Privacy Policy

1. INTRODUCTION AND SCOPE

This Privacy Policy explains how Globalfti Private Limited (“Globalfti”, “GFTI”, “We”, “Us” or “Our”) collects, receives, uses, stores, shares, transfers, protects and otherwise processes Personal Data in connection with Our Platform, Courses and Services.

This Privacy Policy applies to Visitors and Users of the Platform, students enrolled in Courses, persons interacting with Our admissions, support or academic teams, and, where relevant, parents or lawful guardians acting for a User below 18 years of age. It applies to Personal Data collected online and offline, including through Our website, applications, learning management systems, customer relationship management systems, video-conferencing tools, forms, email, telephone, SMS, WhatsApp and other authorised communication channels, as well as at GFTI or Partner Institute premises.

This Privacy Policy should be read together with Our Terms of Use, Refund Policy, and any specific privacy notice presented when particular Personal Data is collected. If there is an inconsistency concerning the processing of Personal Data, this Privacy Policy will govern to the extent of that inconsistency, subject to applicable law.

This Privacy Policy is intended to operate in accordance with applicable Indian law, including the Information Technology Act, 2000 and applicable rules thereunder, and the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025 (“DPDP Rules”), in each case to the extent the relevant provisions are in force and applicable from time to time. References to rights or obligations under the DPDP Act or DPDP Rules apply subject to their statutory commencement. Nothing in this Privacy Policy limits any mandatory right available to You under applicable law.

Where applicable law requires consent for a particular processing activity, We may obtain such consent separately, through the Platform, an enrolment form, a device permission, a specific notice or another appropriate mechanism. Merely accessing this Privacy Policy is not intended to substitute any consent that applicable law requires to be obtained separately.

2. DEFINITIONS

Capitalised expressions not defined in this Privacy Policy have the meanings assigned to them in Our Terms of Use. For this Privacy Policy:

“Account” or “User Account” means the personal account created for a User to access the Platform, Courses or Services.
“Affiliate” means an entity that controls, is controlled by or is under common control with a party, where control means ownership or control of 50% or more of the voting or equivalent management rights.
“Course” means any certification, programme, workshop, training, webinar, seminar or qualification-related service offered by Us, or offered by Us in collaboration with a Partner Institute, through online, offline or hybrid mode, whether instructor-led, self-paced or a combination of both.
“Data Fiduciary” has the meaning assigned under applicable data protection law and, where applicable, includes GFTI when We determine the purpose and means of processing Personal Data.
“Data Principal” means the individual to whom Personal Data relates and, where applicable under law, includes a parent or lawful guardian acting on behalf of a child or a person with disability.
“Device” means a computer, mobile phone, tablet or other device used to access the Platform or Services.
“Partner Institute” has the meaning assigned in the Terms of Use and includes, as applicable, professional bodies, universities, educational institutions, awarding organisations, certification partners, examination bodies and other organisations with whom GFTI works in connection with a Course or Service.
“Personal Data” means data about an individual who is identifiable by or in relation to such data, and includes any equivalent category of personal information recognised under applicable law.
“Personal Data Breach” means any unauthorised processing of Personal Data or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access to Personal Data that compromises its confidentiality, integrity or availability, as recognised under applicable law.
“Platform” collectively means Our websites (including globalfti.com), applications, LMS, CRM, communications systems, examination and evaluation systems, feedback/review systems and other information-technology components used to provide the Services.
“Processing” includes any operation performed on Personal Data, such as collection, recording, organisation, storage, adaptation, retrieval, use, alignment, sharing, disclosure, dissemination, restriction, erasure or destruction, whether carried out wholly or partly by automated means.
“Service Provider” means a person or entity that processes or handles information for, or provides services to, GFTI in connection with the Platform, Courses or Services.
“Usage Data” means technical and interaction information generated through use of the Platform or Services, such as IP address, device/browser information, login records, access logs, session details and similar diagnostic or usage information.
“User”, “You” or “Your” means the individual accessing or using the Services or, where applicable, the entity on whose behalf the individual is acting.

3. PERSONAL DATA WE MAY COLLECT

The categories of Personal Data We collect depend on how You interact with GFTI, the Course or Service selected, the requirements of the relevant Partner Institute or professional body, and the features of the Platform that You use. We seek to collect Personal Data that is reasonably necessary for the relevant purpose.

3.1 Identity and Contact Data

Name, email address, mobile/telephone number and postal address.
Profile photograph and other profile information voluntarily supplied by You.
Date of birth, age or age-verification information where reasonably necessary for enrolment, eligibility, examination registration, financing or compliance with applicable law.
Identity or address documents where required for professional-body registration, examination administration, financing/KYC, legal compliance or fraud prevention.
Parent or guardian details where the User is below 18 years of age and parental or guardian involvement or consent is required.

3.2 Academic, Professional and Registration Data

Educational qualifications, college/university details, marks, certificates, transcripts and prior examination information.
Professional-body, awarding-body or candidate registration numbers, membership numbers, exemptions, eligibility information and related documents.
Examination bookings, examination attempts, results or other information supplied by You or received from a Partner Institute or examination body where relevant to the Course or Services.
Documents and information required to facilitate registration, exemptions, examination booking, certification, membership or other services requested by You.

3.3 Course, Learning and Academic-Performance Data

Courses, subjects, batches and plans selected or purchased by You.
Attendance records for live, offline or online sessions, including time of joining/leaving where available.
LMS progress, viewing history, course-content access records and completion status.
Assignments, homework, practice questions, mock examinations, answers, scores, faculty evaluations, feedback and academic-support records.
Information relevant to Course-specific benefits or eligibility, including requests and evidence submitted for resit support or the “Support Until You Pass” feature.

3.4 Account, Device, Security and Usage Data

User ID, account status, authentication records and password-reset information. We do not intend to view Your password in readable form where appropriate technical controls are used.
IP address, browser type/version, operating system, device type, device identifiers and general network information.
Login dates and times, session information, concurrent-login information, failed-login attempts, security alerts and access history.
Pages, features, classes, recordings or content accessed, duration of access, clicks and other diagnostic or interaction data.
Approximate location inferred from IP or network information where technically generated. Precise device location is collected only where a specific feature requires it and the appropriate permission or notice is provided.

3.5 Payment, Billing and Refund Data

Fee amount, billing details, invoices, transaction/reference numbers, payment status, instalment status, refund requests and refund-payment details.
Bank account or UPI information where reasonably required to process a refund or payment adjustment.
Where payments are processed by a third-party payment gateway, complete card, banking or other payment credentials may be collected directly by that provider and may not be received or stored by GFTI. The provider’s processing is governed by its own terms and privacy practices.

3.6 Financing and Education-Loan Data

Where You voluntarily opt for an education loan, EMI or financing arrangement through a bank, NBFC or other financing partner, We may process information reasonably required to facilitate the application, Course confirmation, KYC/eligibility support, fee disbursement, payment reconciliation, cancellation or refund adjustment.
The financing partner may independently collect and process additional information under its own privacy policy and applicable law. GFTI does not control the lender’s independent credit or underwriting decisions.

3.7 Communications, Support and Feedback Data

Emails, support tickets, telephone-call records or notes, WhatsApp/SMS communications, chat messages and other communications with GFTI.
Feedback, complaints, grievances, survey responses, reviews and testimonials submitted by You.
Records reasonably necessary to investigate or resolve disputes, complaints, suspected misuse or breaches of the Terms of Use.

3.8 Class, Webinar and Event Recording Data

Audio, video, screen-sharing content, name/profile identifiers, questions, chat messages and other participation captured when a live class, webinar, counselling session, academic event or other interactive session is recorded.
Photographs or videos taken at GFTI or Partner Institute events or premises where appropriate notice is provided or where You participate in an activity intended to be photographed or recorded, subject to applicable law.

3.9 Information Collected Through Device Permissions

Certain Application features may request permission to access Your camera or photo library when You choose to upload a photograph, document or other content. If a specific feature requires access to precise location or contacts, We will request the relevant device permission and provide an appropriate notice where required. You may manage device permissions through Your device settings, although disabling a permission may prevent the relevant feature from functioning.

3.10 Information About Other Persons

If You provide Personal Data about another individual, including a parent, guardian, nominee, sponsor or emergency contact, You represent that You are authorised to provide that information and that the individual has been informed as required by applicable law. You should not provide Personal Data that is not reasonably required for the relevant Service.

4. HOW WE COLLECT PERSONAL DATA

We may collect Personal Data:

directly from You when You create an Account, enquire about or enrol in a Course, submit forms or documents, make payments, attend classes, submit assessments, request support, communicate with Us or exercise privacy rights;
automatically through the Platform, cookies, access logs and security/diagnostic technologies when You use Our websites, apps, or other online Services;
from Partner Institutes where relevant to a Service requested by You;
from payment gateways, banks, NBFCs or financing partners in connection with payment, refund or financing status;
from Service Providers who assist Us in operating the Platform or delivering Services; and
from publicly available or lawfully accessible sources where reasonably necessary for verification, fraud prevention, legal compliance or dispute resolution.

5. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

Subject to applicable law, We may process Personal Data for the following purposes:

To create, authenticate, administer and secure User Accounts.
To respond to enquiries, advise You about Courses and process enrolments.
To provide live classes, recorded classes, study materials, academic support, mock examinations and other Services purchased or requested by You.
To allocate batches, communicate schedules, monitor attendance and learning progress, evaluate assignments and mock examinations, and provide faculty feedback.
To determine and administer eligibility for Course-specific features or benefits, including any “Support Until You Pass” in accordance with the Terms of Use and Course Specific Terms.
To facilitate professional-body, Partner Institute, university, awarding-body, examination or certification registration, exemptions, examination administration, membership or certification where the relevant Service includes such assistance.
To process fees, instalments, invoices, taxes, refunds, payment reconciliation and related financial administration.
To facilitate education-loan, EMI or third-party financing arrangements voluntarily selected by You.
To provide customer service, technical support, grievance handling and dispute resolution.
To detect, investigate and prevent account sharing, unauthorised access, fraud, piracy, copying, scraping, security incidents and other breaches of the Terms of Use or applicable law.
To maintain, secure, troubleshoot, analyse, improve and develop the Platform, Courses and Services.
To communicate service-related information such as class links, schedules, examination reminders, security alerts, Course changes, invoices and support updates.
To send marketing or promotional communications where permitted by applicable law and subject to available consent/opt-out choices.
To comply with legal, regulatory, accounting, tax, audit, law-enforcement and other lawful requirements, and to establish, exercise or defend legal claims.
To evaluate or complete a merger, restructuring, acquisition, financing, business transfer or similar corporate transaction, subject to appropriate safeguards and applicable law.

Where We use aggregated or irreversibly anonymised information that no longer identifies an individual, such information may be used for statistics, analytics, service improvement, academic insights or business planning, subject to applicable law.

6. LIVE CLASSES, RECORDINGS AND INTERACTIVE SESSIONS

GFTI may record live classes, webinars, doubt-clearing sessions, counselling or academic sessions and other interactive activities for purposes including providing recordings to eligible Users, academic support, quality assurance, faculty development, service improvement, security, compliance and dispute resolution.

Depending on how You participate, a recording may capture Your name, profile image, voice, video, questions, screen-shared content, chat messages or other contributions. Such recordings may be made available to other Users who are authorised to access the relevant Course, batch, subject or recording library. Accordingly, information You choose to share during an interactive session may be visible or audible to those authorised Users.

Where participation requirements permit, a User who does not wish to appear visually in a recording may keep the camera disabled and may keep the microphone muted except when speaking. Certain Courses or activities may require active participation, identity verification or camera/microphone use, in which case the applicable Course requirements or specific notice will apply.

Users must not independently record, copy, download, retransmit or distribute GFTI classes or recordings except where expressly permitted by GFTI. GFTI may use reasonable technical and administrative measures to protect recordings and investigate unauthorised copying or distribution.

7. ACCOUNT SECURITY, FRAUD PREVENTION AND ANTI-PIRACY MONITORING

User Accounts are personal and are intended for use only by the authorised User. In order to protect Users, GFTI and its intellectual property, and to enforce the Terms of Use, We may process account, device, session and access information to identify suspicious or unauthorised activity.

This may include reasonable analysis of concurrent logins, repeated device changes, unusual access patterns, abnormal downloading or viewing activity, failed-login attempts, account-security events and other indicators of credential sharing, unauthorised access, scraping, piracy or misuse. GFTI may temporarily restrict or suspend access while a suspected security or account-sharing issue is verified, in accordance with the Terms of Use and applicable law.

We may ask a User to verify identity, contact details or an authorised device where reasonably necessary to protect the Account or investigate suspected misuse. Information collected for security purposes will be used and retained only as reasonably necessary for security, compliance, investigation, dispute resolution and enforcement purposes.

8. SHARING AND DISCLOSURE OF PERSONAL DATA

We do not disclose Personal Data merely because it is commercially useful to an unrelated third party. We may share Personal Data where reasonably necessary for the purposes described in this Privacy Policy and subject to applicable law, including with the following categories of recipients:

8.1 Service Providers

We may engage Service Providers such as LMS and cloud-hosting providers, video-conferencing providers, CRM providers, IT and cybersecurity providers, payment gateways, email/SMS/WhatsApp communication providers, analytics providers, customer-support platforms, printing/logistics providers and examination/evaluation technology providers. They may process Personal Data only to the extent necessary to provide their services to Us or as otherwise permitted by applicable law and their contractual arrangements.

8.2 Partner Institutes, Professional Bodies and Examination/Certification Providers

Where required for a Course or Service selected by You, We may disclose relevant Personal Data and documents to Partner Institutes, universities, professional bodies, awarding organisations, examination bodies and certification partners for purposes such as eligibility assessment, registration, exemptions, examination administration, verification, membership, certification and related academic services.

Such organisations may process Personal Data as independent data fiduciaries/controllers for their own purposes under their rules, privacy notices and applicable law. GFTI does not control the independent privacy practices of such third parties.

8.3 Payment and Financing Partners

We may share payment, Course, enrolment or identity information with payment gateways, banks, NBFCs or financing partners to process payments, refunds, education loans, EMI facilities, fee disbursements, reconciliation, KYC/eligibility support or related services voluntarily selected by You. These entities may independently process Personal Data under their own privacy policies and legal obligations.

8.4 Affiliates and Business Operations

We may share Personal Data with Our Affiliates where reasonably necessary for central administration, technology, finance, support, Course delivery or other legitimate operational purposes, subject to appropriate safeguards and applicable law.

8.5 Professional Advisers and Authorities

We may disclose Personal Data to lawyers, auditors, accountants, insurers, consultants and other professional advisers where reasonably necessary. We may also disclose Personal Data to courts, tribunals, regulators, law-enforcement agencies, governmental authorities or other persons where required or authorised by law, legal process or a valid governmental request, or where reasonably necessary to protect rights, safety, security or property or to investigate wrongdoing.

8.6 Corporate Transactions

If GFTI is involved in or evaluating a merger, acquisition, restructuring, financing, sale of assets or transfer of all or part of its business, relevant Personal Data may be disclosed to prospective or actual transaction parties and their advisers subject to reasonable confidentiality and security measures. Where required by law, We will provide appropriate notice of any material change in the entity responsible for Personal Data.

8.7 Other Users and Public/Interactive Areas

When You voluntarily participate in live classes, group discussions, public areas, reviews, forums or similar interactive features, information You share may be visible to the relevant Users or, in a genuinely public area, to the public. You should avoid posting unnecessary Personal Data in such areas.

8.8 With Consent or at Your Direction

We may disclose Personal Data to another person where You have specifically consented to or directed the disclosure, or where another lawful ground is available under applicable law.

9. COOKIES AND SIMILAR TECHNOLOGIES

Our website and Platform may use cookies, pixels, web beacons, local storage and similar technologies to operate the Services, authenticate Users, remember preferences, protect Accounts, measure performance and understand how the Platform is used.

Depending on the technology actually deployed, categories may include:

Necessary or essential cookies required for login, authentication, security and core website functionality;
Functionality cookies that remember choices such as language, preferences or login settings;
Analytics cookies or similar technologies used to understand performance and usage trends; and
Advertising or marketing technologies, where used and where permitted by applicable law.

You may be able to control non-essential cookies through a cookie banner, preference centre or browser/device settings. Blocking certain cookies may affect Platform functionality. Where GFTI publishes a separate Cookie Policy, that policy should be read together with this Privacy Policy.

10. SERVICE COMMUNICATIONS, MARKETING, REVIEWS AND TESTIMONIALS

10.1 Service and Academic Communications

We may contact You through email, telephone, SMS, WhatsApp, in-app notifications or other contact details You provide for communications reasonably connected with Your enquiry, Account, Course or Services, including batch schedules, class links, examination reminders, Course updates, payment information, support messages and security notices. These communications are distinct from promotional marketing.

10.2 Marketing Communications

Subject to applicable law, We may send information about GFTI Courses, offers, events or related services based on Your enquiry, relationship with Us, preferences or consent. Where an opt-out is available, You may unsubscribe from promotional communications using the mechanism provided or by contacting Us. Opting out of promotional communications will not prevent necessary service, academic, transactional or security communications.

10.3 Photographs, Results, Reviews and Testimonials

Feedback and reviews You provide may be used internally to improve Our Services. We will ordinarily seek specific permission before using a student’s identifiable photograph, video, examination result, testimonial or success story in public advertising, social media or other promotional material where such permission is required by applicable law or Our stated practice. Any consent given for promotional use may be withdrawn for future use subject to applicable law and practical limitations in relation to materials already lawfully published or distributed.

11. RETENTION OF PERSONAL DATA

We retain Personal Data only for as long as reasonably necessary for the purpose for which it was collected, for compatible lawful purposes, or for a period required or permitted by applicable law. Retention periods may differ by category of data and context.

For example:

Account and Course records may be retained while the Account or Course access remains active and for a reasonable period thereafter for support, academic administration, dispute resolution and enforcement of contractual rights.
Academic, registration and certification records may be retained for the period reasonably required to administer the relevant Course, professional-body process, resit/support feature or certification requirement.
Billing, tax, invoice and financial records may be retained for the periods required by applicable accounting, tax and other laws.
Class recordings may be retained for the applicable Course-access period and such additional period as reasonably necessary for academic, quality, security or dispute-resolution purposes, after which they may be deleted, archived or anonymised in accordance with GFTI’s retention practices.
Security logs and investigation records may be retained for a reasonable period necessary to protect Accounts, investigate misuse, establish or defend claims and comply with legal obligations.
Where a complaint, investigation or legal proceeding is pending or reasonably anticipated, relevant information may be retained until the matter and applicable retention/limitation requirements are concluded.

When Personal Data is no longer required, We may securely delete it or render it non-identifying, subject to technical, backup and legal requirements.

12. CROSS-BORDER PROCESSING AND TRANSFERS

GFTI, its Partner Institutes and Service Providers may operate or use infrastructure in India or other countries. Accordingly, Personal Data may be processed or stored outside Your state or outside India where reasonably necessary for the relevant Service.

Any cross-border processing or transfer will be subject to applicable law, including the DPDP Act and any restrictions or requirements notified by the Central Government from time to time. We will take reasonable steps appropriate to the circumstances to require that Service Providers handling Personal Data on Our behalf protect it consistently with applicable contractual and legal requirements.

13. SECURITY OF PERSONAL DATA AND PERSONAL DATA BREACHES

13.1 Security Measures

GFTI takes reasonable technical and organisational measures designed to protect Personal Data against unauthorised access, disclosure, alteration, misuse, loss or destruction. Depending on the relevant systems and risks, such measures may include access controls, authentication, role-based access, secure configuration, logging and monitoring, backups, vendor controls, employee confidentiality requirements and incident-response procedures.

No method of transmission over the Internet or method of electronic storage is completely secure. Accordingly, while We take reasonable measures to protect Personal Data, We cannot guarantee absolute security. You are responsible for maintaining the confidentiality of Your Account credentials and for promptly notifying Us if You suspect unauthorised access or compromise.

13.2 Personal Data Breaches

If We become aware of a Personal Data Breach affecting Personal Data for which GFTI is responsible, We may take steps to contain, investigate, remediate and document the incident. Where required by applicable law, We will notify affected Data Principals, the Data Protection Board of India or other competent authorities in the manner and within the period prescribed by law.

14. YOUR CHOICES AND PRIVACY RIGHTS

Subject to applicable law, the statutory commencement of relevant provisions and any applicable exceptions, You may have the following rights or choices in relation to Personal Data:

to request information about Personal Data processed by GFTI and, where applicable, the identities or categories of persons with whom it has been shared;
to request correction of inaccurate or misleading Personal Data, completion of incomplete Personal Data, or updating of Personal Data;
to request erasure of Personal Data where the applicable legal conditions are satisfied and retention is not necessary for the specified purpose or compliance with law;
to withdraw consent where processing is based on consent, using a method made available by GFTI;
to raise a grievance concerning Our processing of Personal Data or the exercise of Your privacy rights; and
to nominate another individual to exercise applicable rights in the event of death or incapacity, where and when such right is available under applicable law.

Withdrawal of consent does not affect the lawfulness of processing undertaken before withdrawal. Where particular Personal Data is necessary to create or maintain an Account, deliver a Course, facilitate professional-body registration, process payment or comply with law, withdrawal or deletion may make it impossible for GFTI to continue some or all Services. In such circumstances, access may be limited, suspended or terminated in accordance with the Terms of Use and applicable law.

We may retain Personal Data notwithstanding a deletion request where retention is reasonably necessary or legally required for payments, tax/accounting, fraud prevention, security, professional-body records, dispute resolution, contractual enforcement, legal claims or another lawful purpose.

14.1 How to Exercise a Privacy Right

You may contact Us using the details in Section 18. We may request information reasonably necessary to verify Your identity, authority and the scope of the request before acting on it. This is intended to protect Users from unauthorised disclosure, correction or deletion of their information.

14.2 Responsibilities When Exercising Rights

When exercising privacy rights, You must provide authentic information, must not impersonate another person, and must not knowingly submit a false or frivolous request or grievance. These requirements apply subject to applicable law.

15. USERS BELOW 18 YEARS OF AGE

Certain professional-programme Courses may be suitable for Users aged 15 to 17. Where a User is below 18 years of age and applicable law requires parental or lawful-guardian consent or involvement, the User may enrol or use the relevant Services only with the required consent or involvement of a parent or lawful guardian.

GFTI may request information or take reasonable steps to verify the age of the User and the identity or authority of the parent or guardian where required by applicable law. GFTI will not knowingly undertake tracking or behavioural monitoring of children, or targeted advertising directed at children, in a manner prohibited by applicable law.

If a parent or lawful guardian believes that a child has provided Personal Data to GFTI without the consent required by law, the parent or guardian should contact Us using the details in Section 18. We may take reasonable steps to verify the request and take appropriate action in accordance with applicable law.

16. THIRD-PARTY WEBSITES, PLATFORMS AND SERVICES

The Platform or Course materials may contain links to third-party websites, professional bodies, examination portals, payment providers, video-conferencing platforms, Partner Institutes or other services not controlled by GFTI. Those third parties may collect or process Personal Data independently under their own terms and privacy policies.

GFTI is not responsible for the privacy practices, security or content of independent third-party services. You should review the privacy notice of a third party before providing Personal Data directly to it.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in Our Services, technology, business practices or applicable law. The updated version will carry a revised “Last Updated” date and may be posted on the Platform.

Where a change materially affects the way We process Personal Data, We may provide additional notice through the Platform, email or another appropriate communication. Where applicable law requires fresh consent for a new or changed processing purpose, We will seek such consent before carrying out the processing to which that consent requirement applies.

18. PRIVACY AND GRIEVANCE CONTACT

If You have a question, request or grievance concerning this Privacy Policy or GFTI’s processing of Personal Data, You may contact:

Designation : Grievance Redressal Officer

Email : pr*****@*******ti.com

Physical Address : GLOBALFTI Pvt. Ltd.
#806, Souravya, 10th-A Main Road, Indiranagar 1st Stage, Bengaluru – 560038, Karnataka, India.

Through Website : Contact Us

We may require You to first use Our internal grievance mechanism before approaching a regulatory authority where applicable law so requires. GFTI will endeavour to respond to privacy grievances within the period required under applicable law and, where no statutory period applies, within a reasonable period having regard to the nature of the request.

19. LAST UPDATED

This document was last updated on 18 September 2026.

Document Version : GFTI_Privacy Policy_18Sep2026_V2.0