PRIVACY POLICY

This Privacy Policy (“Policy”) describes how the Xyberia Technologies Private Limited (“Company”, “We”, “XTPL” or “Our”) collect, protects and uses the personally identifiable information (“Personal information” or “Information”), the user (“You” or “User”) may provide to our website. This Policy also describes the choices the user with regard to our use of your information and how you can access and update the information.
The use of our Platform which includes Internet pages our website and our related websites, platforms, Services, Products and content (collectively referred to as “Services”) is possible without any indication of personal data; however, if a user wants to use our services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a user shall always be in accordance with the Information Technology Act, 2000 and published in accordance with the provisions of Rule 4 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“IT Rules, 2011”) and The General Data Protection Regulation (“GDPR”) applicable to XTPL.
When you visit our website and/or use our services in any manner, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites or Apps and our services and/or you may disagree to provide any further information to us.
Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. This policy is comprehensive in nature which informs the user about the critical aspects of data collection and usage. The salient features of this policy are as under:

1. The policy tells the user about the nature of the information that is collected which clearly indicates what information do we collect.
2. The policy is transparent about the manner in which the information is used.
3. The policy indicates the usage of tracking technologies such as cookies and others.
4. The policy is inclusive of the timelines of the information being stored with the company.
5. The policy guides the user about his/her/their privacy rights with respect to the information stored by the company.

1. Nature and purpose of the information that we collect:

   This section consists of indication about what type of personal and/or sensitive personal data or information collected by the company, as mandated by Rule 4 of the IT Rules, 2011.

   WHAT INFORMATION WE MAY COLLECT

   • Your IP Address;
   • Your location;
   • How you behave on the Website, (what pages you land on, how much time you spend, etc.);
   • What device you use to access the Website and its details (model, operating system, etc.);
   • Cookies and web beacon data;
   • Email address;
   • First name and last name;
   • Phone number;
   • Address, State, City, ZIP/Postal code.

2. Usage of information:

   This section deals with how do we as a company the information provided by you the user. The company believes to be fully transparent about the information kept with it and how the company uses it. The company uses the information for the purposes based on legitimate business interests, the fulfilment of our contract with 3 | Page the user and compliance with the legal obligations. The company uses the information in the following manner:

   HOW WE USE THE INFORMATION?

   • We use this information to analyse and identify your behaviour and enhance the interactions you have with the Website.
   • If you submit your details and give us your consent, we may use your data to send you e-mails/newsletters, re-target XTPL advertisements or re-market our Services using services from third-parties like Facebook and Google.
   • We collect this data in order to help you register for and facilitate provision of our Services.
   • We use this data to enable you to make payments for our Services. We use a thirdparty service provider to manage payment processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of payment processing on our behalf.
   • We use this data for processing your requests, enquiries and complaints, customer services and related activities.
   • We use this data for processing your requests, enquiries and complaints, customer services and related activities.
   • We also use this data to provide you with informative features and services that are developed by us from time to time.
   • We also use this data for providing, testing, improving, or recommending the Services.
   • We also use this data to provide support to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law or anti-fraud activities/systems.
   • We also use this data to provide support to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law or anti-fraud activities/systems.

3. Cookies and other tracking technologies.

   COOKIES

   Cookies are text files which are sent from our server and downloaded to your device when you visit our website. They are useful because they allow us to recognize your device when you return. You can disable them through your browser should you so wish. We use cookies to see which parts of our website are used by Registered Users/Visitors and to record the number of visits to our website.
   Usually, browsers have default setting to accept cookies until you change your browser settings. You can choose to reject and remove cookies from our website by changing your browser settings. If you reject or remove our cookies, it could affect how our website works.
   For the avoidance of any doubt, we should clarify that in the event we anonymize and aggregate information collected from you, we will be entitled to use such anonymized data freely, without any restrictions other than those set out under applicable law.

   WEB BEACON

   Web beacon (also known as Clear GIF, Web Bugs or Pixel Tag) is a tiny picture file embedded on the Website/App that tracks your behaviour and navigation. It is similar to a cookie in what it does, but it does not get downloaded on to your device. We use web beacons to manage cookies, record visits, and to learn marketing metrics. We also use web beacons to track and monitor email opening rates as well as link clicks.

   WEB ANALYTICS

   We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Website through the use of first party cookies and third-party cookies, to, among other things, analyze and 5 | Page track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Website, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors.
   Google Analytics which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
   You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
   For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

4. Timelines of the information.
   We will store any personal data we collect from you as long as it is necessary in order to facilitate your use of the Services and for ancillary legitimate and essential business purposes – these include, without limitation, for improving our Services, attending to technical issues, and dealing with disputes.
   Your personal data will primarily be stored in electronic form. We may enter into agreement with third parties to collect, store, process your personal data but under full compliance with applicable laws. We may need to retain your personal data even if you seek deletion thereof, if it is needed to comply with our legal obligations, resolve disputes and enforce our agreements. If you are a Registered User, please be advised that after you terminate your usage of a Service, we may, unless legally prohibited, delete all data provided or collected by you from our servers.
   However, we will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 6 | Page No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.
   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, then we will securely store your personal information and isolate it from any further processing until deletion is possible.
5. Rights of the users.
   Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 permits our users who are Indian residents and The General Data Protection Regulation (EU) permits our users who are EU residents the right to review or amend the Sensitive Personal Data or Information (SPDI) and give the information provider an option to retract consent at any point of time, in relation to the information that has been so provided.
   In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) 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 this will not affect the lawfulness of the processing before its withdrawal.
   If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
   We do ensure that only authorised people within the organisation have access to the personal data harvested from Google Forms and they respect the company’s code of conduct regarding data protection.
6. Minor Privacy.
   Our Service does not address anyone under the age of 18 (“Minor”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Minor Child/Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers
7. Grievance officer.
   If you have any questions about this Privacy Policy, please contact us at founders@xyberiatech.com.
8. Minor Privacy.
   Our Service does not address anyone under the age of 18 (“Minor”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Minor Child/Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers
9. Changes to this Privacy Policy
   We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes.