1.1 Zepth Technologies Private Limited, (hereinafter referred to as ” Zepth 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 122102, Haryana, India, is committed to protecting the privacy 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. COLLECTED INFORMATION
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 Zepth 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 Zepth Technologies will on commercial reasonable basis require from such third parties to adopt reasonable security standards to safeguard information / data of Users.
2.4 Zepth 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 Zepth 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:
- Contact Information (e.g., name, email address, phone number, billing or mailing address)
- IP address, geo location
- National identification numbers
- Date of birth
- Any other information that the User chooses to provide to us (e.g., by sending an email/otherwise contact us)
- Payment and Banking Information
Information automatically tracked while navigation
Zepth 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
Zepth 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. Zepth 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. USE OF PII
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 Zepth 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 Zepth Technologies for any targeted advertising purposes. However, Zepth Technologies may use existing information of the User(s) to customize the Portal accordingly.
3.3 Zepth 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 Zepth Technologies’ access to this information is limited to authorized personnel with a critical business reason, such as technical support.
3.5 Zepth 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 Zepth Technologies Terms and Conditions; and
d) To protect the Zepth Technologies’ rights, privacy, safety, or property, or those of other persons.
3.6 Zepth Technologies does not sell information about its Users to any person or entity whatsoever. However, during development of its business, Zepth Technologies may sell or buy companies or assets. In such transactions, customer or user information may be transferred to such companies or assets.
Zepth Technologies may also use the PII of the User(s) collected for the following purposes-
i. To facilitate various programs and initiatives launched by Zepth 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 Zepth 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.
4. SHARING OF INFORMATION
Zepth 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 Zepth 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.
A cookie in no way gives Zepth Technologies access to the User’s computer or any information about them, other than the data they choose to share with Zepth 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.
6. LOG FILES
Zepth Technologies maintains log files of the traffic that visits the Portal. Zepth 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.
7. THIRD PARTY LINKS
8. INFORMATION SECURITY
The security of PII is important to Zepth Technologies. Zepth 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 Zepth Technologies’ Portal. Please contact Zepth 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. Zepth Technologies shall not be liable for any misuse or unauthorized use of username and password of the User(s).
9. RETENTION OF INFORMATION
The PII of the User(s) will be kept by Zepth Technologies for as long it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. Zepth 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.
Zepth Technologies shall at all times assume that the information provided by the User(s) is correct, genuine and updated. Zepth Technologies shall not be held liable for any false/ incorrect information/ data of the User/s. The User shall indemnify Zepth 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:
- To send unsolicited mass e-mailings, whether or not such unsolicited e-mailings provoke complaints from the recipients;
- To engage in any of the foregoing activities using the service of another provider but channeling such activities through the Services.
- To falsify User(s) information provided in the Portal or to other User(s) of the Portal.
11. THIRD PARTY DISCLOSURES
Zepth 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 Zepth Technologies, necessary to protect legal rights, including intellectual property rights.
12. VIOLATION OF THE POLICY
Zepth 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: Tanuj Bhatia
Email id: firstname.lastname@example.org
Phone no. +91-9990976252
User(s) are requested to please provide the following information in their query or complaint:
- Identification of the information provided;
- Clear statement as to whether the information is PII or very sensitive personal information;
- Address, telephone number or email address of complainant;
15. REVISION OF POLICY
Zepth 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 Zepth Technologies’ Portal along with the date when the modification was made.
16. ACCESSING AND UPDATING PII
When the User uses the Portal, Zepth 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. Zepth Technologies asks individual users and entities to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and Zepth 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.
17. GENERAL DATA PROTECTION REGULATIONS
While dealing with data subjects of the European Union, Zepth 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 Zepth Technologies for any purpose.
18. WITHDRAWAL OF CONSENT
The consent provided to Zepth Technologies for collection and use of PII may be withdrawn at any time by contacting at email@example.com
19. USER ACKNOWLEDGEMENTS
- is clear and easily accessible and provide statements of Company policies and practices with respective to the Information;
- provides for the various types of personal or sensitive personal data of information to be collected;
- provides for the purposes of collection and usage of the Information;
- provides for disclosure of Information; and
- provides for reasonable security practices and procedures.
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