Privacy Policy

CommLab India LLP ("CommLab India," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we handle personal information when you visit www.commlabindia.com, www.effectuslms.com, or their subdomains; request or use a product or service; download a resource; register for an event; apply for a role; or communicate with us. It also explains the privacy choices and rights that may be available based on where you live and the law that applies.

When we process personal information solely on an enterprise customer's documented instructions, the customer generally decides how and why that information is used. In that role, CommLab India acts as a processor or service provider. The customer's privacy notice and the applicable customer agreement or data processing agreement govern that information. If your request concerns information controlled by one of our customers, please contact that customer first.

1. Who We Are and How to Contact Us

CommLab India LLP is the controller of the website, marketing, business-contact, event, customer-administration, and recruitment information described in this Policy unless a separate notice identifies another organization as the controller.

Email: info@commlabindia.com

Postal address: CommLab India LLP, No. 9-1-130 & 131, Sebastian Road, Secunderabad - 500003, Telangana, India, Attention: Privacy

US office: 330 Mill Bay South, #1505, Afton, Minnesota 55001, USA

2. Scope and Important Information

2.1 What This Policy Covers

This Policy applies to personal information that CommLab India controls through the websites identified above and through the interactions described in the introduction. It does not replace or amend a customer agreement, data processing agreement, employment notice, applicant notice, or another product-specific privacy notice. If a separate notice applies to a particular interaction, that notice controls that interaction.

Customer-controlled information submitted to a hosted platform, learning environment, support channel, or project workspace is governed by the applicable customer agreement and the customer's instructions. CommLab India's obligations as a processor or service provider remain subject to that agreement and applicable law.

2.2 Changes to This Policy

We revise this Policy when our services, data practices, or legal obligations change. The current version will be available on this page with its effective date. When required by law, we will provide additional notice before a material change takes effect.

2.3 Third-Party Sites and Features

Our websites may contain links, social-media features, widgets, or embedded content provided by other organizations. Those providers may collect information directly or use cookies and similar technologies. Their privacy notices govern their independent practices, which CommLab India does not control. A link to another service does not mean that we endorse it.

3. Notice at Collection and Personal Information We Collect

The information we collect depends on how you interact with us. The categories below describe the personal information involved in our activities and, where relevant, its source.

• Contact and identity information, such as your name, business email address, postal address, telephone number, account or registration details, and similar identifiers. Sources may include you, your employer, event or referral partners, publicly available professional sources, and service providers.
• Professional and business information, such as your company, job title, role, department, industry, business interests, training needs, and information included in enquiries, project discussions, forms, surveys, or communications.
• Commercial and transaction information, such as products, services, resources, subscriptions, event registrations, purchases, customer-support history, contractual records, and billing information.
• Payment information. If a website or service offers payment functionality, payment-card and related billing information is processed by payment providers. CommLab India does not ordinarily store full payment-card numbers.
• Internet, device, and network activity, such as IP address, browser and device type, operating system, referring URL, pages viewed, clicks, access times, cookie identifiers, session information, and interactions with emails or online content.
• Approximate location inferred from an IP address. Our public websites are not intended to request device-level precise geolocation unless a separate notice is provided and any required permission is obtained.
• Audio, visual, and event information, such as photographs, recordings, webinar participation, questions, comments, and testimonials when you participate in an event, recording, or customer story.
• Preferences and inferences, such as language, communication preferences, areas of interest, and inferences about likely business interests based on interactions with our websites and communications.
• Job applicant information, such as resume or CV details, employment and education history, professional qualifications, application materials, interview notes, and information supplied by references or recruitment providers. A separate applicant notice may provide additional information.
• Customer-controlled information that enterprise customers or their users submit to hosted platforms, learning services, support channels, or project environments. We process this information under the customer's instructions and applicable agreement.

3.1 Information from Public and Third-Party Sources

We may obtain business contact and professional information from public professional profiles, company websites, event or referral partners, social networks, data providers, and other lawful sources. We use it to verify business records, remove duplicate contacts, understand potential customer needs, and make business-to-business outreach more relevant. Where applicable law requires notice because information was obtained indirectly, we provide that notice within the required period or at the first relevant communication. We rely on consent when required and otherwise on an applicable lawful basis, which may include legitimate interests. Marketing communications include an unsubscribe mechanism or instructions for objecting where required by law.

3.2 Sensitive Personal Information

Please do not submit sensitive personal information through general enquiry, download, newsletter, or event forms unless we specifically request it. If sensitive information is provided without being requested, we use it only as reasonably necessary to address the communication, protect our systems, comply with law, establish or defend claims, or delete it.

Sensitive personal information may be involved when it is necessary for a requested service, transaction, account-security measure, legal obligation, or employment process. We do not use sensitive personal information to infer characteristics about individuals. If a practice triggers a right to limit under applicable law, we will provide the required notice and choice.

4. How We Use Personal Information and Our Lawful Bases

When the EU General Data Protection Regulation, UK GDPR, or a similar law applies, we rely on an appropriate lawful basis for each processing activity. The basis may be consent, performance of or steps toward a contract, compliance with a legal obligation, or a legitimate interest pursued by CommLab India or another party. When relying on legitimate interests, we consider the purpose, necessity, and potential effect on individuals and retain an assessment where required or appropriate.

Our legitimate interests may include operating and improving our websites and services, supporting customers, maintaining security, preventing fraud, measuring performance, and conducting proportionate B2B marketing. You may ask for information about the assessment for a particular activity, subject to legal and confidentiality limits.

5. How We Disclose Personal Information

We disclose personal information for the purposes described in this Policy. Depending on the interaction, recipients may include:

• Corporate affiliates that support shared administration, service delivery, security, customer support, or business operations, subject to appropriate access restrictions.
• Service providers and contractors that provide hosting, analytics, CRM, marketing automation, communications, payment processing, customer support, security, recruitment, professional advisory, or similar services. Their contracts restrict how they may handle information according to their role and applicable law.
• Advertising and social-media partners where permitted by law and subject to required consent and opt-out choices.
• Event, referral, or business partners when you register for a jointly offered activity, request an introduction, or are otherwise informed at the point of collection.
• Professional advisers, auditors, insurers, regulators, courts, law-enforcement agencies, or other parties when disclosure is required by law or reasonably necessary to protect rights, safety, or property; investigate fraud or security incidents; enforce agreements; or preserve the integrity of our services.
• Parties involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to applicable law and appropriate confidentiality measures.

We may use or disclose aggregated or de-identified information for analysis and other business purposes when it cannot reasonably be linked to an individual. Where required by law, we maintain that information in de-identified form and do not attempt to re-identify it except to test whether our de-identification measures are effective.

6. Sale, Sharing, and Targeted Advertising

CommLab India does not sell personal information for money. Some privacy laws define a "sale" more broadly or treat disclosures for cross-context behavioral or targeted advertising as "sharing," even when no money is exchanged. Depending on the advertising technologies in use, these activities may involve identifiers, internet or device activity, approximate location, and inferred interests disclosed to advertising or social-media partners.

Where applicable law gives you an opt-out right, you may exercise that choice through the consent banner where available or by sending a legally recognized opt-out preference signal, including Global Privacy Control. We treat a recognized signal as an opt-out request for the browser or device that sends it and extend it to an associated profile when required by law and reasonably possible. We do not knowingly sell or share personal information about anyone under 16.

7. Cookies and Similar Technologies

We use cookies, pixels, web beacons, local storage, and similar technologies to operate the websites, remember preferences, understand how people use our content, protect our services, measure communications, and support advertising. These technologies can collect the internet, device, and activity information described in Section 3.

• Strictly necessary cookies support core functionality, security, consent records, and requested services.
• Functional cookies remember settings and enable enhanced features.
• Analytics cookies help us understand traffic, usage, and performance.
• Advertising cookies help measure campaigns and may support interest-based or targeted advertising across websites.

For visitors in the EEA and UK, and in other places where prior consent is required, non-essential cookies are not activated until you make a choice. The banner allows you to accept or decline non-essential cookies.

Our Cookie Policy provides information about the cookies and similar technologies currently identified on the relevant website, including their providers, purposes, and expected durations. Browser controls may also block cookies, although some features may then work differently.

8. International Transfers

Because CommLab India operates internationally, personal information may be accessed, stored, or processed in India, the United States, and countries where our customers, service providers, or corporate affiliates operate. Privacy protections in those countries may differ from those in your country.

Where a restricted transfer from the EEA, UK, or another jurisdiction requires a transfer mechanism, we use an appropriate mechanism for the transfer in question. Depending on the circumstances, this may include an adequacy decision, the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, or another lawful safeguard. Where required, we assess the transfer and apply supplementary contractual, technical, or organizational measures appropriate to the risk. You may contact us for information about the safeguard used for a particular transfer, subject to legal and confidentiality limits.

9. Data Retention

We set retention periods by considering why information was collected, its volume and sensitivity, the risk of keeping it, and relevant contractual, tax, accounting, security, limitation-period, and other legal requirements. The periods below are our standard retention approaches for primary systems. A shorter or longer period may apply where you exercise a right, a contract or law requires a different period, information is needed for an investigation or claim, or information remains temporarily in a restricted backup.

After the applicable period, we delete or anonymize the information unless the law permits or requires further retention. Information remaining in a backup is restricted from ordinary use and removed according to the applicable backup cycle, unless preservation is required for security, disaster recovery, or legal reasons.

10. Security

We maintain administrative, technical, and physical safeguards designed to be appropriate to the nature of the personal information and the risks associated with its processing. Depending on the system and processing activity, these measures may include access controls, encryption in transit, secure hosting configurations, monitoring, backup controls, incident-response procedures, and service-provider oversight. We review safeguards in light of the information and risks involved. No security measure or transmission method can eliminate every risk.

If you believe your interaction with us is no longer secure, contact us promptly at info@commlabindia.com with the subject line "Security Concern."

11. Your Privacy Choices

11.1 Marketing Communications

You can unsubscribe from marketing emails through the link or instructions in the message, or by emailing info@commlabindia.com. We may continue to send transactional, service, security, or administrative messages that are necessary for our relationship with you. We retain a limited suppression record when needed to respect your choice.

11.2 Cookies and Advertising

Use the banner to accept or decline non-essential cookies. For more information about the cookies and similar technologies used on the website, see our Cookie Policy. If applicable law gives you the right to opt out of sale, sharing, or targeted advertising, you may also send a legally recognized browser signal, including Global Privacy Control. The signal applies to the browser or device that sends it and, when required by law and reasonably possible, to an associated profile. You may need to renew your choice after clearing cookies or when using another browser or device.

12. EEA and UK Privacy Rights

If EU or UK data protection law applies to our processing of your personal information, you may have the right to:

• Access your personal information and receive a copy
• Correct inaccurate or incomplete information
• Request deletion of personal information
• Restrict certain processing
• Receive certain information in a structured, commonly used, machine-readable format and transmit it to another controller
• Object to processing based on legitimate interests, including related profiling
• Object at any time to processing for direct marketing, including related profiling
• Withdraw consent at any time where processing is based on consent, without affecting earlier lawful processing
• Receive information about and exercise applicable rights concerning solely automated decisions that produce legal or similarly significant effects

These rights are subject to legal conditions and exceptions. Submit a request using Section 19. We ordinarily respond within one month after receiving a valid request. Where permitted, we may extend the period by up to two additional months because of complexity or the number of requests. We will notify you of an extension and explain why.

You may complain to the data protection authority where you live or work, or where you believe an infringement occurred. UK residents may contact the Information Commissioner's Office. You do not have to contact us before making a complaint, although doing so gives us an opportunity to investigate.

13. California Privacy Notice

This section supplements the rest of the Policy for California residents when the California Consumer Privacy Act, as amended ("CCPA"), applies to CommLab India's processing. Terms used here have the meanings given to them by the CCPA.

13.1 Categories Collected and Disclosed

During the preceding 12 months, the categories collected may have included identifiers; customer-record and commercial information; internet or other electronic network activity; approximate geolocation; audio, electronic, visual, or similar information; professional or employment-related information; education information provided during recruitment; and inferences drawn from other information. These categories may be disclosed for business purposes to the recipient categories identified in Section 5.

We do not sell personal information for money. As explained in Section 6, some disclosures to advertising or social-media partners may be considered a sale or sharing under the CCPA even when no money is exchanged. Depending on the technologies used during the preceding 12 months, the categories involved may include identifiers, internet or network activity, approximate location, and inferences. We provide the opt-out methods described in Sections 6 and 11.

We do not knowingly sell or share personal information about consumers under 16. We do not currently offer financial incentives or differences in price or service in exchange for personal information. If that changes, we will provide the notice required by law before the program begins.

13.2 Sensitive Personal Information

Sensitive personal information involved in a service may include account log-in credentials, payment-related information handled by payment providers, or limited recruitment information. We use and disclose it for purposes such as providing a requested service, processing a payment, maintaining security, preventing fraud, complying with law, or administering recruitment. We do not use it to infer characteristics about you. If a practice creates a right to limit, we will provide the required notice and mechanism.

13.3 California Consumer Rights

Subject to legal conditions and exceptions, California residents may have the right to:

• Know the categories and specific pieces of personal information we have collected, the sources, purposes, and categories of recipients
• Delete personal information we collected from you
• Correct inaccurate personal information
• Opt out of the sale or sharing of personal information
• Limit certain uses and disclosures of sensitive personal information when the right applies
• Receive equal service and pricing and not be retaliated or discriminated against for exercising a CCPA right

13.4 Submitting and Verifying a California Request

Submit a request by emailing info@commlabindia.com with the subject line “California Privacy Request,” by writing to the postal address shared in Section 1, or by using the opt-out methods described in Sections 6 and 11 where applicable.

We acknowledge and respond within the period required by law. A substantive response is generally provided within 45 calendar days. If an additional 45 days is permitted and reasonably necessary, we will notify you and explain the reason. To protect personal information, we may compare details supplied with the request against information in our records. We use verification information only to process and document the request or as otherwise permitted by law.

You may appoint an authorized agent. Unless the agent holds a valid power of attorney under applicable law, we may request proof of authorization and, where allowed, ask you to verify your identity or confirm the authorization directly. If we cannot verify a request to the legally required standard, or an exception applies, we will explain the decision unless prohibited from doing so.

14. Other US State Privacy Rights

Residents of Minnesota and other US states may have additional rights when a state privacy law applies to CommLab India and the relevant processing. Depending on the law, these rights may include access, correction, deletion, portability, confirmation of processing, a list of third parties to which personal data was disclosed, and the ability to opt out of sale, targeted advertising, or certain profiling.

Submit a request using Section 19. If we decline a request and applicable law provides an appeal right, you may appeal by emailing info@commlabindia.com with the subject line "Privacy Appeal" within 60 days of our decision. Include the original request and explain why you believe the decision should be reconsidered. We will respond within the period required by the applicable law and provide information about any further complaint option when required.

15. Rights in India and Other Jurisdictions

Privacy laws in India and other jurisdictions may provide additional rights when their relevant provisions are in force and apply to CommLab India's processing. These may include rights to obtain information about processing, request correction or erasure, withdraw consent, nominate another person where provided by law, or use a grievance process. Submit a request or grievance using Section 19. We will respond according to the law that applies to the request.

16. Automated Decision-Making

We do not currently use personal information collected through our public websites to make solely automated decisions that produce legal or similarly significant effects about individuals. This statement does not cover processing performed by an enterprise customer using customer-controlled information. If CommLab India introduces such processing as a controller, the relevant notice will describe the processing and the safeguards and rights required by applicable law.

17. Children's Privacy

Our public websites and business services are intended for adults and are not directed to children under 16. We do not knowingly collect, sell, or share personal information about children under 16 through them. Contact us if you believe a child has submitted personal information so that we can investigate and take appropriate action.

18. Public Features, Testimonials, and Recordings

If we offer a publicly accessible blog comment area, forum, or similar feature, information posted there can be viewed and used by others. Do not post information that you want to keep private. Requests to correct or remove a post will be considered subject to applicable law, technical limitations, and the rights of others.

Customer testimonials, photographs, recordings, and attributed comments are published as permitted by the applicable agreement, authorization, or consent. Contact us with questions about a published item or to withdraw consent where the law provides that right. Withdrawal does not affect use that was lawful before withdrawal and may be limited by other lawful grounds or contractual rights.

18A Privacy and Security Incidents

CommLab India maintains documented incident-response procedures to identify, report, assess, contain, investigate, remediate, and learn from suspected or confirmed privacy and security incidents. Incidents are logged, assigned, escalated, and retained as audit evidence in accordance with applicable internal procedures.

Where applicable law, a customer agreement, or a data processing agreement requires notice, CommLab India will notify the relevant customer, regulator, authority, or affected individual within the required timeframe and provide available information appropriate to the circumstances. Notification decisions are coordinated through authorized Legal, Compliance, Information Security, and management representatives.

18B Artificial Intelligence and Automated Tools

CommLab India may use approved artificial intelligence or automated tools to assist with internal operations, service delivery, analysis, support, or content-related activities. Such use is subject to applicable contracts, customer instructions, data-classification requirements, access controls, security assessment, human oversight, and the CommLab India AI governance framework.

Personal information, confidential information, or customer-controlled information must not be entered into an unapproved public AI tool. When an approved enterprise AI tool or a customer-approved dedicated environment is used, access, data handling, retention, output review, and incident reporting requirements apply. AI-assisted outputs that may affect customers or individuals are subject to appropriate human review for accuracy, confidentiality, bias, intellectual property, accessibility, and contractual compliance.

18C Service Providers and Subprocessors

CommLab India evaluates service providers and subprocessors using risk-based due diligence appropriate to the service and information involved. Contracts include confidentiality, security, privacy, data-use, incident-notification, retention, deletion, audit, and international-transfer terms where applicable. Providers are subject to periodic review and change management in accordance with CommLab India vendor-management procedures.

A current list of significant subprocessors supporting relevant hosted or customer-facing services may be made available to customers through an approved channel or upon reasonable request, subject to confidentiality and security considerations. Customer notification and objection rights, where applicable, are governed by the relevant customer agreement or data processing agreement.

19. Exercising Rights and Contacting Us

Contact us to exercise a privacy right, withdraw consent, object to processing, appeal or question a response where applicable, report a concern, or ask about this Policy.

Email: info@commlabindia.com

Postal address: CommLab India LLP, No. 9-1-130 & 131, Sebastian Road, Secunderabad - 500003, Telangana, India, Attention: Privacy

US office: 330 Mill Bay South, #1505, Afton, Minnesota 55001, USA

Please describe your request, identify the relevant website, service, account, or interaction, and state where you live so that we can determine which law applies. We may request additional information reasonably necessary to verify identity, authority, or the scope of the request and to prevent unauthorized access. We may deny, limit, or charge for a request only where applicable law permits and will explain the decision when required. We respond within the period required by the law that applies.