Scope and Definition
This policy shall govern the collection of data, use of Data and Handling (“usage”) of the Personal Information (“PI”) and the Sensitive Personal Data or Information (“SPDI”) by the Platform Owner in accordance with the Rules.
“Personal Information” means any information that can be used to identify, locate, or contact an individual, alone or when combined with other personal or identifying information. For this purpose, Platform Owner collects the following Personally Identifying Information (“PII”) in a form from the Users during their use of the Platform or the VTS Device:
- Name of the User
- E-mail address
- Credit card or debit card information which is required for payment purposes (excluding passwords, PIN numbers, (CVVs etc.)
- Billing and transaction details
- Any other information as required by Us for the purpose of the User’s use of the Platform or the VTS device.
“Sensitive Personal Information” means such personal information which consists of information relating to:
- Financial information such as bank account or credit card or debit card or other payment instrument details
Any detail relating to the above clauses as provided to a body corporate for providing service; and any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise: Provided that, any information that is freely available or accessible in public domain or any other law for the time being in force shall not be regarded as sensitive personal data or information. By clicking the accept button below you hereby expressly give consent to use your PI and SPDI as more fully described herein below. Your consent to the same shall be construed as a lawful contract between you and the Platform Owner in accordance with the Act and Rules.
“Third party website” A third party website is a website that is outside the domain of the actual Platform that you are in. It is important for you to know when you are leaving the original Platform to a third-party website for security reasons. The content of other websites, services, goods or advertisements that may be linked to this Platform is not maintained or controlled by Platform Owner.
“Non-Personal Information” Platform Owner may also collect information other than Personal Information from You through the Platform when You visit and / or use the Platform. Such information may be stored in server logs. This Non-Personal Information would not assist Platform Owner to identify you personally. This Non-Personal Information may include:
- Your geographic location.
- Details of Your telecom service provider or internet service provider.
- The type of browser (Internet Explorer, Firefox, Opera, Google Chrome etc.)
- The operating system of your system, device and the Website You last visited before visiting the Platform.
You hereby represent to Platform Owner That
The Information you provide to Platform Owner from time to time is and shall be authentic, correct, current and updated and you have all the rights, permissions and consents as may be required to provide such Information to Platform Owner.
Providing the Information to Platform Owner and Platform Owner’s consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third-party agreement, laws, charter documents, judgments, orders and decrees.
Your Information will primarily be stored in electronic form however certain data can also be stored in physical form. We may store, collect, process and use your data in countries other than India but under compliance with applicable laws. We may enter into agreements with third parties (in or outside of India) to store or process your information or data. These third parties may have their own security standards to safeguard your information or data and we will on commercial reasonable basis require from such third parties to adopt reasonable security standards to safeguard your information / data.
Purpose for collecting, using, storing and processing your Information Platform Owner collects, uses, stores and processes your Information for any purpose as may be permissible under applicable laws (including where the applicable law provides for such collection, usage, storage or processes in accordance with the consent of the user) connected with a function or activity of each of Platform Owner’s entities and shall include the following:
- To facilitate your use of the Platform or other services of Platform Owner’s entities
- To respond to your inquiries or fulfil Your requests for information about the various products and services offered on the Platform.
- To provide you with information about products and services available on the Platform and to send you information, materials, and offers from Platform Owner.
- To send you important information regarding the Platform, changes in terms and conditions, user agreements, and policies and/or other administrative information.
- To send you surveys and marketing communications that Platform Owner believes may be of interest to you.
- To help you address your problems incurred on the Platform including addressing any technical problems.
- For proper administering of the Platform.
- To conduct internal reviews and data analysis for the Platform (e.g., to determine the number of visitors to specific pages within the Platform).
- To improve the services, content and advertising on the Platform.
- To facilitate various programmes and initiatives launched by Platform Owner or third-party service providers and business associates.
- To conducting academic research and surveys.
- To protect the integrity of the Platform.
- To respond to legal, judicial, quasi-judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law.
- To conduct analytical studies on various aspects including user behaviour, user preferences etc.
- To implement information security practices.
- To determine any security breaches, computer contaminant or computer virus.
- To investigate, prevent, or take action regarding illegal activities and suspected fraud.
- To undertake forensics of the concerned computer resource as a part of investigation or internal audit.
Legal basis for processing of Personal Information
We will normally collect Limited Personal Information from you only where it is needed to perform a contract including minimum KYC requirement to on-board you, where the processing is in Our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where We have your consent. In some cases, we may also have a legal obligation to collect Personal Information from you. If We processes Personal Information with reliance on your consent, you may withdraw your consent at any time.
Collection and use of Personal Information
We process Personal Information in USA and India. If you are a resident of the European Economic Area and when your Personal Information is processed outside EEA, We, will ensure that the recipient of your Personal Information offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Information as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask you for your prior consent to such international data transfers.
Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory.
The information we collect with cookies is not sold, rented, or shared with any third parties, other than for internal development and maintenance of the Platform.
Links to Other Sites
Disclosure to Third Parties
Platform Owner shall be at liberty to disclose your information or part thereof to third party service providers who may facilitate the providing of services, on our behalf. These service providers have access to your data only to perform the tasks as stipulated by Platform Owner and are obligated not to disclose or use it for any other purpose. Platform Owner may also share personal information with third-party vendors, consultants, and other service providers who work for the Platform Owner, who are bound by contractual obligations to keep personal information confidential.
By participating or accepting any rights granted under this policy, each Participant consents to the collection and processing of personal data relating to the Participant. So that the Platform Owner and its Affiliates can fulfil their obligations and exercise their rights under the contract.
Under the Data Protection Laws, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. With your (client) permission, and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone or post with information, news, and offers on our products and services. We will always work to protect your rights fully and comply with our obligations under the Data Protection Laws.
Governing Law and Dispute Resolution
Platform Owner reserves the right to add, revise, amend, modify or delete any part of this Policy (in part or in full) at its discretion. The updated version of this Policy in force will be posted on the Platform from time to time. In the event of any change in the Act or the Rules or in case of any requirement arising under any of the applicable law, this Policy shall be deemed to be amended or modified to the extent necessary to comply with such amendment to the Act or the Rules or to meet any requirement under the applicable laws.
The user who’s the Personal Information and/or Sensitive Personal Data or Information is collected, received, possessed, processed, stored, transferred, dealt or handled may inquire as to the nature of data stored or processed by the Platform Owner. The person will be provided reasonable access to the person’s Personal Information and Sensitive Personal Data or Information held by the Platform Owner. If any data is inaccurate or incomplete, such person may request that the data be amended or modified or updated.
We have implemented industry standard security policies, rules and technical measures, to protect any kind of personal sensitive information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.
For any grievances related with collection and use of Personal & Sensitive Personal Information please contact:
Grievance Officer email address: firstname.lastname@example.org
- Please include the following subject line in the email – “Attention: Grievance Officer”
- We will strive to address your feedback and concerns in a timely and effective manner.