PRIVACY POLICY

1. DEFINITIONS

1. Unless otherwise expressly defined, the following terms shall have the following meanings:

2. INTRODUCTION

1. The domain name ‘_________’ and the mobile application named ‘_________’ belong to _________ (the “Company” having CIN: _________).

2. This privacy policy is applicable upon the User of the Company’s Website. The said Terms and Conditions of the Company (the “TnCs”) are linked here: __________________. 

3. The Company is committed to the protection of the User’s privacy and User Information in accordance with the applicable law.

4. This privacy policy details the manner in which the User Information and data is generated, collected, stored, processed and used by the Company. 

5. The User is advised to read this privacy policy carefully. The privacy policy is incorporated as part of the TnCs of the Company. By using or accessing the Company’s Website and Services, the User is deemed to have agreed to the terms of the present privacy policy.

6. If the User does not agree to the terms contained hereunder, please do not further use or access the Company’s Website or Services.

3. APPLICABILITY

1. The privacy policy is applicable to the use and access of the Company’s Website and Services by the User. 

2. The privacy policy applies regardless of whether the User used the Company’s Website or Services via computer, mobile phone, tablet, television or any other media or computer resource. 

3. The privacy policy also applies to the User who either registers / creates an Account on the Company’s Website or whose data has been otherwise received in connection with the Services.

4. PERSONAL INFORMATION OF THE USER

1. The User Information (as defined under the TnCs) means and includes the Personal Information of the User, any data relating to identified or identifiable living person (‘data subject’ herein referred as the ‘User’) including but not limited to, name, address, mailing address, telephone number, email ID, bank account details including details linked to credit / debit payment instruments, information about your mobile phone, any personal details that may have been voluntarily provided by the data subject.

2. It is important that the User reads this privacy policy carefully because the User Information and data may be processed by the Company whenever the User uses the Website.

3. To improve its Services for the Users, the Company may collect (a) User Information, and (b) information related to the usage of Company’s Website by the User (“Usage Information”). The User Information or the Usage Information may be collected to:

4. help and guide the User in finding the most relevant information related to the Services provided by the Company;

5. The User Information or the Usage Information may be related to the following:

6. creation and registration of User’s Account with the Website;

7. log information and location information for assessing the Website usage;

8. data collected through campaigns and other publicly available sources; 

9. communication between the Company and the User, or the User with other Users;

10. sign in by the User with its social media or email accounts to access our Website, the User consents to our collection, storage, and use, in accordance with this privacy policy, of the data that you make available to us through such other social media or email account(s). 

11. the Company may obtain information about the User from third-parties for improving the Services. 

12. location information, if any, provided by the User while creating and registering the User Account, may be stored and associated with the User’s Account.

5. COOKIES AND TRACKING

1. The Website utilizes ‘cookies’ and other tracking technologies. A ‘cookie’ is a small text file that may be used to collect data about the User’s activity on the Website. Some cookies and other technologies may serve to recall User Information and Usage Information. Most browsers allow the User to control ‘cookies’, including whether or not to accept them and how to remove them.

2. The Company uses ‘session cookies’ to (a) keep the User logged-in while the User uses the Company’s Services, (b) better understand how the User interacts with the Company’s Services, and (c) monitor aggregate usage and web traffic information on the Website.

3. Tracking technologies may record information such as internet domain and host names, internet protocol (IP) addresses, browser software and operating system types, clickstream patterns and dates and times that the Website is accessed. 

4. The use of cookies and other tracking technologies allows the Company to improve the Website and User’s experience on the Website. The Company may also analyse Usage Information that may or may not contain User Information for trends and statistics.

5. In case the User prefers not to share the session cookies or the web traffic related information, the User may modify the cookie settings on their web browser or device.

6. INFORMATION SHARING AND DISCLOSURE

1. As the User uses, accesses and navigates through the Website, the Company may collect various types of User Information, which may or may not be personally identifiable information. This information is classified as:

2. Personal Information: which means personally identifiable information like the User’s name, address, age, email address and phone number; and 

3. Sensitive Personal Information: which means the User’s financial information, passwords, any biometric, medical or health related information; and

4. Other Information: which means all other information other than Personal Information or Sensitive Personal Information. For example, the nature of device, usage patterns and usage preferences, Website access logs, local caches, location, IP address etc. 

5. The Company may use the Personal Information to grant access to the Website, resolve User’s concerns / customer care, update the User for any changes or additions to our Services or the Website. 

6. Any other Information may be used by the Company for:

7. The Company’s business purposes;

8. analytical purposes, data usage;

9. improving the Company’s Website, or User’s experience; and

10. providing targeted advertisements.

11. The Company will share any User Information with any third party, if, the Company in good faith believes that the same is required for the purposes of compliance with any applicable law, regulation, legal process or enforceable governmental request / action or any manner required for the purposes of protecting our rights or interests.

12. From time to time, the Company shall make the e-mail addresses of the User available to other reputable organizations whose products or services the Company thinks might be interesting for the User. In case the User does not want us to share its e-mail address with other companies or organizations, the User may notify the same to us by emailing us at email ID mentioned under ‘Grievance Redressal’ section hereunder.

13. The User who supplies the Company with its telephone numbers on-line may receive telephone or text message contact from us with information regarding the Services or upcoming events. In case the User does not wish to receive such telephone calls or text messages, the User may notify the same to the Company via email addressed to the email ID mentioned under ‘Grievance Redressal’ section hereunder. 

7. CONSENT 

1. The User expressly confirms and acknowledges that by using and accessing the Website and the Services of the Company, the User has consented to the Company using their User Information and the Usage Information in the manner specified under this privacy policy. 

2. The User’s consent may also have been obtained by the Company by way of an e-signature or a tick / check box on the Website. 

3. Unless the User expressly revokes its consent, by writing to the Company via email mentioned under ‘Grievance Redressal’ section hereunder, the consent once granted shall be deemed to be operative and the Company shall not be required to obtain any fresh / new consents from the User. 

4. It is clarified that the consent granted by the User includes (but is not limited to) the consent for the following:

5. collecting, using, or processing the User’s Personal Information, Sensitive Personal Information, in certain ways or sharing the Personal Information with any third party;

6. transferring the User Information outside of the country of User’s residence;

7. using or placing ‘cookies’ on your computer or other electronic devices as per this privacy policy.

8. CONTROL OVER USER INFORMATION 

1. The User has the ability to control its User Information and Personal Information in accordance with applicable law. 

2. The User shall have the ability to update its profile and related Personal Information at any time. Also, the User may review, update, correct, delete or object its Personal Information by writing to the Company via email at _________.

3. In case the User has concerns regarding the privacy, access or correction of the User Information or Personal Information, the User may contact the Company at the ‘Grievance Redressal’ email mentioned below.

4. Any request made by the User will be entertained by the Company only if the same contains the details of the User Information or Personal Information that the User would like to have changed.

5. All the issues raised by the User will be responded to by the Company within _________ days of receipt of the email from the User.

9. DISPUTE

1. In the event of any dispute, controversy or claim directly or indirectly caused by, arising out of or relating to this privacy policy will be governed by the laws of India.

2. The User and the Company shall use all reasonable endeavours to first resolve the matter on an amicable basis, within a period of _____ days. No recourse to arbitration by one party against the other party under this privacy policy shall take place unless and until such procedure has been followed.

3. Any unresolved disputes or claims which may arise out of or in connection with the privacy policy shall be referred to arbitration in accordance with the provisions of the Indian Arbitration and Conciliation Act, 1996. The arbitration proceedings will be presided by a sole arbitrator to be appointed based on mutual consent of both the User and the Company in writing.

4. The arbitration proceedings shall be in English and shall be held at New Delhi, India.

10. SECURITY AND CONFIDENTIALITY

1. The Company shall endeavour, at all times, to implement reasonable security practices and procedures (such as managerial, operational, physical and technical) for the purpose of protection and safeguarding the User Information and the Personal Information. The Company is strongly committed to protecting the personal and financial information related to the User.

2. The Company shall endeavour to safeguard the security and confidentiality of User Information and Personal Information shared by the User with the Company. However, despite the utmost efforts of the Company to protect your Personal Information, the Company cannot warrant the security of any data that the User transmits through the Website. By accepting this privacy policy, the User accepts that such transmission of the Personal Information is done at the User’s own risk.

3. Lastly, the User is requested to help the Company in protecting the User’s Information and Personal Information by maintaining the secrecy of the username and password used by the User for accessing the Website and Services of the Company.

11. DATA RETENTION

1. The User’s Personal Information processed by the Company no longer than is necessary for the purposes for which it is processed, in line with the legal, regulatory, contractual or statutory obligations as applicable.

2. At the expiry of such periods, the User’s Personal Information shall be deleted or archived to comply with legal / contractual retention obligations or in accordance with applicable statutory limitation periods.

12. AMENDMENTS

1. The Company reserves the right to change or update the privacy policy or any other policies / practices at any time without giving any prior notification to the User. The User is requested to review the privacy policy periodically. Any changes or updates will be effective immediately upon posting the same on the Website.

2. This privacy policy shall apply uniformly to the use and access of the Company’s Website and Services (irrespective of the mode or media used by the User). 

13. GRIEVANCE REDRESSAL

Any complaints or concerns with regards to content or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to:

Name / Designation: _______________________

Contact Details: ___________________________