SCOPE AND APPLICABILITY OF THIS POLICY
PURPOSES FOR COLLECTION, STORAGE AND/OR USE OF SENSITIVE PERSONAL DATA OR INFORMATION
The primary purposes for collection, storage and/or use of Sensitive Personal Data or Information is for:
- Corresponding with You, delivering the programs, information, and services requested by You or other services related inquiries;
- Maintaining quality of the services, providing support to the products or services You have obtained from us, managing company assets;
- To conduct surveys/research about Your opinion of current services or of potential new services that may be offered by us.
- Managing Client Contacts profiles including but not limited to the business relationship between the Clients and Client Contacts, administering and developing our business relationship with You, providing You with information, products or services forthcoming schemes, discounts during festive seasons, ensuring the safety and protection of the rights or property of Celio or its business.
- Complying with applicable legal requirements including (but not limited to) governmental reporting, etc., and fulfilling statutory/legal obligations as a service provider under applicable laws, adhering to judicial or administrative orders, compliance with laws.
- While conducting daily business/operations such Sensitive Personal Data or Information may be provided transferred to affiliates and associate companies, employees/staff of Celio and/or Third Party’s for the purpose of processing such Sensitive Personal Data or Information 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.
- Our Website is presented in the most effective manner to You by making / improving the content of our Website to offer You better products and/or services.
KIND OF SENSITIVE PERSONAL DATA OR INFORMATION WE COLLECT
The “Personal Data and/or Information” referred to in this Policy refers to personal information which does and/or is capable of identifying You as an individual. It consists of the following personal information:
- Name, age, gender, residential address, telephone/ mobile number, date of birth, marital status, email address, emergency contacts or other contact information (including any of your relatives and beneficiaries).
- Affiliations, interests, work history, technical skills, educational background, professional certifications and registrations, language capabilities, training courses attended.
- E-mails, correspondence and communications.
- About the pages You are interested in visit, like/access, the links you click on our Website, the number of times you access the page, items bought by You, loyalty points, pre-nomination, notification, Opinions of features on our Website.
- Information required to comply with various laws, statutory obligations, the requests and directions of law enforcement authorities or court orders.
- Acknowledgements regarding Celio India policies, including ethics and/or conflicts of interest policies and computer and other corporate resource usage policies.
- Any detail relating to the above clauses as provided to Celio; and
- Any of the information received under above clauses by Celio for collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling and disclosing under lawful contract or otherwise.
Most of the Sensitive Personal Data or Information collected is the one that is willingly provided to us by You. However, in some instances, we collect Sensitive Personal Data or Information about You, based on our inferences about You, from other information provided to us by You or on our interactions with You or on such personal information about You that We receive from a third party with Your knowledge.
We will obtain your consent/permission in writing through a letter/fax/email/SMS/website before collecting Your Sensitive Personal Data or Information with respect to the purpose of usage of such data or information. On receiving your Consent, we consider that You have done so freely and voluntarily and agree to this Policy. You shall always have the right to refuse/decline or withdraw your Consent for the Sensitive Personal Data or Information sought to be collected or withdraw Your Consent given earlier to us. We will always respect such a refusal or withdrawal, but it might mean that We shall be unable to perform all services, arrangements or contracts with You and will have the option to discontinue the same. We will inform You of these inabilities, if they occur. However, We reserve the right to retain such Sensitive Personal Data or Information as may be necessary for providing our pending services to You and in accordance with this Policy.
We will while collecting Sensitive Personal Data or Information directly from You take such reasonable steps to ensure that You are aware of the –
- Fact and the purpose that the Sensitive Personal Data or Information is being collected for.
- Intended recipients/transferees of the Sensitive Personal Data or Information; and
- Name and address of the agency that is collecting the Sensitive Personal Data or Information and retaining the same.
- We respect Your privacy rights, therefore, Celio India will observe the following proper procedures/ guidelines when collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling, and disclosing:
- Sensitive Personal Data or Information will be collected, received, possessed, used, processed, recorded, stored, transferred, dealt, handled and disclosed in compliance with the local laws/regulations in the territory where those activities occur including IT Act; will be collected for specified, legal and legitimate purposes and shall be used for the purpose for which it has been collected.
- Sensitive Personal Data or Information will be relevant/necessary to/for the purposes for which it is collected and used.
- Sensitive Personal Data or Information will be completed/updated and accurate with reasonable steps taken to rectify or delete inaccurate Sensitive Personal Data or Information.
- Sensitive Personal Data or Information will be kept only as long as necessary for the purposes for which it was collected and processed;
- Appropriate measures will be taken to prevent hacking, unauthorized access or use, unlawful processing, and unauthorized or accidental loss, destruction, or damage to such Sensitive Personal Data or Information.
DATA COLLECTION DEVICES
We also use logging systems on our internal network to register the use of your computer systems. This is done for the purpose of ensuring the performance, integrity and security of these systems. We have also contracted with third party’s to track and analyse 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 parties use persistent cookies to help us to improve the visitor experience, to manage our Website content, and to track visitor behaviour. All data or information collected by such third party on our behalf is used solely by or on behalf of Celio India and is shared externally only on an anonymous, aggregated basis.
We will make best efforts to do so but do not warrant that any of the websites or any affiliate site(s) or network system linked to 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. Our Website contains links to other sites which are not owned or operated by Celio India. Celio India is not responsible and makes no guaranty for the privacy practices or the content of such websites. These links are provided only as a convenience to You. Neither, Celio India nor any of its affiliates are responsible for the availability of such third party websites or their contents. Celio India will not be liable for Your Sensitive Personal Data or Information transmitted over networks accessed by You of the sites or otherwise connected with Your use of the services. You understand, acknowledge, agree and accept that neither Celio India nor any of its affiliates are responsible or liable, directly or indirectly, for any damage or loss of any sort caused in connection with your use of or reliance on any content of any such site or services available through any such site.
You acknowledge that the services, content, site and/or any software are provided without warranties of any kind, either express or implied, including, without limitation, implied warranties of merchantability, fitness for a particular purpose. Although Celio India has taken adequate safeguard and in case of any breach Celio India shall take action to remedy such breach. In addition to taking all the reasonable precautions as required under law, Celio India expressly disclaims any and all warranties, express or implied, including, without limitation: (i) The services and/ or software will be free of all viruses and hacking. (ii) The software will work on all mobile phones, will be compatible with all mobile phone networks and/or will be available in all geographical areas. (iii) 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 the Celio India’s control or due to heavy traffic on network”.
DISCLOSURES OR TRANSFER OF YOUR SENSITIVE PERSONAL DATA OR INFORMATION
If Celio India wishes or is required to disclose the Sensitive Personal Data or Information collected from You to any Third Party, We will ask for Your prior Consent except when such disclosure has been agreed in the contract between Celio India and You or it is necessary to comply with a legal obligation or it is to be shared with Government agencies or to be disclosed to any third party by an order under law. Celio India will transfer, with Your Consent, the Sensitive Personal Data or Information to any other Third Party in India or overseas, which ensures the same level of data protection that is adhered to by Celio India as set out herein for fulfilling any contractual obligation.
We will disclose or transfer Your Sensitive Personal Data or Information in accordance with this Policy and all applicable legal requirements. Your Sensitive Personal Data or Information 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) from one office within Celio India to another office in India or overseas 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 Celio India.
- For Centralized Data Processing Activities: We have centralized certain aspects of our data processing and administration in order to allow us to better manage our business. Such centralization may result in the transfer of Your Sensitive Personal Data or Information: (i) from one country to another; (ii) to our employees/staff of the affiliates/associate companies of Celio India in other locations etc. However, whenever Your Sensitive Personal Data or Information is transferred within Celio India, it will be processed in accordance with the terms and conditions of this Policy.
- 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.
REASONABLE SECURITY PRACTICES AND PROCEDURES
We seek to ensure compliance with the requirements of the IT Act to ensure the protection and preservation of Your privacy, therefore We take appropriate security measures to protect Your Sensitive Personal Data or Information against unauthorized access, alteration, disclosure or destruction. We have a number of physical, electronic, and procedural safeguards/measures in place to actively protect the confidentiality, security, and integrity of Your Sensitive Personal Data or Information, including a comprehensively documented information security programme and a strict security policy that contains managerial, technical, operational and physical security control measures for protecting such data or information. We have implemented standard or code of best practices for data or information protection.
We limit access to Your Sensitive Personal Data or Information to members of our team/employees of Celio India 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/employees of Celio India’s. Failure to meet these obligations may result in disciplinary and other actions, including dissolution of a contract, termination of employment and criminal prosecution.
RETENTION OF YOUR SENSITIVE PERSONAL DATA OR INFORMATION
It is our practice to destroy Your Sensitive Personal Data or Information 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 herein below. We are aware of the importance of timely destruction of Sensitive Personal Data or Information. We ensure that Your Sensitive Personal Data or Information 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.
UPDATING OR REVIEWING YOUR SENSITIVE PERSONAL DATA OR INFORMATION
You may, by a written request review the Sensitive Personal Data or Information provided by You. We will ensure that any Sensitive Personal Data or Information about You which is found to be inaccurate or deficient shall be corrected or amended as may be feasible.
You expressly state that Sensitive Personal Data or Information 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 Celio India for all losses incurred by Celio India due to any false, distorted, manipulated, defamatory, libelous, vulgar, obscene, fraudulent or misleading facts made by You to Celio India.
In case of any discrepancies or grievances with regard to the processing of Your Sensitive Personal Data or Information, please write to email@example.com. Further on receipt of any concerns or complaints, the Grievance Officer will employ all commercially reasonable efforts to address the same within one (1) month of receipt of same.
All Celio India affiliates/group companies will ensure that this Policy is observed in absolutely strict compliance as required to do so. All employees/staff of Celio India and Third Parties (if any) who have access to Sensitive Personal Data or Information are required to comply with this Policy.
All Third Parties shall only process the Sensitive Personal Data or Information in accordance with Celio India’s instructions or make decisions regarding such data or information as part of the delivery of their services. In either instance, Celio India will select reliable Third Parties 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. Celio India will require Third Parties to comply with this Policy or to guarantee the same levels of data protection that is adhered to by Celio India when managing/handling/processing such data or information. Such selected Third Parties 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 Celio India concludes that a Third Party is not complying with these obligations, it 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 including penalties under applicable laws.
All Third Party’s and our team members/employees/staff do hereby specifically accept and 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 Sensitive Personal Data or Information. The said Third Parties’ 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
Celio India has the right to update, change or modify make amendments to 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 relevant internal and external websites.
Effective with the implementation of this Policy, applicable Celio India privacy guidelines or practices relating to the processing of Sensitive Personal Data or Information 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 are ambiguous, the provisions /definitions established under the IT Act shall apply.