SCOPE AND APPLICABILITY OF THIS POLICY
TYPES OF PERSONAL DATA OR INFORMATION WE COLLECT
The term “personal data or information” (Info) in this Policy refers to personal information which does identify You and/or is capable of identifying You as an individual. The types of Info that We may collect consist of following personal information relating to You, including but not limited to Name, Address, Mobile Phone Number, E Mail Address, Location and Browsing habits.
Provided that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Info for the purposes of this Policy.
We respect Your privacy rights, therefore, We will observe the following guidelines when collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling, and disclosing:
• Info will be collected, received, possessed, used, processed, recorded, stored, transferred, dealt, handled and disclosed in compliance with applicable Indian laws;
• Info will be collected for specified, legal and legitimate purposes and shall be used for the purpose for which it has been collected;
• Info will be relevant/necessary to/for the purposes for which it is collected and used;
• Info will be kept only as long as necessary for the purposes for which it was collected and processed; and
• Appropriate prescribed measures will be taken to prevent unauthorized access or use, unlawful processing, and unauthorized or accidental loss, destruction, or damage to such Info.
PURPOSES FOR COLLECTION, STORAGE AND/OR USE OF PERSONAL DATA OR INFORMATION
The primary purposes for collection, storage and/or use of Info is for:
• Our business processes, operations and management including but not limited to performance of the business, operation of the services, entering into or performing any contract, maintaining quality of the services, providing support to the products You have obtained from Us;
• processing order(s), corresponding with You, fulfilling Your transaction requests and delivering the products requested by You;
• providing You with information or products that You request from Us or which We feel may interest You, record keeping and other general administrative and services related processes;
• ensuring the safety and protection of Our rights or property or Our business;
• complying with applicable legal requirements including but not limited to governmental reporting, etc. and fulfilling statutory/legal obligations under applicable laws, adhering to judicial or administrative orders, compliance with laws;
• contacting You via surveys to conduct research about Your opinion of current services or of potential new services that may be offered by Us;
• monitoring or recording of certain calls, chats and other interactions relating to the online transactions which may involve You calling Us or Us calling You and online chats for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction;
• while conducting daily business/operations such Info may be provided to Our affiliates and associate companies, Our employees/staff and Third Party for the purpose of processing such Info for or on Our behalf including but not limited to helping Us to perform statistical analysis, send You email or postal mail, provide customer support/support services, arrange for deliveries of programs, products, information, and services etc.;
• direct marketing and promotional purposes;
• operating Website, improving the content of Our Website to offer You better products and/or services and to ensure that content from our Website is presented in the most effective manner for You;
• to help diagnose problems with Our server, and to administer Our Website. Your IP address is also used to help identify You and to gather broad demographic information;
• in connection with Our business;
• to preserve transaction history as governed by existing law or policy; and
• to serve various promotional and advertising materials to You via display advertisements through the Google Ad network on third party websites. You can opt out of Google Analytics for Display Advertising and customize Google Display network ads using the Ads Preferences Manager.
DATA COLLECTION DEVICES
We have also contracted with Third Party to track and analyze anonymous usage and volume statistical information from Our visitors and members for research purposes. Such information is shared externally only on an anonymous, aggregated basis. Such Third Party use persistent cookies to help Us to improve the visitor experience, to manage Our Website content, and to track visitor behavior. All data or information collected by such Third Party on Our behalf is used solely by Us or on Our behalf and is shared externally only on an anonymous, aggregated basis.
We will make best efforts to do so but do not warrant that Our Website is free of any operational errors nor do We warrant that Our Website will be free of any virus, computer contaminant, worm, or other harmful components.
You acknowledge that Our Website, its services and contents are provided on an “as is” and “as available” basis, without warranties of any kind, either express or implied. We expressly disclaims that any service will be uninterrupted, timely, secure or error-free for any reasons whatsoever including but not limited to overload / breakdown of receiving network, servers or applications; system failures out of Our control or due to heavy traffic on network”.
DISCLOSURES OR TRANSFER OF YOUR INFO
We will disclose or transfer Your Info in accordance with this Policy and all applicable legal requirements. Your Info will be disclosed or transferred, as may be required from time to time, as follows:
• For Business Purposes: to (i) the appropriate employees/staff/persons in Our offices; (ii) Our affiliates and associate companies; (iii) to Our different offices within India and outside India in accordance with the IT Act; (iv) to any Third Party, in the event of a proposed or actual business transfer; and (v) in connection with Our business and services provided by Us.
• To Third Parties: working with Us or on Our behalf in different industries and categories of business. We will disclose, share, transfer or provide Your Info to any Third Party in connection with Our business requirements or for the purposes indicated herein. Such Third Party are required to process Your Info they receive from Us in a lawful, safe and responsible manner in accordance with this Policy and the prevailing laws and take all appropriate security and confidentiality measures such that they do not use Your Info for their own purposes or disclose Your Info to others. Neither We nor any Third Party will publish Your Info.
• For Legal Requirement: to any court of law and/or government agencies/entity as may be required under law and/or statutory authority, Reserve Bank of India and Credit Information Bureau India Ltd (“CIBIL”) or in response to a legal process, for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences and/or to any Third Party by an order under the applicable law or if We determine it is necessary or desirable to comply with any applicable law regulation, legal process or enforceable governmental request or to protect or defend Our rights or property including compliance with accounting and tax rules and regulations or to investigate detect, prevent, or take action regarding illegal activities, suspected fraud, security or technical issues or situations involving potential threats to the physical safety of any person.
• For Centralized Data Processing Activities: We have centralized certain aspects of Our data processing and administration in order to allow Us to manage Our business in better ways. Such centralization may result in the transfer of Your Info: (i) from one country to another; (ii) to Our employees/staff of the affiliates/associate companies of Zilo in other locations etc. However, whenever Your Info is transferred within Zilo, it will be processed in accordance with the terms and conditions of this Policy.
We have in Our Website, stringent security measures in place to protect the loss, misuse, and alteration of the information under Our control. Whenever You change or access Your account information, We offer the use of a secure server. Once Your information is in our possession We adhere to strict security guidelines, protecting it against unauthorized access. We take appropriate security measures to protect Your Info against unauthorized access, alteration, disclosure or destruction.
We limit access to Your Info to members of Our team/Our employees /Third Party who We believe reasonably need to come into contact with that information for the purpose of performing their duties. We have strict confidentiality obligations that apply to such members/Our employees /Third Party.
RETENTION OF YOUR INFO
We are aware of the importance of timely destruction of Info. We ensure that Your Info is not stored/retained for a longer period than necessary for the purpose for which it was collected, used or processed or as provided in Our contracts except when there is a legal obligation to do so under any law. It is our practice to destroy Your Info as soon as possible after it is no longer necessary for the purpose for which it was collected, used or processed save and except as stated hereinabove.
UPDATING OR REVIEWING YOUR PERSONAL DATA OR INFORMATION/ QUESTIONS OR COMPLAINTS
You can review the Info provided by You any time. We will ensure that any change done by You in Your Info shall be included as soon as possible. You expressly state that Info provided by You to Us is correct and complete in all respects and does not contain any false, distorted, manipulated, fraudulent or misleading facts. We expressly disclaim any liability arising out of the said data or information provided by You to Us. Further, You expressly agree that We are not responsible for the accuracy and authenticity of such data or information provided by You to Us and You agree to indemnify Zilo for all losses incurred by Zilo due to any false, distorted, manipulated, defamatory, libelous, vulgar, obscene, fraudulent or misleading facts made by You to Zilo.
All Our affiliates/group companies will ensure that this Policy is observed. All Our employees/staff of and Third Party who have access to Info are required to comply with this Policy.
All Third Party shall only process the Info in accordance with Our instructions or make decisions regarding such data or information as part of the delivery of their services. In either instance, We will select reliable Third Party who undertake, by contract or other legally binding and permissible means, to put in place appropriate technical and organizational security measures to ensure an adequate level of protection of such data or information. We will require Third Party to comply with this Policy or to guarantee the same levels of data protection that is adhered to by Us when handling/processing such data or information. Such selected Third Party will have access to such data or information solely for the purposes of performing the services specified in the applicable service contract and are legally and contractually bound to maintain the privacy of such data or information shared with them and will not disclose it further. If We conclude that a Third Party is not complying with these obligations, We will promptly take appropriate actions to remedy such non-compliance or implement necessary sanctions.
Additionally, Our team members/employees/staff are bound by internal confidentiality policies. Any team member/employee/staff found to have violated this Policy or any other policies will be subject to disciplinary action, up to and including termination of employment and/or penalties under applicable laws. All Third Party and Our team members/employees/staff do hereby specifically agree that he/she/it shall, at all times, comply with the requirements of the IT Act, while collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling and disclosing Info. The said Third Party and team members/employees/staff do further unequivocally declare that in case he/she/it violates any provisions of the IT Act, he/she/it shall alone be responsible for all his/her/its acts, deeds and things and that he/she/it alone shall be liable for civil and criminal liability there under or under any other law for the time being in force.
MODIFICATIONS TO THE POLICY
We reserve the right to update, change or modify this Policy, from time to time, without prior notification. The policy shall come into effect from the date of such update, change or modification. We will inform You regarding any such changes by updating this Policy and will post all changes to the Policy on the Website. Effective with the implementation of this Policy, applicable Zilo privacy guidelines or practices relating to the processing of Info will be superseded by the terms of this Policy and modified accordingly. All parties to any such agreements will be notified of the effective date of implementation of the Policy. If any of the terms or definitions used in this Policy is ambiguous, the definitions established under the IT Act shall apply.
YOUR CHOICES AND SELECTING YOUR PRIVACY PREFERENCES
We give you the choice of receiving a variety of information that complements our products. You can subscribe to receive certain product information like new updates, upcoming products and Our general communications like offers, sale, discount or invitations to participate in market research or compliance reviews. We give you a choice regarding delivery of Our general communications by postal mail, email, telephone, or mobile device.
Subscription communications include email newsletters, etc. that may be expressly requested by You or which You consented to receive. After You request such communications, You may opt out of receiving them by using one of the following methods:
Select the emails “opt out” or “unsubscribe” link, or follow the opt-out instructions included in each email subscription communication.
Be sure to provide Your name, relevant contact information, and specific relevant information about Our subscriptions that you no longer wish to receive. Please be aware that when You opt out of receiving certain subscription communications, it may affect the services You have chosen to receive from Zilo where accepting the communications is a condition of receiving the services.
This option does not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings or other administrative and transactional notices where the primary purpose of these communications is not promotional in nature.
CORRECT INACCURACIES IN THE INFORMATION
To correct or update any information you have provided, the Website allows you to do it online. In the event of loss of access details you can send an e-mail to: firstname.lastname@example.org