Privacy PolicyYour privacy is important to us, and the Cactus Communications Group (“CACTUS,” “theCompany,” “we,” “our,” or “us”) is committed to protecting your privacy whilst providing apersonalized and valuable service.
Here at CACTUS, we are committed to safeguarding your data while rendering our professional
services. Editage is a brand and division of CACTUS India that operates through various group
entities including, but not limited to, entities located in Singapore, Japan, China, Korea, theUnited Kingdom, and the United States.
This Privacy Policy governs our data collection, processing, and usage practices. It is designed toallow the Data Subject (“you”) to make an informed choice regarding use, access, andcorrection of your Personal Information.
If you have any requests concerning your Personal Information or any queries about thesepractices, please contact us by e-mail on privacy@cactusglobal.com or you can contact us bywriting to Cactus Communications Private Limited, 510, Shalimar Morya Park, Off Link Road,Andheri (West), Mumbai 400053, Maharashtra, India.
1. Personal Data That We Collect
We collect from you Personal Information such as full name, gender, date of birth, address, jobtitle, company information, e-mail addresses, telephone numbers, identification details, andreferral source, and if you are a Service Provider, we will also collect payment information(including bank, credit/debit card details, and electronic payment ids) billing address, and workand education profile. This data may include IP Address, operating system, and browser type.
We may also have acquired your Personal Information from a third-party Service Provider or
publicly available data source.
2. How We Use Your Personal Data
As Data Controller:
We use the information we collect only in compliance with this Privacy Policy. We will never sell
your Personal Information to any third party without your explicit consent. In addition to theuses identified elsewhere in this Privacy Policy, we may use your Personal Information to (a)assist you with service, partnership, or employment request; (b) send to you information that
we think may be of interest to you by post, email, or other means; (c) send you marketing
communications relating to our business (including any profiling we engage in that is related tosuch direct marketing); (d) respond to an enquiry, question, or concern that you may haveraised; or (e) perform analytics and create a database to improve your browsing experience andenhance the functionality of our services.

We may share Personal Information with trusted Service Providers or our group companies forpayment processing, supplementing the information you provide us in order to provide youwith better service, perform statistical analysis, provide marketing assistance, host the site andindex user profile pages and usernames as part of the URL and customer support. Such thirdparties are prohibited from using your Personal Information except for these purposes, andthey are required to maintain the confidentiality of your information. If you do not want us toshare your Personal Information with these third parties, contact us at
privacy@cactusglobal.com.
To facilitate our global operations, we may transfer and access Personal Information fromaround the world. This Privacy Policy shall apply even if we transfer Personal Information tocountries outside the European Union.
After you place an order on our Website, you will need to make payment for the services you
have ordered. In order to process your payment, we use a number of third-party payment
processors. Your payment will be processed by the payment provider you choose to process
your payment via a payment gateway.
If you give us banking, debit card, credit card, or other payment mode details, we solely use
such details to process refund of payment to you. The third-party payment processors we use
also collect, use, and process your information, including payment information, in accordancewith their privacy policies.
To ensure that the security and integrity of the Site is safeguarded, CACTUS may monitor your
Personal Information. CACTUS may under certain circumstances engage a trusted third-party
Service Provider for the purpose of managing the technical operations involved in hosting theSite. Information you submit to us via the contact form on our Website will be stored outside
the European Economic Area on our third-party hosting provider’s servers in Singapore. To
the extent that it may be necessary, and solely for the purposes of providing the service
available on the Site to you, we may disclose to such third party any of your Personal
Information that may be necessary for the procurement of services from the third party.
As Data Processor:
We shall use and process the information or data we collect through Data
Controllers/Controllers (“Business Partner”) as per the instructions given by Controllers and incompliance with the terms and conditions applicable to Processors under Controller/Processor
Binding Agreement entered with the Controllers and applicable Regulation. We agree not toprocess such information to sub-processors (Sub-contractor), unless prior written consent issought from the Controller, and in the event where general consent has been given by theController, we shall inform the Controller of any new sub-processor. We shall have the same
contractual obligations reflected with the sub-processors as agreed with the Controller andassume complete responsibility for the actions and inactions of such sub-processors.
Upon written request from the Controller, we agree to delete or return all the Personal
Information or data to the Controller after the end of the provision of services relating toprocessing, unless there is a legal obligation or basis for us to retain a copy of such information

or data for further processing. The information or data collected through the Controller will be
stored outside the European Economic Area on our third-party hosting provider’s servers.
In addition to implementation of appropriate technical and organizational measures to ensure
an appropriate level of security, we shall make available to the Controller all informationnecessary to demonstrate compliance with our obligations, and allow the Controller or anotherauditor appointed by the Controller for conducting audits, including inspections, todemonstrate that processing meets the requirements of the Regulation, and ensure theprotection of the rights of the data subject.
3. Children’s Personal Information
CACTUS does not knowingly collect any Personal Information from children under the age of 18.
If you are under the age of 18, please do not submit any Personal Information through ourWebsites or Service(s). We encourage parents and legal guardians to monitor their children’s
Internet usage and to help enforce this Policy by instructing their children never to provide
Personal Information through our Service(s) or Websites without their permission. If you havereason to believe that a child under the age of 18 has provided Personal Information to us
through our Websites or Service(s), please contact us at privacy@cactusglobal.com, and we will
endeavor to delete that information and terminate the child’s account from our databases.
4. Retention of Personal Information
We retain Personal Information that you provide us as long as an Account is active or as needed
to provide the Service(s) or as necessary to comply with our legal obligations, maintain accurate
financial and other records, resolve disputes, and enforce our agreements. If you wish toterminate your Account or request that we no longer use Your Personal Information, pleasecontact us at privacy@cactusglobal.com.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking
into account the following:•the purpose(s) and use of your information both now and in the future (such as whether
it is necessary to continue to store that information in order to continue to perform ourobligations under a contract with you or to contact you in the future);•

whether we have any legal obligation to continue to process your information (such as
any record-keeping obligations imposed by relevant law or regulation);•whether we have any legal basis to continue to process your information (such as yourconsent);•

how valuable your information is (both now and in the future);•

any relevant agreed industry practices on how long information should be retained;•the levels of risk, cost, and liability involved with us continuing to hold the information;•

how hard it is to ensure that the information can be kept up to date and accurate; and•any relevant surrounding circumstances (such as the nature and status of ourrelationship with you).

5. Use of Cookies & Similar Technologies
Cookies are data files that are sent from a website to a browser to record information aboutusers for various purposes.
We use cookies, including essential, functional, and analytical cookies. For further information
on how we use cookies, please see our cookies policy.
You can reject some or all of the cookies we use on or via our Website by changing yourbrowser settings, but doing so can impair your ability to use our Website or some or all of its
features. For further information about cookies, including how to change your browser settingsand other ways in which you can reject cookies, please visit www.allaboutcookies.org or see
our cookies policy.
6. Social Media Features
Some of our Websites, namely, www.editage.com/insights, include social media features, suchas Facebook, LinkedIn, Twitter, and Orcid, the “Share This” button, or interactive miniprograms. Where we have your consent, these features may collect your IP address and which
page you are visiting on our Websites, and may set a cookie to enable the feature to function
properly. Social media features and widgets are either hosted by a third party or hosted directlyon our Websites. Your interactions with these features are governed by the privacy policy ofthe company providing them.
7. Security of Your Personal Information
CACTUS has put in place the following security practices and procedures to protect your
Personal Information from unauthorized access, use, or disclosure:a)

We secure the Personal Information you provide on computer servers in a controlled,secure environment, protected from unauthorized access, use, or disclosureb)

All our Information security processes are ISO/IEC 27001:2013 compliant.

c)

All our employees and Service Providers have signed confidentiality agreements where
they have undertaken that they will not make any Personal Information available toanyone, unless authorized in writing by the user.

d)Personal Information will not be made available to any third party, except as provided
herein or by obtaining your prior written consent.

e)

All documents submitted are managed through a secure online job management
system; the documents that are sent to us can only be viewed by service professionals
working on your assignment.

f)Payment-related Personal Information:i.

The Site uses Secure Socket Layer (SSL) encryption when accepting paymentrelated Personal Information, to ensure that your payment-related PersonalInformation is secure.

ii.

In order to protect your credit card information, all online transactions areconducted using a secure 256-bit SSL encryption signed by VeriSign. Encryption
ensures that no information is accessible to unknown parties. CACTUS hereby
undertakes not to store your credit card information, thereby reducing thepossibility of fraudulent charges being made by CACTUS.

8. Hyperlinks
Our Company Websites contain links to other websites, including without limitation thosewebsites of other companies within the CACTUS group. Their inclusion cannot be taken to imply
any endorsement or validation by us of the content of the said websites. We are notresponsible for the privacy practices nor do we accept any liability about the content of suchwebsites including those of our group companies that have their own privacy policies tailored
for the business practices and sectors in which they operate.
9. Testimonials & Public Forums
9.1.

We post on our Websites customer testimonials/comments/reviews that may contain
Personal Information. Prior to posting the testimonial, we obtain the customer’s
consent to post their name along with their testimonial. If you want your testimonialremoved, please contact us at privacy@cactusglobal.com.

9.2.

Our Websites offer publicly accessible blogs, community forums, or discussion boardposts. You should be aware that any information you provide in these areas may beread, collected, and used by others who access them. You agree and acknowledge thatthe use of such information is not confidential, does not constitute Personal
Information, and is not subject to protection under CACTUS’s Privacy Policy.

10. Corporate Events
In the event CACTUS goes through a business transition, such as a merger or acquisition byanother company, or sale of all or a portion of its assets, your user account and personal data
will likely be among the assets transferred. You will be notified via a prominent notice of any
such change in ownership or control. During such event, we may also disclose your Personal
Information to any other third party with your prior consent.
11. Responsibility with You
When you submit any Personal Information to us, you represent that you have the lawful rightto submit the Personal Information and agree that you will not submit any information unless
you are legally entitled to do so and that such Personal Information is true, complete, andaccurate. You may not use a false email address or other identifying information toimpersonate any person or entity, or otherwise mislead as to the origin of any content. Anyimproper collection or misuse of Personal Information is in violation of this Privacy Policy and of
the applicable terms and conditions of use. You agree not to misuse any Personal Information
available on our Site or to gather it or use robots or other automated scripts, codes, orfunctionalities to do so. We may immediately suspend or terminate your access to our Site
without notice if we become aware that you are in breach of applicable terms and conditions ofuse or of this Privacy Policy.
12. Opting Out and Unsubscribing
12.1. Reviewing, Correcting, and Deletion of Your Personal Information
Upon request, CACTUS will provide you with information about whether we hold any ofyour Personal Information. We allow users of the Service(s) or Website to access,update, or modify their information by clicking on the My Account link in the CACTUS
navigation menu. If you provide us with your Personal Information, you have thefollowing rights with respect to that information:To review the user information that you have supplied to usTo request that we correct any errors, outdated information, or omissions in user
information that you have supplied to usTo request that your user information not be used to contact you

To request that your user information be deleted from our records

To withdraw your consent to our use of your information; please note that if you
withdraw your consent, this will not affect the lawfulness of our use and processing ofyour information on the basis of your consent before the point in time when youwithdraw your consent
To exercise any of these rights and requests, please contact us at privacy@cactusglobal.com or by postal mail to Cactus Communications Private Limited, 510,Shalimar Morya Park, Off Link Road, Andheri West, Mumbai 400053, India, Attention:
Privacy Team. We will respond to your request within reasonable timeframe and notify
you of the action we have taken.

12.2. To Unsubscribe from Our Communications
Your registered email address will be automatically subscribed to our weekly
newsletter, which will contain information on industry updates, author resources,upcoming webinars, latest offers, and new services by CACTUS. You may unsubscribefrom our marketing communications by clicking on the “unsubscribe” link located on
the bottom of our e-mails, or by sending us an email at privacy@cactusglobal.com.
Customers cannot opt out of receiving transactional emails related to their accountwith us.

13. Sensitive Personal Information
What Is Sensitive Personal Information?
“Sensitive Personal Information” is information about an individual that reveals their racial orethnic origin, political opinions, religious or philosophical beliefs, trade union membership,
genetic information, biometric information for the purpose of uniquely identifying anindividual, information concerning health, or information concerning a natural person’s sex life
or sexual orientation.
We do not knowingly or intentionally collect sensitive Personal Information from individuals,
and you must not submit sensitive Personal Information to us.
If, however, you inadvertently or unintentionally transmit sensitive Personal Information to us,
you will be considered to have explicitly consented to us processing that sensitive PersonalInformation.
14. Amendments to Privacy Policy
We may update this Privacy Policy from time to time to keep up with changing legislation andbest practices. If we make any material changes, we will notify you by email (sent to the e-mailaddress specified in your account) or by means of a notice on the Website prior to the change
becoming effective. Provided that we will not notify you if we amend the Policy to makeaddition, deletions, or modifications to the list of cookies from time to time, to keep the list of
cookies current and accurate. Your continued use of this Websites or the Service(s) following
the posting of any amendment, modification, or change to this Policy shall constitute youracceptance of the amendments to this Policy. You can choose to discontinue use of theWebsites or Service(s) if you do not accept the terms of this Policy or any modified version ofthis Policy.
15. Legal Disclosure
We reserve the right to disclose your personal data as required by applicable law, in response
to lawful requests by public authorities, including meeting national security or law enforcement
requirements and when we believe that disclosure is necessary to protect our rights and/or tocomply with a judicial proceeding, court order, or other legal process served on us.
16. Contact Us
If you have any questions about this Privacy Policy or the data we hold about you or you wish toensure that the data we hold about you is accurate and kept up to date, please do not hesitate
to contact us at privacy@cactusglobal.com.
Effective Date: May 25, 2018