With effect from [13th Oct 2022]
- The Company may collect information from you from both online and offline sources. The Company collects information from you on the Website through the Register/Sign-up/Log-in page or any other page on the Website, if applicable. On the Register/Sign-up/Log-in page, and other pages on the Website, you may be required to give your contact information (such as name, mobile number, email ID etc.), and certain other details. Further, the Company also collects information about you based on your Website use and order placement and may also collect information from you through offline sources. When the Website requests your identity, the Website will clearly indicate the purpose of the inquiry before the information is requested.
- When you request a page from any place within the Website, our web servers automatically recognize certain information such as the User’s web request, IP address, browser type, referring/ exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, device related data, location data, and other such information. The Company uses this information to analyse trends, to administer the Website, to track Users’ movements around the Website and to gather demographic information about the User base as a whole. The Company may link this automatically-collected data to personally identifiable information.
- The Company also collects and stores marketing and communications data based on your interaction with the Website. This includes both a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third party partners/ sellers.
- The Company collects information that you may provide to us, when you write directly to us (including by way of e-mail).
- The Company collects information that the Users provide to the Company over telephone or any other medium. The Company may make and keep a record of the information shared by the Users with us.
- The Company collects and stores information that the Users provide to us by completing surveys.
- The Company may also obtain personal information of a User through third parties or from publicly available sources, such as:
- Profile data from social media platforms and networks when Users give us permission to do so and only if applicable;
- Technical data for the purposes of conducting fraud and risk assessments;
- Data from external third parties who have entered into contracts with us to assist us with our business operations and provided that such service providers adhere to our data protection requirements;
- Identity data and contact data from publicly available sources in accordance with applicable laws; and
- Data from internal third parties or from specific third parties, such as audit support and information technology.
- Data collected by the Company (whether through online or offline sources) may be:
- Anonymized: This data will not contain any personally identifiable information relating to the User.
- Collection of Information through cookies – Cookies are small pieces of information saved by your browser onto your browsing device, such as computer or mobile phone. Cookies are used to record various aspects of your visit and assist the Company to provide you with uninterrupted service. These cookies terminate once the customer closes the browser.
- By default, the Company uses a persistent cookie that stores User login ID (but not password) to make it easier for the User to login when returning to the Website. The Company encodes its cookies so that only the Company can interpret the information stored in them. The User may remove or block this cookie using the User’s browser settings to disable the feature.
- The Company also stores transaction history. The Company may collect additional information in ways not specifically described herein. For example, the Company may track information related to interactions with customer service or responses from surveys or other feedback tools. The Company uses this information to continually improve the service provided to the Users.
- The Company partners with third-party service providers to either display advertising on the Website or to manage our advertising on other websites. Our third-party partner may use technologies such as cookies to gather information about your activities on the Website and other websites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
- Opt-out procedure – Upon initial communication from the Company, you may opt-out of receiving further communications from the Company. To be completely removed from the Company mailing list, you may contact us at email@example.com. If you are using an e-mail forwarding service or other similar service, please make sure to include the correct e-mail address or addresses.
Use And Processing Of The Information Collected
- The Company may use your information for or in connection with any of the following purposes:
- For providing services - The primary goal of the Company in collecting the information is to provide you the services as set out on the Website. The Company may use the personal information provided by you in the following ways:
- To provide you with products and services;
- To facilitate, process your requests and transactions and to provide you with transaction and post transaction-related services, providing, improving, and marketing our products and services, including site content and performance;
- To resolve technical issues of access to the Website via telephone or email;
- To evaluate your use of the services;
- To better understand Users’ needs and interests;
- To identify and reach you;
- To process your personal information in connection with the performance of a contract that we have with you;
- For marketing and advertising purposes, including for providing you with further information, products and services and newsletters;
- Personalize your experience and customize Website experience;
- To check the identity and suitability of Users for certain products and services;
- Improve our Website in order to better serve you;
- Allow us to better service you in responding to your customer service requests;
- Administer a contest, promotion, survey or other site feature;
- To monitor your compliance with any terms and conditions associated with our products and services;
- To share it with such third parties with whom it contracts in connection with provision of services to you or to whom it transfers its rights and duties under any agreement entered into with such third parties;
- The Company may sub-contract all or part of the services to a third-party sub-contractor. When you sign up for these services, the Company will share names, contact information or other personally identifiable information that are necessary for the third party to provide these services. Per the Company's contractual arrangements with these parties, they are not allowed to use personally identifiable information except for the explicit purpose of providing these services; and/or
- For all other incidental and associated purposes relating to the provision of our products and services.
For safeguarding and improving the Website – In order to protect the Company and the Website against any security threat and to improve/introduce certain features on the Website, the Company may use your personal information in the following ways:
- To ensure the security and operation of the Company’s information technology environment;
- To improve the Company’s artificial intelligence protocols and chatbots; and/or
- To detect and protect against error, fraud, and other criminal activity.
- For legal purposes – In accordance with the applicable laws on data protection, the Company may use your personal information for the following purposes:
- To comply with its legal obligations;
- To make disclosures as may be required under applicable law;
- To comply with the legal process to respond to requests from public, regulatory or government authorities; and/or
- To comply with the orders of law enforcement agencies, governmental officials, legal or regulatory authorities and/or to such other statutory bodies who have appropriate authorization to access the same for any specific legal purpose.
- For other business purposes – The Company may use your personal information for other business purposes as well, which include the following:
- To provide aggregated de-identified data to Enterprise Clients (as defined hereinafter) or partners under the terms of agreement with them;
- To carry on audits, due diligence for effecting investments in the Company;
- As part of sale, merger or similar change of the business or its parent company, subsidiaries, affiliates and related group companies;
- To perform internal business processes such as data analysis, audits;
- In case of a necessity for our legitimate interests or the legitimate interests of a third party which requires us to put in place appropriate privacy measures to ensure that our legitimate interests are not outweighed by impacts on your interests, fundamental rights or freedoms; and/or
- To develop new products and services and improve the existing ones.
- The Company may share aggregated information with the Company's partners / clients. This is not linked to any personal information that can identify any individual person. Information available with the Company may be shared by the Company even after completion of the services.
- If none of the above applies, we may seek your explicit consent for specific forms of use/processing of your personal information, which you may decline or revoke at any time.
- Web beacons – The web pages of the Website contain electronic images known as “Web beacons” (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyse how the Website is Web beacons may also be used in some of the Company’s emails to know which emails and links recipients have opened, allowing it to gauge the effectiveness of its customer communications and marketing campaigns.
Disclosure Of Information
- External third parties: We may share your personal information with (i) third party service providers under contract who assist us with our business operations; (ii) credit bureaus to report financial data, as permitted by law; (iii) in the event the Company sells or buys any business or assets, it may disclose User’s information to the prospective seller or buyer of such business or assets. The Company may also transfer or assign such information in the course of corporate divestitures, mergers or dissolution; (iv) when required by law enforcement agencies, government officials, statutory bodies, fraud detection agencies or other similar third parties; and/or (v) when we are compelled to do so by law (such as via a subpoena, court order or similar legal procedure) or when we are under a duty to do so in order to comply with any legal obligation, or to protect the rights, property or safety of the Company, its Users or others.
Storage Of Information
- We store and process User’s personal information on our secure servers and the servers/databases of other cloud service providers (such as Amazon Web Services, Google, Microsoft, and others). The Company may store the User’s information in locations outside the direct control of the Company (for instance, on servers or databases co-located with hosting providers (such as Amazon Web Services, Google, Microsoft, and others)). We use reasonable safeguards to preserve the integrity and security of User information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment. To achieve the same, we use reasonable security practices and procedures as mandated under applicable laws for the protection of User information.
- However, we would like to bring to the User’s attention that data transmission over the internet is not completely secure and that any information that User transmits to us is at User’s own risk. We assume no liability for any disclosure of information due to errors in transmission, unauthorized third-party access to our Website and data bases or other acts of third parties or acts or omissions beyond our reasonable control and User shall not hold the Company responsible for any breach of security.
- Data Retention
- The Company may store User’s personal information for as long as required for the fulfilment of the purposes for which we collected it and for as long as the User account on the Website is active or as needed to provide services to the User or otherwise as required by the Company for undertaking its legitimate business activities or to comply with applicable law. The retention of personal information by the Company is determined by considering compliance with legal (contractual or statutory requirements), accounting and compliance reporting requirements.
- If the User wishes to cancel its account on the Website, or requests that the Company no longer use its information to provide services, the User may contact the Company via email, asking the Company to do so. Notwithstanding any such cancellation/ request, the Company will retain and use all information provided by the User, as may be necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes.
- Post termination of your account on the Website, or post any request by the User that the Company should not use his/ her information, the Company may continue to use your anonymized data aggregated or in combination with anonymized data of other users. The Company may use this aggregated anonymized data for data analysis, profiling and research purposes, for example - to gain insights about our Users and their profiles. We may keep your contact information along with your application details (if any) for fraud prevention purposes and for the exercise/ defense of a legal claim or for providing evidence in legal proceeding(s).
Company As a Pass-Through Facilitator
- The Company may, in some cases, be a pass-through facilitator for data under a contract with a client or partner (“Enterprise Client”). In such cases, the Enterprise Client shall be deemed to be the owner of the information collected on the Website, and the Company shall not be deemed to be the owner of such information. The Company may, as part of the agreement with such Enterprise Clients, use the information collected to provide the relevant services to the User. Post completion of the service, a copy of the identified and de-identified data will still be retained by the Company, to be used as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes.
Treatment Of Data In Case Of A Sale Of Assets, Merger, Acquisition
- The Company reserves the right to disclose and transfer your personal information: (i) to a subsequent owner, co-owner or operator of the Website, website, mobile application or applicable database; or (ii) to the transferee entity in case of a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process. You will be notified via email and/or a prominent notice on our Website of any change in ownership, possession or uses of your personal and Website usage information, as well as any choices you may have regarding your personal information.
- The Company maintains a strict "No-Spam" policy, which means that the Company does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
Protection Of Information
- The Company takes the security of your information very seriously. The Company protects your information from loss, theft, misuse and unauthorized access, use, disclosure, reproduction, alteration and destruction by using generally accepted industry standards. The Company has put in place appropriate methods and managerial procedures to safeguard and secure such information. It only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the User. The Website allows Users access to their personal information and allows them to correct, amend or delete inaccurate information.
- The Company takes all necessary precautions to protect your personal information both online and off-line. No administrator at the Company will have knowledge of your It is important for you to protect against unauthorized access to your password and your computer. Be sure to log off from the Website when finished.
- By using the Website, you accept the inherent security implications of data transmission over the internet. Therefore, the use of the Website will be at your own risk and the Company assumes no liability for any disclosure of information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to hold the Company responsible for any breach of security.
- The Company shall not be liable for the transfer of any personal identification information resulting from loss or distribution of data, the delineation or corruption of storage media, power failures, natural phenomena, riots, acts of vandalism, sabotage, terrorism or any other event beyond the Company's control.
- In the event the Company becomes aware of any breach of the security of your information, it will promptly notify you and take appropriate action to the best of its ability to remedy such a breach.
- The Website may contain links to other sites. The linked sites are not necessarily under the control of the Company. Please be aware that the Company is not responsible for the privacy practices of such other sites. The Company encourages you to read the privacy policies of each web site that collects personally identifiable information. If you decide to access any of the third-party sites linked to Website, you do this entirely at your own risk. Any links to any partner of the Website should be the responsibility of the linking party, and the Company shall not be responsible for notification of any change in name or location of any information on the Website.
- By using the Website, you represent that you are of the age of majority as defined under applicable law and have the legal capacity to access the Website.
Notification Of Changes
- Using the Company services or accessing the Website after a notice of changes has been sent to you or published on the Website or on our website shall constitute your consent to the changed terms.
- Grievance Officer
- If you have any grievance with respect to the Website or the services in connection with which your information is collected, including any discrepancies and grievances with respect to the processing of information, you can contact our Grievance Officer at: firstname.lastname@example.org
Governing Law / Dispute Resolution
- There shall be one (1) arbitrator and the seat of the arbitration shall be Gurgaon, India. The language of the arbitration proceedings and of all written decisions and correspondence relating to the arbitration shall be English.