1.1 Galton Technologies Private Limited, (hereinafter referred to as " Galton Technologies," or "us," or "we"), a company incorporated and existing under the provisions of the Companies Act, 1956/ 2013 having its registered office at 201, Tower-D, Pioneer Urban Square, Sector-62, Golf Course Ext. Road, Gurugram 122018, Haryana, India, is committed to protecting theprivacy rights of its user(s) and recognizes the need for appropriate protection and management of any Personally Identifiable Information (hereinafter referred to as “PII”) that is shared by the user(s) by operation of its web-based software i.e. via website https://app.zepth.com and mobile application named “ZEPTH” (hereinafter jointly referred to as “Portal”).
1.6 As used in this Policy, “Personally Identifiable Information or PII” shall mean and include any information that alone or in combination with other information relates to a specific, identifiable individual person. By way of illustration and not limitation, PII includes individuals’ names, personal identification numbers such as individual’s mobile number, email address, home or office address, age, occupation, location, birth date and any other information provided by the User which is of personally identifiable form.
2.1 Users who use and/or register on the Portal will be requested to provide their PII. The PII is used for efficient service and better user experience for the User.
2.2 By accessing the Portal, the User consents to collection, storage, and use of the PII provided by him/her (including any changes thereto as provided).
2.3 Galton Technologies may enter into agreements with third parties to store or process information/ data of Users. These third parties may have their own security standards to safeguard the information or data of Users and Galton Technologies will on commercial reasonable basis require from such third parties to adopt reasonable security standards to safeguard information / data of Users.
2.4 Galton Technologies respects the privacy of the Users and is committed to reasonably protect
it in all respects. The types of information about the User which may be collected by Galton
Technologies are as follows:
i. information supplied by Users
ii. information automatically tracked while navigation
iii. information collected from any other source (collectively referred to as “Information”)
Information supplied by Users
While signing up on or accessing the Portal, the information of the user is collected, including but not limited to:
Galton Technologies may also collect information through the User’s interaction with and use of the Portal which does not reveal the User’s specific identity or does not directly relate to an individual. Such information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, Portal usage data, demographic information, geographic or geo-location information, statistical and aggregated information.Information collected from any other source
Galton Technologies may receive information about the User from other public sources, add it to the User account information and treat it in accordance with this policy. Galton Technologies may obtain updated contact information available in public domain from third parties in order to correct records and provide the Services or to communicate with the User.
3.1 The PII of the User(s) may be used to set up and administer the User’s account, provide necessary technical support, verify identity of User(s) and send important communication.
3.2 The PII of the User(s) may be used to deliver advertising, marketing and event-based communication. Such communication may contain option to opt out of receiving such communications in future. If the User choses to opt out of receiving such marketing and event-based communication by emailing at email@example.com, then Galton Technologies shall not contact such User and will ensure that new data collected about the User(s) from then on will not be used by Galton Technologies for any targeted advertising purposes. However, Galton Technologies may use existing information of the User(s) to customize the Portal accordingly.
3.3 Galton Technologies may use the PII of the User(s) for internal and external research and development purposes and to improve and test the features and functions of the Portal for giving the best options to the Users.
3.4 Galton Technologies’ access to this information is limited to authorized personnel with a critical business reason, such as technical support.
3.5 Galton Technologies may use and retain the PII of the User(s) for legal and compliance
reasons, such as the prevention, detection, or investigation of a crime; loss prevention; fraud,
or to meet our internal and external audit requirements, information security purposes, and or
which is required
a) under applicable law
b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and
other public and government authorities,
c) to enforce the Galton Technologies Terms and Conditions; and
d) to protect the Galton Technologies’ rights, privacy, safety, or property, or those of other persons.
3.6 Galton Technologies does not sell information about its Users to any person or entity whatsoever. However, during development of its business, Galton Technologies may sell or buy companies or assets. In such transactions, customer or user information may be transferred to such companies or assets.
Galton Technologies may also use the PII of the User(s) collected for the following purposes-
i. to facilitate various programs and initiatives launched by Galton Technologies or third-
party service providers and business associates;
ii. to analyze how the Portal are used, to measure the effectiveness of advertisements, to facilitating payments;
iii. to protect the integrity of the Portal;
iv. to conduct analytical studies on various aspects including user behavior, user preferences etc.;
v. to determine any security breaches, computer contaminant or computer virus;
vi. to investigate, prevent, or take action regarding illegal activities and suspected fraud;
vii. to undertake forensics of the concerned computer resource as a part of investigation or internal audit;
viii. to enhance ability of Galton Technologies to communicate with Users and customers about additional services;
ix. to trace computer resources or any person who may have contravened or is suspected of having or being likely to contravene, any provision of law including the Information Technology Act, 2000 that is likely to have an adverse impact on the Portal.
x. To provide technical assistances requiring initial setup, support services or dealing with any suspicious activities from the user accounts.
Galton Technologies may share User information with third parties, including service providers, regulated institutions), affiliated entities, payment processing service providers and business partners for the following purposes:
4.1. Information may be shared with the Galton Technologies’ service providers and affiliates to assist in operation of the activities on the Portal.
4.2 Information may be shared with fraud prevention and detection service providers for the purpose of detecting and preventing fraudulent activity.
the Portal is being used, and customize the same as per the User’s needs and choices.
Additionally, cookies may be used to remember choices, such as language preferences, and
otherwise to customize services for the User.
A cookie in no way gives Galton Technologies access to the User’s computer or any information about them, other than the data they choose to share with Galton Technologies. The User(s) can choose to accept or decline cookies.
The "help" portion of the toolbar on most browsers will tell the Users how to prevent their browser from accepting new cookies, how to have the browser notify then when they receive a new cookie, or how to disable cookies altogether. However, cookies will allow Users to take full advantage of some of the Portal features and it is recommended to leave them turned on.
Galton Technologies maintains log files of the traffic that visits the Portal. Galton Technologies does not link any information gathered in these log files to PII. Log files are used to manage traffic loads and information technology requirements for providing reliable service.
The security of PII is important to Galton Technologies. Galton Technologies follows
generally accepted industry standards to protect the PII submitted by User(s). However, no
method of transmission over the Internet or method of electronic storage can be said to be
100% secure, therefore, while it is attempted to use commercially acceptable means to protect
PII, there is no guarantee of absolute security.
The User(s) is responsible for all uses of his/her username and password created at the time of signing up of Galton Technologies’ Portal. Please contact Galton Technologies immediately if the User(s) believes password has been misused. The Users shall be individually responsible for maintaining the confidentiality of their user name and password and for all activities occurring under their account. Galton Technologies shall not be liable for any misuse or unauthorized use of username and password of the User(s).
The PII of the User(s) will be kept by Galton Technologies for as long it is necessary to fulfil
the purpose for which it was collected, or as required or permitted by applicable laws. Galton
Technologies will cease to retain PII of users, or remove the means by which the data can be
associated with Users, as soon as it is reasonable to assume that such retention no longer
serves the purpose for which the personal data was collected, and is no longer necessary for
legal or business purposes.
Galton Technologies shall at all times assume that the information provided by the User(s) is correct, genuine and updated. Galton Technologies shall not be held liable for any false/ incorrect information/ data of the User/s. The User shall indemnify Galton Technologies in case of any loss, damage or injury caused to it due to the use or lawful disclosure of false data provided by the User(s).
It is contrary to this policy for User(s) to use Portal to effect or participate in any of the following activities:
Galton Technologies does not sell, trade, lend, transfer or disclose any PII collected from the
Technologies reserves the right to provide the PII to its employees or partners or agents who
have a need-to-know such information for the purpose of maintenance and development of
the Portal and enabling Galton Technologies to provide Services to the User(s). However,
this does not include trusted third parties such as contractors and vendors who assist Galton
Technologies in operating the Service, conducting business, or servicing the users, so long as
those parties agree to keep this information confidential.
Galton Technologies also reserves the right to disclose PII when special circumstances call for it, such as when disclosure is required by law or court order or when disclosure is, in the sole discretion of Galton Technologies, necessary to protect legal rights, including intellectual property rights.
Galton Technologies has appointed an internal data protection officer for the Users to contact if a User has any queries, clarifications or complaints regarding compliance with this Policy or relating to processing of information. The data protection officer’s name and contact information are provided below:Name: Ankit Maheshwari
User(s) are requested to please provide the following information in their query or complaint:
Galton Technologies reserves the right to revise, amend or modify this Policy at any time and in any manner, according to its requirement. Any change or revision will be posted on Galton Technologies’ Portal along with the date when the modification was made.
When the User uses the Portal, Galton Technologies makes good faith efforts to provide the User, as and when requested by the User, with access to his/her PII and User shall further ensure that any PII or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such PII or sensitive personal data or information to be retained by law or for legitimate business purposes. Galton Technologies asks individual users and entities to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and Galton Technologies may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.
While dealing with data subjects of the European Union, Galton Technologies takes measures to comply with General Data Protection Regulation, (GDPR, Regulation no. 2016/679). Under GDPR, User(s) have right to access their PII submitted to Galton Technologies for any purpose.
The consent provided to Galton Technologies for collection and use of PII may be withdrawn at any time by contacting at firstname.lastname@example.org