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Privacy Policy

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FSN Solutions Limited — Global Technology Institute

Privacy Policy

Bangladesh Operations

1Preamble and Organization Identity

FSN Solutions Limited, operating its Global Technology Institute under the brand name “FSN-GTI,” is a technology education enterprise registered and incorporated in Bangladesh.

Registered Address: Plot-16, Road-3, Sector-4, Uttara, Dhaka-1230, Bangladesh
TIN: 548003768245

This Privacy Policy (“Policy”) governs FSN-GTI’s collection, processing, storage, use, disclosure, and retention of personal data in connection with its operations in Bangladesh, including through its website at https://fsn-gti.com, its training programs, enrollment and payment systems, and all other services.

FSN-GTI acts as the Data Controller for all personal data processed under this Policy. FSN-GTI collects and processes only the minimum personal data necessary for the stated purposes. Where required under applicable law, explicit consent will be obtained prior to processing.

By accessing our website, enrolling in any program, or otherwise interacting with our services, you acknowledge that you have read, understood, and consent to the practices described in this Policy.

2Definitions

“Personal Data”Any information relating to an identified or identifiable natural person, including name, address, email, phone number, financial details, login credentials, and device identifiers.
“Sensitive Personal Data”A subset of personal data warranting heightened protection, including biometric data, financial account and payment card information, national identification numbers, health or medical information.
“Processing”Any operation performed on personal data, whether automated or manual, including collection, recording, storage, use, disclosure, restriction, erasure, or destruction.
“Data Controller”FSN-GTI, the entity that determines the purposes and means of processing personal data.
“Data Processor”A third party that processes personal data on behalf of and under the instructions of FSN-GTI.
“Consent”A freely given, specific, informed, and unambiguous indication of agreement to the processing of personal data, given by a clear affirmative act.
“Data Breach”Any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.
“Grievance Officer”The designated representative of FSN-GTI in Bangladesh responsible for receiving and addressing privacy complaints from data subjects.

3Information We Collect

3.1 Personal Data You Provide to Us

a)Full legal name
b)Email address
c)Mobile phone number (including country code)
d)Billing address and payment information (credit/debit card details, bKash or other MFS credentials, bank transfer details)
e)National ID number or Passport number (where required for certification)
f)Account login credentials (username and password in encrypted form)
g)Enrollment and course completion records
h)Correspondence and communications submitted to FSN-GTI
i)Photographs or identity documents submitted for verification

3.2 Sensitive Personal Data

a)Financial account information, payment card data, and MFS credentials
b)Biometric data, where collected for identity verification
c)Government-issued identification numbers
FSN-GTI will only collect sensitive personal data where strictly necessary and will obtain explicit consent before doing so.

3.3 Data Collected Automatically

a)IP address
b)Browser type, version, and language settings
c)Device type, operating system, and screen resolution
d)Pages visited, time and date of access, and session duration
e)Referring website or URL
f)Cookie identifiers and similar tracking data

3.4 Data from Third Parties

We may receive personal data from payment gateway providers, BHTPA-affiliated universities, and referral sources, subject to those parties’ own privacy obligations and our lawful basis for processing.

4Legal Basis for Processing

a)Consent: Freely given, specific, informed, and unambiguous. You may withdraw consent at any time without detriment to core services.
b)Contractual Necessity: Processing necessary for enrollment, payment processing, and course delivery.
c)Legal Obligation: Required by Bangladeshi law, including the Cyber Protection Ordinance 2025, tax laws, and BHTPA requirements.
d)Legitimate Interests: Website security, fraud prevention, and service improvement, provided these do not override your rights.
e)Vital Interests: Where necessary to protect the vital interests of a person in emergency circumstances.

5How We Use Your Personal Data

5.1 Service Delivery and Administration

Enrolling learners; processing payments and issuing receipts; managing accounts, attendance, and course progress; issuing certificates and credentials; facilitating laboratory access through BHTPA-partnered universities.

5.2 Communications

Responding to inquiries; sending essential service communications (enrollment confirmations, payment receipts, schedule updates); sending promotional communications only where you have provided explicit opt-in consent.

To opt out of marketing at any time, click “Unsubscribe” in any marketing email, or send a request to info@fsn-gti.com. Opt-out requests are processed within five (5) working days.

5.3 Legal and Regulatory Compliance

Complying with BHTPA reporting obligations; responding to lawful requests from law enforcement; complying with tax and accounting obligations; enforcing our Terms and Conditions.

5.4 Service Improvement and Analytics

Analyzing usage patterns to improve website functionality and course design; conducting internal research and quality assurance; detecting and preventing fraud and unauthorized access. We will not use your data for any materially different purpose without prior notice and, where required, your consent.

6Cookies and Tracking Technologies

6.1 Types of Cookies We Use

Strictly NecessaryRequired for the Website to function — session management, login, payment security. Cannot be disabled.
FunctionalEnable enhanced functionality such as remembering language preferences and login details.
AnalyticsCollect anonymized information about how visitors interact with our Website. Used only in aggregate form.
MarketingUsed only where you have provided explicit consent to receive personalized promotional content.

6.2 Managing Cookies

You may control or disable non-essential cookies through your browser settings or our cookie consent tool. Disabling strictly necessary cookies will impair core functionality.

7Disclosure and Sharing of Personal Data

FSN-GTI does not sell, rent, or trade your personal data to any third party for commercial gain.

7.1 Service Providers and Data Processors

We may share data with trusted third-party vendors including payment gateways, cloud hosting providers, email service providers, LMS platform providers, and analytics providers. All are contractually bound to process data only on FSN-GTI’s instructions and implement appropriate security measures.

7.2 Law Enforcement and Legal Proceedings

FSN-GTI may disclose personal data when required by law. We will, to the extent permitted by law, notify affected data subjects.

7.3 Protection of Rights and Safety

We may disclose personal data where reasonably necessary to protect the rights, safety, or property of FSN-GTI, our learners, or the public.

7.4 Corporate Restructuring

If FSN-GTI undergoes a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction with prior notice.

8Cross-Border Data Transfers

Where personal data is transferred outside Bangladesh, FSN-GTI ensures appropriate safeguards are in place, including contractual data protection clauses, or that the transfer is permitted under applicable law.

Data Localization: For restricted personal data (as defined under the PDPO), FSN-GTI maintains at least one synchronized real-time copy within Bangladesh, per Section 29(7)(b) of the PDPO.

Prior Regulatory Approval: Bulk cross-border transfers of sensitive personal data (NID numbers, passport numbers, TINs, biometric data, genetic data) require prior NDMA approval.

Transition Period: Certain PDPO enforcement provisions take effect approximately May 2027. FSN-GTI is actively aligning its infrastructure ahead of that date.

9Data Security

FSN-GTI implements comprehensive security measures including:

🔒Encryption of sensitive data in transit (TLS) and payment card data at rest (PCI-DSS)
🔒Access controls and role-based permissions
🔒Regular security assessments, vulnerability scans, and penetration testing
🔒Multi-factor authentication for administrative access
🔒Employee training on data handling and phishing prevention
🔒Incident response procedures for detecting, containing, and reporting breaches

9.1 Data Breach Notification

In the event of a data breach, FSN-GTI will: (1) notify the relevant regulatory authority within 72 hours where required by law; (2) notify affected data subjects without undue delay where the breach poses a high risk; and (3) maintain an internal breach record. While we take all reasonable steps to protect your data, no method of internet transmission is completely secure.

10Data Retention

Data Category Retention Period
Learner enrollment and course records 7 years from completion
Payment and billing records 7 years (tax/VAT compliance)
Account login and authentication data Duration of account + 2 years
Marketing opt-in/opt-out records 5 years or until consent withdrawn
Security logs and access records 2 years from log generation
Data breach records 5 years from date of breach
Correspondence and support records 3 years from last interaction

At the expiry of the applicable retention period, personal data will be securely deleted or anonymized. Where legal proceedings are ongoing, relevant data may be retained beyond these periods.

11Your Rights as a Data Subject

Right of AccessRequest confirmation of whether we hold personal data about you and receive a copy.
Right to RectificationRequest correction of inaccurate or incomplete personal data.
Right to ErasureRequest deletion of your data where it is no longer necessary or where consent is withdrawn.
Right to Restrict ProcessingRequest that we limit the processing of your data in certain circumstances.
Right to Data PortabilityReceive your data in a structured, machine-readable format and transmit it to another controller.
Right to Withdraw ConsentWithdraw consent at any time without affecting the lawfulness of prior processing.
Right to Object to MarketingObject at any time to processing of your data for direct marketing purposes.
Right to Lodge a ComplaintLodge a complaint with FSN-GTI’s Grievance Officer or the NDMA.

To exercise any of the above rights, submit a written request to our Grievance Officer. We will respond within thirty (30) days. In complex cases, this may be extended by sixty (60) days with notice.

12Children’s Privacy

FSN-GTI’s programs are designed for adult learners. We do not knowingly collect personal data from individuals under eighteen (18). Where BHTPA university programs may be attended by individuals aged sixteen (16) to eighteen (18), enrollment is conditional upon verified parental or guardian consent obtained in writing. If we become aware that a child’s data was collected without appropriate consent, we will promptly delete it.

13Grievance Officer and Complaint Resolution

Grievance Officer — FSN-GTI Bangladesh Operations
Email: info@fsn-gti.com
Phone: +880 1602-058897
Address: Plot-16, Road-3, Sector-4, Uttara, Dhaka-1230, Bangladesh
Response Time: Within 30 days of receipt

Upon receipt of a complaint, the Grievance Officer shall: (a) acknowledge within five (5) working days; (b) investigate; (c) issue a substantive response within thirty (30) days; and (d) escalate unresolved complaints to the NDMA.

14Third-Party Links and External Services

Our Website may contain links to external websites not operated by FSN-GTI. This Policy applies solely to FSN-GTI’s operations. We encourage you to review external privacy policies. Where we embed third-party tools (payment gateways, video conferencing, social media plugins), those tools may independently collect data from you, and we will disclose their use and, where applicable, obtain your consent.

15Amendments to This Privacy Policy

FSN-GTI may amend this Policy at any time. Material amendments will be communicated via email at least thirty (30) days prior to taking effect. All amendments will be posted on our Website with an updated effective date. Where an amendment requires fresh consent, we will seek it separately.

16Governing Law and Jurisdiction

This Policy is governed by the laws of Bangladesh. Data subjects may seek redress through:

a)FSN-GTI’s Grievance Officer as a first step;
b)The Bangladesh Computer Council or the NDMA;
c)The Cyber Tribunal under the Cyber Protection Ordinance, 2025;
d)The Consumer Rights Protection Directorate (CRPD).

Contact Information

FSN Solutions Limited (FSN-GTI)

Website: https://fsn-gti.com

Email: info@fsn-gti.com

Phone: +880 1602-058897

Address: Plot-16, Road-3, Sector-4, Uttara, Dhaka-1230, Bangladesh

TIN: 548003768245


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