- Section 43A of the Information Technology Act, 2000 (“IT Act”);
- Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and
- Regulation 3(1) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediaries Guidelines”).
Information Collected and Means of Collection
We may collect the following personal information about you:
If you are a customer, we may collect:
- name, contact number, email address of the authorized person to enable effective and prompt communication;
- details of Government identity documents to allow access to your employees/representatives, to data centers; and
- biometric information of employees/representatives, if required, for enhanced security reasons.
If you are an employee, we may collect
- name, contact details, email address and residential address;
- past employment records;
- bank account details;
- medical condition; or
- Any other information that may be required in the course of employment.
(collectively, “Personal Information”
Some of the personal information such as financial information, passwords, medical health, physiological condition or biometric information may be classified as sensitive personal data or information (“SPDI”).
The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of personal information, which is defined under the SPDI Rules as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person. The SPDI Rules further define sensitive personal data or information of a person as personal information about that person relating to:
You provide all information to us voluntarily. Collection, use and disclosure of Personal Information and SPDI require your express consent. You are providing us with your consent to our use, collection, and disclosure of the Personal Information and SPDI which belongs to your or any person whom you are authorized to represent. You may choose to not provide us with Personal Information and SPDI, but in the event that you do so, we will be unable to provide our Services.
Applicability of GDPR
What Personal/ Non-Personal Information do we Collect?
To request for a free demo, subscribe to our newsletter/alerts or to get in touch with us through the form available on our ‘contact us’ section or if you call us directly, you would need to provide us with Personal Information such as your name, organization, telephone number, e-mail address and physical address. We also collect the information shown in the comment when you leave your comments on our website.
We may also collect your Personal Information such as your name, e-mail address etc. when you communicate with our customer support staff using our chat support feature or through e-mail.
Website and social media accounts– We may also collect, store and use your Personal Information when you (1) access our social networking handles operated by us (such as those on Facebook, Twitter, Instagram and/or LinkedIn) (2) share or comment on our blogs (3) comment/ provide feedback/testimonials on such social networking handles.
We may also automatically collect non-personally identifiable information through cookies to improve our Website and Offerings, such as pattern of your use of the Website, our Offerings, visits, material that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information, IP address and date and time when you access or use website. Cookies are small encrypted files, that the Website transfers to the device through which you access our Website.
AdWords: We use Google AdWords as a marketing tool to allow the members of the public to reach out to us through our Website. We also collect and store information when you, in order to interact with us, click on our advertisement which is displayed on the Google search page and subsequently get directed to our Website.
Mouseflow: Mouseflow tracks clicks, mouse movement, scrolls, forms, and more. It shows an anonymized recording of the activity from each visitor on the Website. It helps us filter sessions to find ones with user frustration, errors, compatibility issues, etc.
Accuracy of information.
Please make sure that any Personal Information you share with us is accurate and up to date information. If you are sharing any Personal Information on behalf of a third person, you should ensure that you are authorized to do so.
Use of Information
We use the Personal Information for the following purposes:
- to provide you with information about our Offerings and/or our periodic newsletters;
- if we do engage in a business relationship, we may use the Personal Information to provide you such Offerings and to assist you in the
- event you need any additional support;
- for creation or development of business intelligence or data analytics in relation to our Website and/ or the Offerings provided by us;
- to assess queries, requirements, and process requests for products and services;
- for client communication, billing and administration;
- to improve the usability of the Website and for Website maintenance;
- to process job applications (if you apply for a position with our organization);
- to prevent fraud and abuse;
- to enhance the security of the Website;
- to ensure that content from the Website is presented in the most effective manner for you and for your computer;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to maintain leads;
- to run marketing or promotional campaigns;
- to create brand awareness;
- to improve the Offerings;
- to provide you with information that we may believe may be of your interest;
- for internal record keeping; and
- to comply with our legal or statutory obligations.
(collectively, the above constitute ‘the purposes’)
Legal Basis (for EU residents): We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal bases of consent [as provided in Art. 6 (1) (a) of the GDPR], contract [as provided in Art. 6 (1) (b) of the GDPR], or on the basis of our legitimate interests [as provided in Art. 6 (1) (f) of the GDPR], provided that such interests are not overridden by your privacy rights and interests.
Disclosure of Information
We do not sell, rent, share, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Information in the following cases:
- Service Providers: We may share your Personal Information with the service providers who work with us in connection with operating and maintaining the Website and/ or providing the Offerings.
- Merger or Acquisition: We may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Website, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein.
- Legal and Regulatory Authorities: We may disclose your Personal Information in order to comply with our legal obligations/ court orders/ requests by Government authorities.
Changes to your information
You may review, correct, update, change or delete your Personal Information or SPDI by writing to us at the contact details specified below. You can delete any part of the Personal Information or SPDI or request us to delete the same, and we will comply with such requests within a reasonable time, unless we are required to keep certain information for legal purposes. You may update your Personal Information or SPDI at any point by writing to us at the details indicated below in the contact section.
We reserve the right to verify and authenticate your identity and your Personal Information in order to ensure accurate delivery of Services. Access to or correction, updating or deletion of your Personal Information or SPDI may be denied or limited by us if it would violate another person’s rights and/or is not otherwise permitted by applicable law.
Customers may opt-out of receiving notices of new or upgraded products from the Company or its partners by sending a request to firstname.lastname@example.org. In this request to email@example.com, customers must identify the service purchased from the Company, domain name (if applicable), contact information, and the date the service was purchased. However, customers may not opt-out of receiving information from the Company which is essential for maintaining or updating customers’ accounts or system information.
Transfer of Your Personal Information Across Borders (for EU Residents)
We have a worldwide presence through our regional sales or delivery centres. The Personal Information we collect (of EU residents) might be processed outside the EU at a secure centre in India and also on the cloud-based CRM system “Microsoft Dynamics” whose servers are located in India. We collect and transfer Personal Information outside the EU in accordance with the provisions of the GDPR. If you have questions, please contact us at firstname.lastname@example.org.
Retention of Information
- We endeavour to only collect only such Personal Information that is necessary for the purposes indicated here and to retain such data for no longer than is necessary for such purposes. The length of time Personal Information is retained, and criteria for determining that time, are dependent on the nature of the Personal Information and the purpose for which it was provided/ collected.
- Subject to this section, we will try to delete your Personal Information upon reasonable written request for the same. Please note, however, that there might be latency in deleting Personal Information from our servers and backed-up versions might exist even after deletion. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact email@example.com
Our Security Measures
We store your Personal Information on our servers located in India and also on cloud-based CRM system “Microsoft Dynamics” whose servers are located in India and this information is accessible to our personnel across our offices located globally. Although we provide appropriate firewalls and protections, we cannot warrant the security of any Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we assume no liability or responsibility for it. You are required to be careful to avoid “phishing” scams, where someone may send you an e-mail that looks like it is from us asking for your Personal Information.
Your Rights (For EU Residents)
You have the right to request us to let you know what Personal Information belonging to you do we hold in our possession, right to have us rectify or modify any such Personal Information, right to have us erase/delete your Personal Information, right to restrict us from processing such Personal Information, right to object to our use of your Personal Information. If you would like to exercise ANY of these rights, please contact firstname.lastname@example.org.
Links to Other Websites
Limitation of Liability
Governing Laws and Disputes
Changes to This Policy
Contact Our Redressal/Grievance Officer
In accordance with the IT Act and the SPDI Rules, the name and contact details of the Redressal/Grievance Officer are provided below:
Name: Mr. Ravindra Katti, Director
Address: Office No. 4 A1, 4th Floor, Gundecha Onclave, Kherani Road, SakiNaka, Andheri East Mumbai – 400 072,
Email ID: email@example.com
Changes to the Policy