the Data Fiduciary responsible for processing personal data in connection with the India Campus under the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and applicable rules.

1.1 Personal Data We Collect

• Identity and contact information: name, mobile number, email address, date of birth/age, location;
• Educational information: qualifications, programme preferences, application details and supporting documents;
• Payment-related information (processed via third-party payment gateways — see Data Sharing and Disclosure);
• Communication records with you, including calls, emails and WhatsApp messages;
• Technical and device information, including cookies and similar technologies (see Cookies and Other Tracking Technologies);
• Any other information you voluntarily provide through forms, calls, emails, WhatsApp or other channels.

1.2 Purpose of Processing

We use this information to respond to your enquiries; provide counselling and admission assistance; process applications; connect you with relevant educational institutions and partners; provide student support; process payments; improve and secure the Portal; prevent fraud; comply with legal obligations; maintain business records; and, only with your separate affirmative consent, send promotional or commercial communications.

We process your personal data on the basis of your consent, or, where permitted under the DPDP Act, for a “legitimate use” such as a purpose for which you have voluntarily provided data and not indicated you do not consent (e.g., responding to an unsolicited enquiry), compliance with law, or performance of a service you have requested. This Section, together with the consent screens presented to you at the point of data collection, constitutes the notice required under Section 5 of the DPDP Act.

Because the Portal is used by prospective students, some of whom are minors applying for undergraduate programmes, this Policy applies enhanced protections for minors’ data. See the Minors’ Data section below.

4.1 Separate, affirmative consent

At the point you submit your contact details, you will be asked to give separate, specific and affirmative consent (e.g., by ticking distinct checkboxes, none of which is pre-ticked) for each of the following, rather than a single bundled consent:

• (a) Service-related processing: processing necessary to respond to your enquiry, provide counselling, and process your application, including sharing your data with the specific institutions you apply to.
• (b) Promotional communications: receiving marketing or promotional messages about programmes, offers or related opportunities from MSM Unify India and/or its partners, by telephone, SMS, email or WhatsApp.

Consent (a) is required to use the Portal’s core services. Consent (b) is optional and you may use the Portal’s core services without giving it.

4.2 Withdrawal

You may withdraw consent (b) at any time using the unsubscribe/opt-out mechanism provided, or by contacting the Privacy & Grievance Officer named in the Grievance Redressal section. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, or Service Communications necessary to deliver a service you have already requested.

MSM Global Education Private Limited (“MGEP”, “we”, “us” or “the Company”) uses cookies and similar tracking technologies on its website, including the MSM Unify India Campus website (“Website”), to enhance user experience, facilitate website functionality, analyse usage patterns and improve our services.

5.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They enable the Website to recognise your browser, remember certain preferences and, where applicable, retain information previously provided by you. We may also use similar technologies, including pixels, tags, scripts and web beacons, for purposes described in this section.

5.2 Types of Cookies We Use

Depending on the features and services available on the Website, we may use the following categories of cookies:

• Strictly Necessary Cookies: essential for the operation, security and accessibility of the Website and to enable core functions, such as user authentication and secure access to relevant features.
• Functional Cookies: these remember your preferences and settings to provide a more personalised and consistent browsing experience.
• Analytics and Performance Cookies: these help us understand how users interact with the Website, including pages visited, time spent, traffic patterns and technical errors, enabling us to evaluate and improve Website performance.
• Advertising and Marketing Cookies: where implemented and subject to applicable consent requirements, these may be used to measure the effectiveness of marketing campaigns, understand user interests and deliver relevant communications or advertisements.

5.3 Information Collected Through Cookies

Cookies and other tracking technologies may collect technical and usage-related information, including your Internet Protocol (IP) address, browser type, device and operating system information, Internet domain and host names, pages visited, clickstream data, referring URLs, browsing preferences, and the dates and times of Website access.

We may use this information in aggregated or statistical form to analyse trends, monitor Website performance, maintain security, detect technical issues and improve our Website and services.

Where such information identifies or can reasonably be linked to an individual, it will be treated as Personal Data in accordance with this Privacy Policy and applicable data protection laws.

5.4 Consent and Cookie Preferences

Where required under applicable law, we will seek your consent before placing or accessing non-essential cookies or deploying tracking technologies that require consent.

You may manage your cookie preferences through the cookie consent banner or preference management tool made available on the Website, where applicable. You may also withdraw or modify your consent at any time through the available cookie settings.

Refusing or withdrawing consent for non-essential cookies will not affect your access to essential Website features, although certain optional functionalities or personalised services may be limited.

5.5 Managing Cookies Through Your Browser

Most web browsers allow you to control, restrict, block or delete cookies through their settings. You may configure your browser to notify you when cookies are being placed or to refuse certain categories of cookies.

Please note that disabling or deleting certain cookies may affect Website functionality, and you may be required to re-enter your login credentials or preferences when accessing certain areas of the Website.

5.6 Third-Party Cookies and Tracking Technologies

We may permit third-party service providers, including analytics, technology, advertising and platform service providers, to use cookies or similar technologies on the Website for legitimate business purposes and, where required, subject to your consent.

Such third parties may process information in accordance with their respective privacy policies and applicable contractual obligations. MGEP does not control cookies placed by third-party websites or services independently of our Website.

We encourage you to review the privacy and cookie policies of relevant third-party providers for further information about their data collection and processing practices.

5.7 Updates to This Cookie Section

We may update this section from time to time to reflect changes in our Website, technologies, business practices or applicable legal requirements. Any revised version will be published on the Website with the updated effective date, where applicable.

We may share personal data, where necessary and lawful, with:

• educational institutions, universities, colleges, admission and counselling partners — limited to the specific institutions you have chosen to apply to or enquire about, which will be identified to you before your data is shared with them;
• payment processors, for the purpose of processing payments;
• technology, IT and cloud service providers, and communication providers, who process data on our behalf under contractual confidentiality and security obligations;
• professional advisers, auditors, regulators and governmental authorities, where required by law;
• other authorised service providers engaged to support the services described in this Policy.

Each such party receives only the information reasonably required for its specific purpose and is bound by contractual, confidentiality and security obligations. On request, we will tell you which specific institutions or partners your personal data has been shared with.

Subject to applicable law and verification of your identity, you have the right to:

• obtain a summary of the personal data we hold about you and the processing activities undertaken;
• request correction, completion or updating of your personal data;
• request erasure of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention requirements;
• withdraw consent, to the extent processing is based on consent, as described in Consent, Granularity and Withdrawal;
• nominate another individual to exercise these rights on your behalf in the event of your death or incapacity;
• file a grievance with us as described in Grievance Redressal, and, if unsatisfied with our response, to file a complaint with the Data Protection Board of India.

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including:

• approximately 3 years from your last active interaction, enquiry or application, for prospective-student records;
• 7 years for financial, payment or tax records, or such longer period as required by applicable law;
• for the duration of an active student/application relationship and thereafter for the applicable limitation, regulatory or legal period.

Where feasible and required by applicable law, we will notify you a reasonable period before personal data that is no longer necessary is erased, so that you may request continued retention where permitted. Data is otherwise securely deleted, anonymised or aggregated when no longer required, subject to legal holds.

9.1 The Portal is used by prospective students, including applicants for undergraduate programmes who may be under 18 years of age. We treat this as an expected, routine part of our user base rather than an exceptional case.

9.2 Age check

At the point of registration or enquiry, the Portal will ask for a date of birth. Where the user is identified as a minor, the enquiry/application flow will require the involvement of a parent or legal guardian before any further processing takes place.

9.3 Verifiable parental consent

Where the processing of Personal Data of a child requires parental or lawful guardian consent under applicable law, MSM Global Education Private Limited (“MGEP”), operating the MSM Unify India Campus platform, shall obtain verifiable consent from the parent or lawful guardian before undertaking such processing.

Such consent may be obtained through one or more verification mechanisms, including OTP-based verification, recorded confirmation calls, verification through a linked parent or guardian account, DigiLocker-based verification, government-issued identity verification, or any other mechanism permitted under the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the rules framed thereunder.

MSM Unify India’s Verification Mechanism: The Company may implement a verification mechanism involving verification of the parent’s or lawful guardian’s identity and relationship with the child through a legally recognised verification service, government-authorised digital platform, or other method prescribed or permitted under applicable law. The specific mechanism adopted shall be proportionate to the nature of processing and shall comply with applicable requirements concerning consent, data minimisation, security and protection of children’s Personal Data.

The Company shall not knowingly undertake processing of a child’s Personal Data requiring verifiable parental or lawful guardian consent until such consent has been obtained and verified in accordance with applicable law.

9.4 No tracking or targeted advertising to minors

We will not undertake behavioural monitoring, tracking, or targeted advertising directed at users we know to be minors, and will not process minors’ data in any manner likely to cause them harm, except where a statutory exemption applies (for example, for age verification itself, or where processing is clearly in the minor’s interest, such as for counselling they have sought).

9.5 A parent or guardian who has provided consent under this Section may withdraw it at any time by contacting the Privacy & Grievance Officer named in the Grievance Redressal section, following which we will stop further processing of the minor’s data other than as required by law.

Some of our service providers, cloud infrastructure, technology platforms, educational partners or group entities may process or store personal data outside India. Where personal data is transferred outside India, we will ensure the transfer is undertaken in accordance with the DPDP Act, applicable rules, any government-notified restrictions on transfer to specific countries or territories, and other applicable Indian law, and will implement appropriate contractual, organisational and technical safeguards with the recipient.

We maintain reasonable security safeguards, including access controls, authentication, confidentiality measures, monitoring, backups, and appropriate technical and organisational measures designed to protect personal data from unauthorised access, disclosure, alteration, loss or destruction. In the event of a personal data breach, we will take appropriate remedial measures and notify the Data Protection Board of India and affected users within the timelines and in the manner required by applicable law.

For questions about the processing of your personal data, to exercise the rights set out above, or to raise a privacy grievance, please contact:

• Privacy & Grievance Officer, MSM Global Education Private Limited
• Registered Office: Flat No. 207, S.F. Sachet-2, Near Reliance House, Near Maradiya Plaza, Navrangpura, Ahmedabad, Gujarat – 380009, India
• Email: grievance@msmunify.com

We will acknowledge and aim to resolve grievances within the timelines prescribed under applicable law. If you are not satisfied with our response, you may escalate your complaint to the Data Protection Board of India, constituted under the DPDP Act, 2023.

We may update this Policy from time to time to reflect changes in our services, technology, data-processing practices or applicable law. The updated Policy will be published on the Portal together with a revised “Last Updated” date. Where changes are material — for example, a new category of data shared with third parties — we will take reasonable steps to bring the change to your attention, such as a notice on the Portal or an email, before it takes effect. Continued use of the Portal following an update constitutes acceptance of the revised Policy to the extent permitted by applicable law.

• MSM Global Education Private Limited
• CIN: U68200GJ2021FTC123627
• Registered Office: Flat No. 207, S.F. Sachet-2, Near Reliance House, Near Maradiya Plaza, Navrangpura, Ahmedabad, Gujarat – 380009, India
• Corporate Office: Plot No. 28, Institutional Area, Sector-32, Gurugram, Haryana – 122003, India
• Website: www.msmunify.com