Last updated August 17, 2019
TABLE OF CONTENTS :
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- WHO WILL YOUR INFORMATION BE SHARED WITH?
- DO WE USE GOOGLE MAPS?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DATA PRIVACY LAWS IN INDIA
- THE DATA (PRIVACY AND PROTECTION BILL), 2017
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data. We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or Apps or otherwise contacting us. The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following: Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data. Credentials. We collect passwords, password hints, and similar security information used for authentication and account access. Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions. Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS” below. 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 automatically collected In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites or Apps. We automatically collect certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. Information collected through our Apps in Short: We may collect information regarding your mobile device, push notifications, when you use our apps. if you use our Apps, we may also collect the following information:
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s storage, social media accounts, SMS messages, reminders, sensors, contacts, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. Information collected from other sources In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources. We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
2. 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 Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below. We use the information we collect or receive:
- To facilitate account creation and logon process. If you choose to link your account with us to a third-party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGINS” for further information.
- 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 (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites or Apps.
- To post testimonials. We post testimonials on our Sites or Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at Support@varsangini.com and be sure to include your name, testimonial location, and contact information.
- Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
- Request Feedback. We may use your information to request feedback and to contact you about your use of our Sites or Apps.
- To protect our Sites. We may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
- To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
- To enforce our terms, conditions and policies.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- 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 Sites or Apps, products, services, marketing and your experience.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, 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 in 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: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps 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.
- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
- Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following third parties. We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
- Advertising, Direct Marketing, and Lead Generation Google Ad Sense and Bing Ads
- Content Optimization Fonts.com Web Fonts, Adobe Edge Web Fonts, GitHub social plugins, Mail Chimp widget plugin and YouTube video embed
- Data Backup and Security Google Drive Backup and Dropbox Backup
- Invoice and Billing Cashfree, Razor-pay, Paytm and BHIM UPI
- Retargeting Platforms Facebook Custom Audience, Google Analytics Remarketing and Facebook Re marketing
- Social Media Sharing and Advertising Facebook advertising, Google+ social plugins, Instagram advertising, Whats-app, LinkedIn social plugins, Pinterest advertising, YouTube social plugins, Twitter advertising and Tumbler social plugins
- User Account Registration and Authentication Facebook Login, Google Sign-In, Twitter OAuth and Google OAuth 2.0
- User Commenting and Forums Facebook Comments
- Web and Mobile Analytics Google Analytics
- Website Hosting Siteground
- Website Testing Google Website Optimizer
6. DO WE USE GOOGLE MAPS?
7.HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. 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 appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. you have certain rights under applicable data protection laws. These may include the right (I) to request rectification or erasure; (II) to restrict the processing of your personal information; and (III) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 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.
Account Information If you would at any time like to review or change the information in your account or terminate your account, you can:
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DATA PRIVACY LAWS IN INDIA
In Short: Yes, When the Information Technology Act, 2000 (hereinafter referred to as the “IT Act”) first came into force on October 17, 2000 it lacked provisions for protection and the procedure to be followed to ensure the safety and security of sensitive personal information of an individual. This led to several other amendments and bills being passed and finally The Information Technology (Amendment) Act, 2008 inserted Section 43A in the IT Act which notified the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (hereinafter referred to as the “2011 Rules”). The key features of 2011 Rules are:
- These 2011 Rules only apply to body corporate and persons located in India. Section 43A of the IT Act explicitly provides that whenever a corporate body possesses or deals with any sensitive personal data or information, and is negligent in maintaining a reasonable security to protect such data or information, which thereby causes wrongful loss or wrongful gain to any person, then such body corporate shall be liable to pay damages to the person(s) so affected.
- A list of items has been provided which are to be treated as “sensitive personal data” which include passwords, biometric information, sexual orientation, medical records and history, credit/ debit card information, etc. but any information which is freely available or accessible in the public domain is not considered to be sensitive personal data.
- The body corporate must establish reasonable security practices for maintenance of confidentiality of such data, obtain consents from persons for collecting such sensitive personal data for lawful and necessary purpose.
- The purpose must be clear and information used only for such consent as given and data to be retained only till such time as needed.
- The 2011 Rules also provide Grievance Office who shall be responsible to address grievances of information providers within 1 month for resolution of such Grievances. Body corporate must have an audit of the reasonable security practices and procedures implemented by it by an auditor at least once a year or as and when the body corporate or a person on its behalf undertake significant up gradation of its process and computer resources.
- The punishment for disclosure of information in breach of lawful contract and imprisonment under the IT Act may be for a term not exceeding three years, or with a fine which may be Indian Rupees 5 million or with both.
13. THE DATA (PRIVACY AND PROTECTION BILL), 2017
Recently, a Bill was introduced in Parliament proposing to bring privacy under the ambit of legislation. This is not the first Bill on privacy introduced in Parliament. However, this Bill is different from the previous Bills in the sense that it seeks to make the consent of an individual for collection and processing of personal data mandatory. The Bill states that the individual will have the sole right and the final right to modify or remove personal data from any database, public or private. In the context of sensitive and personal information, the person must provide his or her express and affirmative consent for the collection, use, storage of any such data.
This Bill applies not only to private corporations or body corporate, but is equally applicable to state entities, government agencies or any other persons acting on their behalf. Even the definition of a “third party” under this Bill includes the public authorities. This symbolizes a significant change in law from the existing regime under the IT Act and 2011 Rules in India.
However, with respect to sensitive, personal data, Section 20(2) provides that no sensitive data shall be processed for any other purpose apart from its intended use but can be used by welfare schemes and social protection laws. Hence, this would imply that the Aadhaar scheme, as mentioned earlier, would also have access to a person’s personal, sensitive information. This Section is analogous with the present dispute at the Supreme Court and will continue to be subject to debate due the existing privacy concerns.
Although this Bill, which is still pending to be passed into legislation, is much more in line with the stricter GDPR norms it is unlikely to come into force until the pending litigation regarding the Aadhaar scheme comes to a conclusion regarding the use of the Government of the personal, sensitive data of the residents in India.
14. DO WE MAKE UPDATES TO THIS POLICY?
15.HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If You Have Questions or Comments About This Policy,
You May Email Us at Support@Varsangini.Com,
Contact Us +91 6356004366,
By Post To: Varsangini B-7, New T.T. Market Ring Road Surat, India 395002, India.