1. INFORMATION RECEIVED, COLLECTED AND STORED BY THE COMPANY
We collect and process some or all of the following type of information in the course of you using our Services. The type of information we collect will depend on the circumstances and the Service you are using. Generally speaking, the information about the user as collected by the Company is: (a) data supplied by users and (b) data automatically tracked while navigation (c) data collected from any other source (collectively referred to as “Information”).
(a). Information Supplied by Users
(i) Registration Data
This Information includes, but is not limited to, basic contact information provided by you on our Website, which may include your name, mobile number, address, e-mail address, data of birth, demographical information, gender, interests, preferences, place of work, position, country. For example, the Company may collect personal Information when you register on the Website, to subscribe to our Services or for requesting further information. It can also include information that we have not requested but which you have volunteered, such as information provided during interactions via comments or other submissions you have made to our online Services, such as online forums, in response to a survey, while requesting certain Services or products, or to enter a sweepstakes, contest, or other promotion.
When you register using your other accounts like on Facebook, Twitter, Gmail etc. we shall retrieve Information from such account to continue to interact with you and to continue providing the Services.
In case you choose to decline to submit personal Information on the Website, the Company may not be able to provide certain sites / content / apps / services / features to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal Information.
(ii) Subscription or Paid Service Data
You may choose to purchase any subscription or paid Service using a credit card, e-wallet or any other electronic payment system. When you chose any subscription or paid Service, we or our payment system provider may collect your purchase, address or billing information, including your credit card number and expiration date, etc. (“Payment Information”). However, when you order using an in-app purchase option, same are handled by such platform providers. Typically, the Payment information is provided directly by users, via the Website, into the PCI/DSS-compliant payment processing service to which the Company subscribes, and the Company does not, itself, process or store the Payment Information, except as stated herein.
The subscriptions or paid Services may be on auto renewal mode unless cancelled. If at any point you do not wish to auto-renew your subscription, you may cancel your subscription before the end of the subscription term.
This Payment Information is used to provide you your requested Services, to manage your account, to communicate with you, and enforce any terms of service or agreement related to the Website. We use any Payment Information we acquire from you only to fulfill your order.
(iii) Information about other Individuals
(b) Information automatically tracked while navigation
When you use our Services, we automatically record Information about your usage of those Services, your interaction with our emails as well as information about the device you are using and your internet connection. We do this in the following ways:
(ii) Log File Information
We automatically collect limited information about your computer’s connection to the Internet, mobile number, etc., when you visit the Website / Service. We automatically receive and log information from your browser, including your computer’s name, your operating system, browser type and version, IP address, CPU speed, and connection speed. We may also collect log information from your device, including your location, IP address, your device’s name, device’s serial number or unique identification number (e.g. UDiD on your iOS device). If you access the Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geo-location data, or other transactional information for that device.
(iii) Clear GIFs
Besides web beacons, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. We use this information to inter-alia to measure traffic within the Website / Service to improve the Website / Service quality, functionality and interactivity and let advertisers know the geographic locations from where our visitors come.
(c) Information collected from any other source
(i) Information from other Sources: Demographic & Purchase Information
We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use analytical tools to track the user behaviour on our Website. These tools have been enabled to support display advertising towards helping us gain understanding of our users’ demographics and interests. The reports are anonymous and cannot be associated with any individual personally identifiable Information that you may have shared with us.
(ii)Advertisements& Purchase Information
2. INFORMATION USE BY THE COMPANY
We use Information held about you for our legitimate business interests for the following purposes:
(i) To provide you Services including associated functionalities whether by us or by our designated representatives and/or business partners to you or to parties designated by you and any and all matters ancillary thereto including to carry out obligations from any contracts entered into between us. We rely on performance of our contract with you so as the legal basis for such processing;
(ii) To verify and process payment when you subscribe to, purchase and/or obtain Services from any of our Website. We rely on performance of our contract with you so as the legal basis for such processing;
(iii) For verification and record of your personal particulars, to authenticate you so that we know it is you and not someone else which includes comparing it with Information from other sources and using the Information to communicate with you. We rely on performance of our contract with you so as the legal basis for such processing;
(iv) To conduct market research and statistical analysis of the users of the Website including the number of users, the frequency of use, profile of users and using such analysis for our business plans, the enhancement of our products and services, targeted advertisements and conveying such Information in broad terms (but not information in relation to specific individuals) to third parties who have or propose to have business dealings with us. We rely on legitimate business interests as the legal basis for such processing and the legitimate interest is the analyzing the use of the Services and improving the same;
(v) To send you Information, promotions and updates including marketing and advertising materials in relation to our Services and those of third party organizations selected by us. We will only do this where we reasonably believe that our Services may be of interest to you and you consent to being provided with such information. We rely on legitimate business interest as the legal basis to promote our Services to you as the legal basis for this processing;
(vi) To prevent fraud or other potentially illegal activities (including copyright infringement) and to block disruptive users and protect the safety of users of our Services. The legal basis for this processing is our legitimate business interests being the proper protection of our business against risks and
(viii) To enforce our terms of Service. The legal basis for this processing being the protection and assertion of our legal rights and the legal rights of others.
In any case, if you would prefer that we do not use your Information to market or promote our products and Services to you, please either (i) tick the relevant box on the form through which we collect your Information (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) contact us at the contact details set out below:
3. Sensitive Personal Information
Unless specifically requested, we ask that you not send us, and you shall not disclose, on or through the Services or otherwise to us, any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, national identification numbers, social security numbers, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
4. DISCLOSURE OF PERSONAL INFORMATION AND OTHER INFORMATION
(a)Information Shared with Group Companies and Affiliates
The Company may share Information with its employees, agents, officers, group companies, the employees, agents and officers of such group companies and our affiliates (including affiliated websites under common ownership or control) for the purpose of processing Information on its behalf.
(b)Information shared with Third Parties and Sponsors
(i) The Company may share with other third parties Information about our Website users, such as your use of the Website or other websites, and the Services provided on the Website or other websites, but only on an anonymous and aggregate basis to help us develop content, services, and advertising that we hope you will find of interest. The Company may also share your Information with a sponsor or other third party (“Third-Party Provider”) to perform Site-related services, including database management, maintenance services, analytics, marketing, data processing, and email and text message distribution. These third parties have access to your Information only to perform these tasks only on our behalf.
(c)Information shared via third party social buttons, widgets and other embedded content
Further, we use third-party advertising companies to serve ads when you visit or use the Website or Services. These companies may use Information (not including your name, address, email address or telephone number) about your visits or use to particular website, mobile application or services, in order to provide advertisements about goods and services of interest to you.
(d)Information shared with Other Parties
The Company may also disclose your personal and other Information to unaffiliated third parties if we believe in good faith that such disclosure is necessary: (i) to comply with the law or in response to a subpoena, court order, search warrants, judicial proceedings, other legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims; (ii) to protect the interests, rights, safety, or property of the Company or others; (iii) to enforce any terms of service on the Website; (iv) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential, or as otherwise required by law; (v) to provide you and other users of the Website with the Services or products requested by you and/or the other users, and to perform other activities related to such Services and products, including billing and collection; (vi) to provide you with special offers or promotions from the Company that may be of interest to you; or (vii) to operate the Company’s systems properly.
(f)Sale or Transfer of all or part of Business of Company
If the Company sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, the Company may transfer your Information to the party or parties involved in the transaction as part of that transaction.
In addition to the scenarios identified above, we may share Information about you for any other purposes disclosed to you at the time we collect your Information or pursuant to your consent.
(h) Some General Exceptions to Disclosures
The collection, further use, and/or disclosure of your Information by Third-Party Providers or by other third parties is not the responsibility of the Company. Rather, such collection, use, and/or disclosure is governed by the Third-Party Providers’ privacy policies.
b) Any personally identifiable Information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, Twitter etc.
The above exceptions are not exhaustive and will include exceptions available in law as well as otherwise.
5. SECURITY OF PERSONAL INFORMATION
Any personal Information you provide to Company is kept on secure servers with limited access. The Company uses reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal Information against loss, theft, unauthorized use or access, disclosure, or modification; and (b) to ensure the integrity of the personal Information.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that Information you supply will not be intercepted while being transmitted to us over the Internet, any transmission is at your own risk. And, of course, any Information you include in a posting to the discussion areas is available to anyone with Internet access.
Remember that even after you cancel your account, copies of some Information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services and such Information is outside the Company’s control. Further, if you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us.
6. TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES
7. RIGHTS AVAILABLE TO YOU
You have a number of important rights free of charge. In summary, those include rights to:
a) Access and updating your Information – When you use the Services or the Website, we make good faith efforts to provide you, as and when requested by you, with access to your Information. Further, if there is any change in your Information, you may update it by accessing the relevant page of the Website, or by contacting us. If you have any questions about how we use the Information collected which relates to you, please contact us. We will endeavour to update your Information within 14 working days of any new or updated Information being provided to us, in order to ensure that the Information we hold about you is as accurate and up to date as possible;
b) Require us to correct any mistakes in your Information – In such case we shall ensure that any Information or data found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such Information to be retained by law or for legitimate business purposes;
c) Require the erasure of your Information in certain situations;
d) Require us to restrict processing or object at any time to processing of personal Information in certain situations;
e) Receive the personal Information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations;
f) Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
g) Object in certain other situations to our continued processing of your personal Information;
h) Otherwise restrict our processing of your personal Information in certain circumstances.
We ask individual users to identify themselves and the Information requested to be accessed, corrected or removed before processing such requests or inform other limitations you would like to put on our use of your personal Information. If you would like to exercise any of those rights, please:
email, call or write to us and provide us enough information to identify you [(e.g. account number, user name, registration details)],
let us know the Information to which your request relates.
We may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable. Please note that we often need to retain certain data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. Further, because of the way we maintain certain services, after you delete your Information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.
The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you keep using the Services)
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)
9. CHILDREN USING OUR SERVICES
Except where otherwise indicated, we do not knowingly collect or store any personal Information from children under the age of 13. If you are aged 13 or under, we request that you do not provide us with Information relating to you or to others. Please seek the guidance of your parent or guardian before using our Services.
If you are the parent or guardian of a child who is aged under 16 and you become aware that your child has provided us with information without your consent, please contact us as given below. We will delete such information from our records within a reasonable time.
Depending on the service, we may also seek to obtain the consent of your parent or guardian if you are under the age of 18.
11. QUESTIONS / GRIEVANCE REDRESSAL
Redressal Mechanism: Any complaints. or concerns with regards to the processing of information provided by you or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing by email to email@example.com.
We request you to please provide the following information in your complaint:
a) Your address, telephone number and e-mail address;
b) A statement, under penalty of perjury, that the information in the notice is accurate;
The company shall not be responsible for any communication, if addressed, to any non-designated person in this regard.
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