Section 43A of the Information Technology Act, 2000;
Regulations 3 and 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”).
If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at email@example.com.
WHAT INFORMATION DO WE COLLECT?
In Short:We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us and services or otherwise contacting us. The personal information we collect can include the following: first name, last name, and/ or nickname; phone numbers; email addresses; business email; business phone number; and other similar data. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).
HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time by unsubscribing.
Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties) tailored to offering you better services.
Request Feedback. We may use your information for feedback regarding our services.
To deliver services to the user. We may use your information to help deliver our services more effectively
To respond to user inquiries/offer support to users. We may use your information to contact you in order to serve your queries.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with select third parties that allow us to undertake the activities mentioned in section 2.
We only share your data in ways that we tell you about. We may share your Personal Information in the following manner:
By using it for Estoot’s social media engagement. However in such case we do not include your address, email ID, contact number;
By publishing online and offline for company reports and promotional and marketing material. However in such case we do not include your address, email ID, contact number.
Any in-house publication
Any in-house content generation activities.
To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Except for the third parties described above, to third parties only with your consent.
HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented best practices and security policies, rules and technical measures to protect data including Personal Information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to your electronic devices through which you use the website, we shall not be held liable for any loss whatsoever incurred by you.
As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing to firstname.lastname@example.org
We shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond our reasonable control including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your privacy rights at any time.
We respect your rights and control over your Personal Information. You may exercise any of the following rights:
Request access to the Personal Information that we process about you;
Request that we correct inaccurate or incomplete Personal Information about you;
Request deletion of Personal Information about you;
Request restrictions, temporarily or permanently, on our processing of some or all Personal Information about you;
Request transfer of Personal Information to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and
Opt-out or object to our use of Personal Information about you where our use is based on your consent or our legitimate interests.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
In the event that Estoot Digital Pvt. Ltd. becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Estoot Digital Pvt. Ltd. will promptly investigate the matter and notify the applicable Supervisory Authority as soon as possible after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org or by post to:
Estoot Digital Pvt. Ltd.
4th Floor, Capital Business Center, Veritas Building
Gurgaon, HR 122001
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please get in touch at email@example.com. We will respond to your request within 30 days.
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