Last Updated : 12th November 2020
Pepper Content is dedicated to protecting and respecting the individual’s legal rights of privacy and data protection while collecting, storing, using, and transmitting the Personal Data (defined below).
This Policy should be read in conjunction with the Terms of Usage and forms an integral part of Terms and Conditions, which are incorporated herein by reference. For any terms used herein but not defined, please refer to the Terms and Conditions.
Any Service availed by the Users of the Platform, inclusive of the Creators, Customers on the Platform, and the visitors who visit the page (“You” or “Your” or “User”) through the Platform, is conditioned upon Your acceptance of the terms and conditions contained in Terms of Usage of the Company as available on the Platform and this Policy.
I. INTRODUCTION AND APPLICABILITY OF THE POLICY
We are strongly committed to respecting Your online privacy and recognize the need for appropriate protection and management of any Personal Data collected and/or collated by Us.
We collect and/or collate and/or use Personal Data from Our Users, and this Policy outlines the procedure of collecting, storage and processing of such Personal Data; the types of Personal Data being collected from the Users by the Company; the purpose of collecting the Personal Data; the recipients of the Personal Data; and how the Personal Data is processed, stored and protected. The purpose of this Policy is to ensure that there is an intact charter to collect, process, use, store, and protect any Personal Data, including Sensitive Data (defined below) collected by Us.
The Policy applies to any User who is a natural person and accesses or browses the Platform or avails the Services provided on the Platform.
“CCPA” shall mean the California Consumer Privacy Act of 2018, as amended from time to time and as amended by California Privacy Rights Act, 2020;
“COPPA” shall mean the Children’s Online Privacy Protection Act;
“DOPPA” shall mean the Delaware Online Privacy and Protection Act;
“GDPR” shall mean the General Data Protection Regulations, applicable as of May 25, 2018, in all member states of the European Union (EU), as amended from time to time;
“IT Act” shall mean the Information Technology Act, 2000, as amended from time to time;
“IT Rules” shall mean the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
“Locational Information” means and includes the information obtained through GPS or other means, such as the geographical location of the User;
“Non-Personal Data” means and includes any information that is not Personal Data;
“Personal Data” means and includes any information that identifies, relates to, or could reasonably be linked to a natural person, such as the name, contact details, email address, gender, age, organisation name, organisation email id, or any other relevant material provided by a User, including but not limited to information gathered through the Services. However, it does not include any information or data which is already available in the public domain, information publicly available in the government records, whether federal, central, state, or local such as professional licenses, real estate/property records, or which can be furnished under (Indian) Right to Information Act, 2005 or any other similar applicable laws; Personal Data includes Sensitive Data, Technical Information, and Location Information.
“Sensitive Data” means and includes such Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, physical or medical records or health information, sexual orientation, genetic data, biometric information, passwords, credentials, and financial information;
“Technical Information” means and includes any information gathered through various technologies that may employ Cookies, web beacons, or similar technologies to automatically record certain information from Your device through which You use the Platform. This Technical Information may include Your Internet Protocol (IP) address, device or browser type, Internet service provider (ISP), referring or exit pages, clickstream data, operating system, hardware model, operating system version, unique device identifiers, and mobile network. This data includes usage information and user statistics.
Any reference made to the Policy in this document shall mean and refer to the latest version of the Policy.
This Policy has been drafted and published in accordance with the IT Act, IT Rules, CCPA, COPPA, DOPPA, and GDPR.
This Policy constitutes a legal agreement between the Company, as the owner of the Platform, and You, as a user of the Platform. The terms of this Policy shall become effective upon Your acceptance of the same (directly or indirectly in electronic form, by use of the Platform, or by other means) and will thereafter continue to govern the relationship between the Company and You during Your use of the Platform and the Services.
Please be advised that any Personal Data procured by Us shall be:
processed fairly and lawfully for rendering the Services;
obtained only for specified and lawful purposes, and not be used in any manner which is against the law or policy under any applicable law;
adequate, relevant, and not excessive in relation to the purpose for which it is required;
able to be reviewed by the User from time to time and updated if the need arises; and
not kept longer than for the time which it is required or the purpose for which it is required or as required by the applicable law.
We will not be liable for any loss or damage sustained by You for the reason of any disclosure (inadvertent or otherwise) of any Personal Data, if the same is either (a) required for sharing Your information for legitimate purposes under applicable law; or (b) was affected through no fault, act, or omission of the Company.
Please read this Policy carefully, as it affects Your rights and liabilities under applicable law. If You are not comfortable with any of the terms or policies described in this Policy, You may choose to discontinue usage of the Platform and Services.
By accessing or browsing the Platform or availing the Services, You explicitly accept, without limitation or qualification, the terms and conditions of this Policy and Terms of Usage available on the Platform and give Your consent and authorize Us to collect, use or disclose such Personal Data for the purposes as stated in this Policy and the Terms of Usage and as permitted or required under applicable law.
You understand and hereby consent that the Personal Data may be transferred to any third-party user for the purpose of providing Services through the Platform or any jointly developed or marketed services, payment processing, order fulfillment, customer services, data analysis, information technology services, and any other services which enable Us to provide Services through the Platform.
This Policy shall be enforceable against You in the same manner as any other written agreement. If You do not agree with this Policy, You may refuse or withdraw Your consent any time, or alternatively choose not to provide Us with any Personal Data. Under such circumstances, Your access to the Services We provide may be limited or We may be unable to render Services.
The intimation to withdraw Your consent can be sent to [email protected].
IV. INFORMATION COLLECTED BY US
We collect, process, and store the Personal Data when You access or browse the Platform or avail the Services.
If You are a Creator, We may also collect the following Personal Data:
Account Details: These include Your username and password and preferred account settings such as the language and time zone etc.
Professional Credentials: Information regarding Your prior work experience and educational qualifications that is provided by You upon creation of Your Account (as defined in Terms of Usage) during registration on the Platform.
Invoicing Information: In order to make payments for the Content Services rendered by You via the Platform, We would require Your banking details, such as name, address, email id, PAN card details, and financial information that corresponds to Your bank, including but not limited to, bank name, branch, account number, IFSC code, etc.
If You are a Customer, We may collect the following Personal Data:
Account Details: These include Your username and password, location, and preferred account settings such as the language and time zone, etc.
Billing Details: These include details such as name, address, email id, and other financial information that corresponds to Your mode of payment, including but not limited to credit card/ debit card details, net banking information, bank details etc. Please note that confidential information such as the CVV/PIN Number and the net banking credentials will not be stored by Us.
Financial Information shall be collected using third-party intermediary PCI-DSS compliant service providers. The payment information is provided directly by You, via the Platform, 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.
If You are a passive User of the Platform and do not register for the Services, then the Platform may still collect, process, and store Your Non-Personal Information.
To protect Your privacy, You should not provide the Company with any Personal Data that is not specifically requested or that You do not wish to share. You may choose not to provide certain Personal Data, but then You might not be able to use Our Platform or certain features of Our Platform. By undergoing the registration process, You consent to Us collecting and using Your Personal Data.
When You use the Platform, We may collect certain Technical Information about Your computer or mobile to facilitate, evaluate and verify Your use of the Platform. For example, We may store environmental variables, such as browser type, operating system, speed of the central processing unit (CPU), referring or exiting web pages, click patterns, search queries, navigation paths, timestamps, Services availed, crashes, and the internet protocol (IP) address of Your computer. This information is generally collected in aggregate form without identifying any User individually.
When You use the platform, We may require you to connect your Google Account via Google’s OAuth Integration for us to receive data from your connected Google Analytics and Google Search Console which used to enable certain parts of the platform.
If You contact Our customer support team, then, We will collect and store the contact information You give them (generally Your name, mobile number, and e-mail address) and information about the Services availed by You. We will also store the communications You have with Our customer service team and any additional information in those communications for training purposes and in order to improve the Services provided by Us. We recommend You to not share any Sensitive Data, including but not limited to, financial information, such as credit card number, OTPs, login passwords, and other sensitive information in Your correspondence with Our customer support team.
If You post any comments or content on our Platform, You should be aware that any information, including Personal Data You choose to provide there, may be read, collected, or used by the third parties. We are not responsible for the information You choose to submit, and we cannot guarantee that third parties have not made copies of or will not use such information in any way.
V. PURPOSE OF COLLECTION AND USAGE OF THIS INFORMATION
Processing of Personal Data may be necessary for the performance of Our agreement with You. It is contractually necessary to process Your Personal Data to fulfil Our obligations as provided in Our Terms of Usage. Depending on whether You are a Creator, Customer, or a visitor, the Personal Data collected by Us shall be used for providing Our Services, and the Personal Data is utilized for other functions including but not limited to:
maintaining the Platform;
to verify Your identity;
to evaluate the quality and competence of Our personnel;
to resolve any complaints, You may have and ensure that You receive the highest quality of Services;
notifying You about changes to Our Platform and providing updates;
allowing You to participate in interactive features of Our Platform when You choose to do so;
providing analysis or valuable information so that We can improve the Platform;
monitoring the usage of the Platform;
detecting, preventing, and addressing technical issues;
analyse usage patterns and user preferences by compiling and analysing aggregate statistics in respect of the use of Our Platform for our internal use;
improve User experience by communicating with you about Your account and activities on the Platform via phone, email or chat on Our Platform;
notify You about new products and features;
ask for ratings and reviews of the Services and the Platform; and
to comply with legal and regulatory regulations, including customs and GST requirements.
Business or Research Purposes: Personal Data is used for business or research purposes, including improving and customizing the Platform for ease of use and the products and Services offered by Us. We may archive this information to use it for future communications for providing updates and/or surveys.
Legal obligations: Our processing of Your Personal Data is necessary in order to allow Us to comply with a legal obligation or to protect the vital interests of Our Users. For instance, where We are required to retain business records for fixed periods of time in order to comply with local legal requirements.
Aggregating information/Anonymized data: We may aggregate certain information and analyse it in a manner to further accentuate the level of Services to Our customers. This Information includes the average number of Users of the Platform, the average clicks of the Services, the features used, the response rate, and other such statistics regarding groups or individuals. In doing so, We shall not be making disclosures of any Personal Data as defined in this Policy.
In certain limited situations, We rely on Your consent in order to process Your Personal Data. We seek Your consent at the time of provision, and such processing will only be performed where consent is secured.
(collectively referred to as “Legitimate Purpose”)
VI. DISCLOSURE AND SHARING OF INFORMATION
We do not rent, sell or disclose or share any Personal Data that We collect from You with third-parties, save and except in order to provide You with the Services or for the Legitimate Purposes as specified above. Any such disclosure, if made, shall be in accordance with this Policy and as per the procedure prescribed by applicable law and in compliance with our legal obligations. We may share Your Personal Data in the circumstances and for the purposes as specified hereunder:
We shall share the Personal Data to the third-party service providers/vendors to provide You with the Services and to effectuate any activities that fall under the Legitimate Purpose for which such Personal Data has been collected.
When compelled by law: We may disclose any Personal Data provided by You on the Platform to relevant authorities as may be deemed to be necessary or appropriate:
under applicable law, including laws outside your country of residence;
to comply with legal process;
to respond to requests from public and government authorities including public and government authorities including public and government authorities outside your country of residence in accordance with applicable laws; and
for the purpose of verification of identity or for prevention, detection, and investigation, including cyber incidents, prosecution, and punishment of offences under applicable law.
Merger or Acquisition: We may share Personal Data upon merger or acquisition of the Company with another company. We shall transmit and transfer the Personal Data upon acquisition or merger of the Company with another company.
With Our Affiliated Entities: We may share Your Personal Data within the Pepper Content group of companies to enable the Company to carry out the purposes set out in this Policy and Our Terms of Usage.
With Our service providers: We may share Personal Data with other service providers on a need-to-know basis, subject to obligations of confidentiality for the provision of Services. We hereby clarify that the Company works with institutions, vendors, partners, advertisers, and other service providers, including but not limited to those who provide products or services such as contact information verification, website hosting, data analysis, providing infrastructure, information technology services, auditing services, and other similar services, in different industries and categories of business by virtue of lawful contracts instituted between such third parties and Company to improve our product and services. Accordingly, We may share Your Personal Data with such service provider in order to provide You with Services. However, these service providers will not be authorized to use or disclose such Personal Data except as necessary to perform the Services on Our behalf or comply with legal requirements.
Employees/Agents of Company: We follow a strict confidentiality policy with regard to the disclosure of confidential information to Our employees or other personnel. There may be situations where We may disclose the confidential information only to those of Our employees and other personnel on a need-to-know basis. Any breach of confidential information by the employees, or personnel within the Company is dealt with stringently by Us.
Except for the Personal Data disclosed pursuant to sub-clause (a), (b), (c), (d), (e), and (f) of Clause 6.1 above, the Company may share Information, if You authorize Us to do so.
VII. TRANSFER OF INFORMATION
Your Personal Data may be transferred to Our Affiliated Entities or Our business partners and service providers from time to time for Legitimate Purposes identified in this Policy.
Your Personal Data may be transferred to, and maintained on computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.
If You are located outside India and choose to provide Personal Data to Us under this Policy, please note that We may transfer such Personal Data to India to process the same.
Your consent to this Policy followed by Your submission of the Personal Data represents Your agreement to such transfer.
We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place to protect Your Personal Data as per applicable laws.
VIII. YOUR RIGHTS
You can always choose not to provide the requested Personal Data to Us, and it may however result in You not availing certain features of, or the entire, Services. You retain several rights in relation to Your Personal Data as provided under applicable law. We will take reasonable measures to delete Your Personal Data from Our records. We will keep certain records/information pertaining to payment or Service matters wherever necessary in order to ensure compliance with applicable laws or to exercise, defend or establish Our rights. You can exercise the following rights by writing to Us at [email protected]:
access, confirm, and review Personal Data You may have provided;
correct Personal Data that may be inaccurate or irrelevant;
deletion and erasure of Your Personal Data from the publicly available pages of the Platform;
receive Personal Data We hold about You in a portable format;
object to or restrict any form of processing You may not be comfortable with;
opting out of marketing or promotional communication;
withdraw Your consent provided under this Policy.
If You want to withdraw Your consent or raise any objection to the use of Your Personal Data for receiving any direct marketing information to which You previously opted-in, You can do so by contacting our customer support at above mentioned addresses. If You withdraw/object Your consent, Our use of Your Personal Data before You withdrew/objected shall still be lawful.
The Users located in European Countries have the right to complain to a data protection authority about Our collection and Use of Your Personal Data and Sensitive Data in accordance with GDPR.
IX. CHILDREN’S PRIVACY
Our Platform and Services are generally meant for use by anyone who is not a Minor, and We knowingly do not collect Personal Data of/from Minors, unless such Minor is using the Platform under Parental Consent. If it comes to Our notice that We have collected Information from/of Minor who is not registered on Our Platform with Parent Consent or We have unknowlingly collected or received Personal Data of such Minor, We shall take steps to remove that Personal Data from Our servers. If You believe that We might have any Personal Data that may have been collected from a Minor or has been provided by a Minor who using Platform or Services without Parental Consent, please write to us at [email protected] and We will remove such Personal Data from Our servers.
X. NOTICE FOR CALIFORNIA USERS
This PRIVACY Notice FOR CALIFORNIA RESIDENTS (“California Notice”) supplements the information contained in the Terms of Usage and applies solely to visitors, Users, and others who reside in the State of California. We have adopted this Policy in compliance with the CCPA and other California privacy laws. Any capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the CCPA.
Categories of Personal Data collected:
The Personal Data that the Company collects, or has collected from the Users in the 12 (twelve) months prior to the effective date of this disclosure, fall into the following categories established by the CCPA, depending on which Service is used:
Identifiers: such as Your name, alias, address, phone numbers, IP address, Your Pepper Content account log-in information, or a government-issued identifier (e.g., social security number, which may be required for tax purposes);
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): such as name, signature, government-issued identifier (e.g., social security number, which may be required for tax purposes), passport number, a credit card number, debit card number, or other payment information;
Protected Classifications: information that may reveal age, gender, race, sexual orientation, religion, maritial status or other protected classifications;
Commercial information: such as purchase and logistic activity and other purchasing or consuming histories or tendencies;
Internet or other electronic network activity information: including browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, and the content of email and text messages;
Geolocation data: such as the location of Your device or computer, which may, in some cases, constitute precise geolocation information;
Audio or visual information: such as if a service provider reviews recordings of customer service phone calls for quality assurance purposes or if We use a service provider to fulfill Your order;
Professional information: for example, data You may provide about Your business, In case Creators, the past and current employment history. In case of employees, current or past employment history or performance evaluations;
Inference data: such as information about Your activity on the Platform.
The Personal Data does not include:
Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, such as: (i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA); and (ii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
As stated under Section 6 of this Policy, We disclose Your Personal Data for a business purpose to the to the following categories of third parties:
Service providers; and
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding 12 (twelve) months, we have not sold any Personal Data.
In accordance with CCPA, as a Californian resident, You may exercise the following rights in relation with Your Personal Data by writing to Us at [email protected]:
Right to know: You have the right to request the following information: (i) categories of the Personal Data and Sensitive Data that We have collected from You over the past 12 (twelve) months and the specific pieces of Personal Data and Sensitive Data, We have collected from You; (ii) categories of the sources from which Personal Data and Sensitive Data was collected; (iii) business or commercial purpose for which the Personal Data and Sensitive Data was collected; (iv) categories of the Personal Data and Sensitive Data that were disclosed for a business purpose or sold during the past 12 (twelve) months (v) categories of third parties to whom the Personal Data was disclosed or sold;
Right to request deletion: You have the right to request that the Personal Data and Sensitive Data collected from You be deleted. However, We might not delete Your Personal Data and Sensitive Data in certain events, including (i) to detect security incidents; (ii) to debug to identify and repair errors; (iii) to exercise free speech; (iv) to comply with California Electronic Communications Privacy Act; (v) to engage in public, peer-reviewed, historical or statistical research; (vi) to comply with legal obligations;
Right to “opt-out” from sale of Personal Data: You have the right to “opt-out” by requesting that Your Personal Data and Sensitive Data not be sold in any form;
Right to non-discrimination: You have the right not to be discriminated against for exercising Your privacy rights under the CCPA;
Right to know information disclosed to third-parties: You have the right to request the categories of Personal Data and Sensitive Data that We disclosed to third parties in the last 12 (twelve) months for direct marketing purposes and any other related information on the relevant third parties.
We might request certain additional information in order to verify Your identity in relation to Your request for exercising the rights mentioned in Clause 9.1. You must also specify the rights You wish to exercise. We will verify Your request and respond to You within 45 (forty-five) days.
No sale of Personal Data- In the 12 (twelve) months prior to the effective date of this Disclosure, Pepper Content has not sold any personal information of consumers, as those terms are defined under the CCPA
CCPA Sensitive Personal Information Disclosure- The categories of Personal Data that the Company collects and discloses for a business purpose includes "sensitive personal information" as defined under the CCPA. The Company does not use or disclose such sensitive personal information for any purpose not expressly permitted by the CCPA.
CCPA Retention Disclosure- We keep Your Personal Data to enable Your continued use of the Platform and the Services for as long as it is required in order to fulfill the relevant purposes described in this Policy, as permitted or as may be required by law, or as otherwise communicated to You. For example, We retain Your transaction history so that You can review past Services (and repeat orders if desired) and what addresses you have shipped orders to and to improve the relevance of products and content we recommend.
CCPA Non-discrimination Statement- Pepper Content will not discriminate against any User for exercising their rights under the CCPA.
We might request certain additional information in order to verify Your identity in relation to Your request for exercising the rights mentioned above. You must also specify the rights you wish to exercise. We will verify your request and respond to you within 45 (forty-five) days.
You may designate another person or entity (“Authorized Agent”) to act on Your behalf in connection with Your request for rights that are guaranteed by the CCPA. An Authorized Agent is a natural person or business entity registered with the Secretary of State to conduct business in California that You have authorized to act on Your or to make a request to know or to delete. You Authorized Agent can submit a request by sending an email to the email id provided in the Clause 9.1 by attaching the signed permission. Please note that We may deny a request from an Authorized Agent that does not submit proof that they have been authorized by You.
Under the CCPA, Your Authorized Agent is responsible for implementing and maintaining reasonable security procedures and practices to protect and use Your Personal Data only for the purpose of fulfilling Your request.
XI. RETENTION AND STORAGE OF INFORMATION
All Personal Data provided by You, save and except upon withdrawal or termination, shall be retained in locations outside the direct control of the Company (for instance, on servers or databases co-locates with hosting providers). We will delete such Personal Data as requested by You, based on a request received from You within a reasonable period and latest, within 30 (thirty) days of receiving a deletion request. However, We may retain such portion of Personal Data and for such periods as may be required under applicable law. Notwithstanding anything contained herein, We may retain certain Personal Data after account deletion for reasons including but limited to the following purposes: If there is an unresolved issue relating to Your account or an unresolved claim or dispute; If We are required to by applicable law; and/or in aggregated and/or anonymized form; or Company may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing Users' safety and security.
We may store Your Personal Data using Our own secure on-site servers or other internally hosted technology. Your Personal Data may also be stored by third parties via cloud services or other technology with whom the Company has contracted to support the Company's Services. This is necessary to operate globally and provide our Services to You. These third parties do not use or have access to Your Personal Data other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that We use to protect Your Personal Data.
We retain Your Personal Data for as long as it is necessary to provide Our Services or until You ask Us to delete Your Personal Data. However, You acknowledge that We may retain some Personal Data after You have closed or We have deleted Your account where necessary to enable Us to meet Our legal obligations or to exercise, defend, or establish Our rights under applicable laws.
If You choose to integrate your Google account for Google Analytics and Google Search Console data via OAuth integration, We may store the data received from your Google Analytics and Search Console using secure third party servers via cloud services or other technology with whom the Company has contracted to support the Company's Services. Our app complies with Google API Services User Data Policy, including the Limited Use requirements. We don’t share the information received from your Google account integration with any third party which is not specified here and any data sharing adheres to Google API Services User Data Policy, including the Limited Use requirements.
Contains a link to the Google API Services User Data Policy so that it's easily accessible to all users.
XII. COOKIES AND OTHER TRACKING TECHNOLOGIES
Our Platform may utilize “cookies” and other Technical Information. “Cookies” are a small text file consisting of alphanumeric numbers used to collect the information about Platform activity. The Technical Information helps us analyse web traffic and helps You by customizing the Platform to Your preferences. Cookies in no way give us access to Your computer or mobile device. In relation to Cookies, You can deny access to the installation of the Cookies by modifying the settings on Your web browser, however, this may prevent You from taking full advantage of the Platform.
We may aggregate and/or de-identify any Perosnal Data collected/received by the Company; such information can no longer be linked to You or Your device (“De-Identified Information”). We may use De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, at Our discretion.
XIII. THIRD PARTY SERVICES
We may use Your Personal Data to send You promotional information about third-parties which We think You may find interesting if You tell Us that You wish this to happen. We shall not be responsible for any disclosure of Personal Data due to unauthorized third-party access or other acts of third parties or acts or omissions beyond our reasonable control, and You agree that You will not hold Us responsible for any breach of security unless such breach has been caused as a direct result of Our negligence or wilful default.
XIV. DATA SECURITY
You agree and accept that Your Personal Data may be stored in third-party cloud service infrastructure providers. While all reasonable attempts have been taken from Our end to ensure the safe and secure storage of Your Information. We take appropriate and reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of Information. We shall not be liable for any data breach on the part of the third-party cloud service infrastructure provider that was beyond Our control. In addition to the security measures put in place by the third-party cloud service infrastructure provider for safe and secure storage of Your Information, We use certain physical, managerial, technical or operational safeguards as per industry standards and established best practices to protect the Personal Data We collect. We use reasonable security practices and procedures and use secure servers as mandated under applicable laws for the protection of Your Information.
If You have an account registered directly with the Company, Your Personal Data is protected by the password You use to access Your account on the Platform. It is important that You protect and maintain Your account’s security made.
We review Our Personal Data collection, storage, and processing practices, including physical security measures to guard against unauthorized access to systems. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of Our database, nor can We guarantee that the Personal Data You supply will not be intercepted while being transmitted to Us over the internet. We will notify as soon as possible but no later than 72 (seventy-two) hours from when We determine that Our systems have been hacked and Your Personal Data is disclosed as a result of such hacking or any other unauthorized breach of Your systems and databases. You accept the inherent security implications of data transmission over the internet, and the internet cannot always be guaranteed as completely secure. Therefore, Your use of the Platform will be at Your own risk. If you have any concerns, please feel free to contact us at [email protected].
XV. CHANGES AND UPDATES TO THE POLICY
We may modify or revise the Policy from time to time and shall accordingly notify You of any changes to the Policy by posting the revised Policy on the Platform with an updated date of revision. We shall endeavour to review, revise, update, modify, amend, or correct the Policy on a regular and routine basis, especially whenever a significant update is made to the technology employed by us. You must periodically review the Policy for the latest information on our privacy practices. In the event You continue to use the Platform and Our services after any update in the Policy, your use of the Platform shall be subject to such updated Policy. Your continued usage of Services, post any amendment, would deem to mean that You accept and understand the revised Policy. Further, we retain the right at any time to deny or suspend access to all, or any part of, the Service to anyone who we reasonably believe has violated any provision of this Policy.
XVI. DISCREPANCIES AND GRIEVANCES WITH THE COMPANY
In case of any discrepancy or grievance faced by the Users in India, with respect to all or any Personal Data shared with Company, please feel free to contact Our Grievance Officer:
[Attention: Rishabh Shekhar
Email ID: [email protected]o
Address: A-305, Dynasty Business Park, Andheri East, Mumbai – 400059]
[The Grievance Officer is identified above pursuant to the provisions of applicable laws, including but not limited to the Information Technology Act, 2000, and the Consumer Protection Act, 2019, and the rules enacted under those laws.]
For Users located outside India, any complaints or concerns with regards to content or comment or breach of the Terms of Usage/Policy may be informed to the designated Grievance Officer as mentioned below in writing or through email: [●] address: [●].
We assure You that we shall ensure implementation of the Policy and shall make the Policy available to individuals, and put our best efforts to redress the grievances of the User expeditiously within [1 (one)] month from the date of receipt of the grievance.
Please feel free to reach out to us by e-mail at [[email protected]] in case of any concerns, grievances, or questions relating to Our privacy or data related practices.
The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy.
This Policy does not apply to any information other than the Personal Data collected by Us through the Platform.
This Policy shall be inapplicable to any unsolicited information You provide Us through the Platform or through any other means. All unsolicited information shall be deemed to be non-confidential, and We shall be free to use and / or disclose such unsolicited information without any limitations.
The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by applicable laws.
Rights under this Policy may be waived only in writing. Any delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.