Privacy Policy

Effective date: May 25, 2018. Last Updated: September 16, 2020

Creatorbox Softwares Private Limited, having its registered office at  18, 80 Feet Road, Koramangala, 4th Block, Bangalore- 560034, Karnataka, India (“Company” or “we” or “us”), is the owner of the website domain at  https://pushowl.com/  (“Platform”); and any service availed by users (hereinafter referred to as “you”, “your” or “User”)  through the Platform is conditioned upon your acceptance of the Terms and Conditions as available on Platform and this privacy policy (“Privacy Policy”).

THIS PRIVACY POLICY HAS BEEN DRAFTED AND PUBLISHED IN ACCORDANCE WITH THE INFORMATION TECHNOLOGY ACT 2000; THE INFORMATION TECHNOLOGY (AMENDMENT) ACT 2008; AND THE INFORMATION TECHNOLOGY (REASONABLE SECURITY PRACTICES AND PROCEDURES AND SENSITIVE PERSONAL DATA OR INFORMATION) RULES 2011. THIS PRIVACY POLICY CONSTITUTES A LEGAL AGREEMENT BETWEEN YOU, AS A USER OF THE PLATFORM AND US, AS THE OWNER OF THE PLATFORM. YOU MUST BE A NATURAL PERSON WHO IS AT LEAST 18 YEARS OF AGE.

• We are strongly committed to respecting your online privacy and recognize the need forappropriate protection and management of any personal information collected and/orcollated by us.

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• The purpose of this Privacy Policy is to ensure that there is an intact charter to collect, useand protect any personal and/or sensitive data collected by us. This Policy defines ourprocedure for collection, usage, processing, disclosure and protection of any informationobtained by us through the Platform.

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• Please be advised that any Information (as defined herein below) procured by us, shall be:

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• processed fairly and lawfully for rendering the Services (as defined in Terms ofService);

  a.

• obtained only for specified and lawful purposes, and not be used in any manner whichis against the law or policy in force in India (“Applicable Law”);

  b.

• adequate, relevant and not excessive in relation to the purpose for which it is required;

  c.

• able to be reviewed by the User, from time to time and updated-if need arises; and

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• not kept longer than for the time which it is required or the purpose for which it isrequired or as required by the applicable law.

  e.

• WE SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE SUSTAINED BY REASONOF ANY DISCLOSURE (INADVERTENT OR OTHERWISE) OF ANY DATA, IF THESAME IS EITHER (A) REQUIRED FOR SHARING YOUR INFORMATION FORLEGITIMATE PURPOSES; OR (B) WAS AFFECTED THROUGH NO FAULT, ACT, OROMISSION OF THE COMPANY.

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• BY USING THE SERVICES, YOU EXPLICITLY ACCEPT, WITHOUT LIMITATION ORQUALIFICATION, THE COLLECTION, USE AND TRANSFER OF THE DATA IN THEMANNER DESCRIBED HEREIN.

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• PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT AFFECTS YOUR RIGHTSAND LIABILITIES UNDER LAW.

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• Please note that by providing the Information (as enumerated upon herein below), youprovide your consent and authorize us to collect, use or disclose such Information for thebusiness and research purposes and as stated in this Privacy Policy, the Terms andConditions, and as permitted or required by applicable law. Moreover, you understand andhereby consent that this Information may be transferred to any third party user for thepurpose of providing services through the Platform or to any third-party providers forrendering Services (as defined in the Terms of Service), any jointly developed or marketedservices, payment processing, order fulfilment, customer services, data analysis,information technology services and such other services which enable us to provideServices through the Platform.

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• This Privacy Policy shall be enforceable against you in the same manner as any otherwritten agreement. By visiting or accessing the Platform and voluntarily providing us withInformation (including Personal Data), you are consenting to our use of Information, inaccordance with this Privacy Policy. If you do not agree with this Privacy Policy, you mayrefuse or withdraw your consent any time, or alternatively choose to not provide us withany Personal Information. Under such circumstance, we may be unable to renderServices.

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• Such an intimation to withdraw your consent can be send to contact@pushowl.com.

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• “Personal Data” means and includes any Information that relates to a natural personthrough which an individual is identified, such as the name, contact details, email address,gender, age or any other relevant material provided by a User, including but not limited toinformation gathered through availing Services, communications with the instructors. Itshall also cover information of User’s care person details (name, age, gender, mobilenumber, relationship with the User).

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• “Technical Information” means and includes any Information gathered through varioustechnologies that may employ cookies, web beacons, or similar technologies toautomatically record certain information from your device through which you use thePlatform. This technical information may include your Internet Protocol (IP) address, deviceor browser type, Internet service provider (ISP), referring or exit pages, clickstream data,operating system. This data includes usage information and user statistics.

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• “Locational Information” shall mean and include the information obtained through GPSor other means, such as the geographical location of the User.

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• “Non-Personal Information”

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• “Information through use of our service” means and includes information which isshared with us to avail our Services including but not limited to chats with instructors,Company’s representatives etc.

  a.

• “Non-Personal Information” means and includes any information that does not revealyour specific identity, such as, browser information, information collected throughCookies (as defined below), pixel tags and other technologies, demographicinformation, etc. As is true with most websites, our Company gathers some informationautomatically when you visit the Platform. When you use the Platform, we may collectcertain information about your computer or mobile to facilitate, evaluate and verify youruse of the Platform. For example, we may store environmental variables, such asbrowser type, operating system, speed of the central processing unit (CPU), referringor exit web pages, click patterns and the internet protocol (IP) address of yourcomputer. This information is generally collected in aggregate form, without identifyingany user individually.

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• The data collected by us shall be used for availing our Platform and utilised for otherfunctions including but not limited to:

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• to render Services (as defined in the Terms and Conditions);

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• maintaining the Platform;

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• to evaluate the quality and competence of our personnel;

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• to resolve any complaints, you may have and ensure that you receive the highestquality of Services;

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• notifying you about changes to our Platform;

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• allowing you to participate in interactive features of our Platform when You choose todo so;

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• providing analysis or valuable information so that we can improve the Platform;

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• monitoring the usage of the Platform;

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• detecting, preventing and addressing technical issues;

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• Business or Research Purposes: The Information saved and except Personal Information,is used for business or research purposes, including improving and customizing thePlatform for ease of use and the products and services offered by us. We may archive thisinformation to use it for future communications for providing updates and/or surveys.

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• Aggregating Information / Anonymized data: We may aggregate Information and analyse itin a manner to further accentuate the level of services that we offer to our customers. ThisInformation includes average number of Users of the Platform, the average clicks of theservices/, the features used, the response rate, etc.  and other such statistics regardinggroups or individuals. In doing so, we shall not be making disclosures of any PersonalInformation as defined above.

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• We do not rent, sell or disclose or share any Information that we collect from you, with thirdparties, save and except in order to provide you with the Services in accordance with thePrivacy Policy and as per the procedure prescribed by law and in compliance with our legalobligations. We may share your Information in circumstances and for the purposes asspecified hereunder:

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• We shall share the information to the third-party service providers/ vendors, toprovide you with the Services.

  a.

• When compelled by law: We may disclose any Information provided by you on thePlatform as may be deemed to be necessary or appropriate:

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• under applicable law, including laws outside your country of residence;

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• to comply with legal process;

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• to respond to requests from public and government authorities including publicand government authorities including public and government authoritiesoutside your country of residence;

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• to protect our operations or those of any of our affiliates;

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• to protect our rights, privacy, safety or property, and/that of our affiliates, youor others;

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• to allow us to pursue available remedies or limit the damages that we maysustain; or

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• to protect against legal liability;

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• to protect the personal safety of Users of the Platform;

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• to prevent or investigate possible wrongdoing in connection with the Platform.

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• Merger or Acquisition: We may share Information upon merger or acquisition ofCompany with another company. We shall transmit and transfer the Informationupon acquisition or merger of Company with another company;

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• With our service providers: We may share Information with other service providerson a need to know basis, subject to obligations of confidentiality for provision ofServices. We hereby clarify that Company works with institutions, vendors, partners,advertisers, and other service providers, including (but not limited) to those whoprovide products or services such as contact Information verification, websitehosting, data analysis, providing infrastructure, information technology services,auditing services and other similar services, in different industries and categories ofbusiness by virtue of lawful contracts instituted between such third parties andCompany to improve our product and services. Accordingly, we may share yourInformation with such service provider in order to provide you with Services;

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• Employees /Agents of Company: We follow a strict confidentiality policy with regardto disclosure of confidential information to our employees or other personnel. Theremay be situations, where we may disclose the confidential information only to thoseof our employees and other personnel on a need to know basis. Any breach ofconfidential information by the employees, personnel within the Company is dealtwith stringently by us.

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• Except for the Information disclosed pursuant to sub-clause (a), (b), (c), (d) and (e) ofClause 6.1 above, Company may share Information, if you authorize us to do so.

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• Your information may be transferred to, and maintained on, computers located outside ofyour state, province, country or other governmental jurisdiction where the data protectionlaws may differ from those from your jurisdiction.

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• If you are located in India and choose to provide information to us, please note that wemay process the Information in India or outside India.

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• Your consent to this Privacy Policy followed by your submission of such informationrepresents your agreement to that transfer.

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• We will take all steps reasonably necessary to ensure that your data is treated securelyand in accordance with this Privacy Policy and no transfer of your data will take place to anorganization or a country unless there are adequate controls in place including the securityof your data.

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• access, confirm, and review Personal Information you may have provided;

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• correct Personal Information that may be inaccurate or irrelevant;

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• deletion and erasure of your Personal Information from the publicly available pagesof the Platform;

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• receive Personal Information we hold about you in a portable format;

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• object to or restrict any form of processing you may not be comfortable with;

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• Our Platform may utilize “cookies” and other Technical Information. “Cookies” are a smalltext file consisting of alphanumeric numbers used to collect the Information about Platformactivity. The Technical Information helps us analyse web traffic and helps you bycustomizing the Platform to your preferences. Cookies in no way gives us access to yourcomputer or mobile device. In relation to Cookies, you can deny access to the installationof the Cookies by modifying the settings on your web browser, however, this may preventyou from taking full advantage of the Platform.

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• Our use of Cookies and Technical Information allows us to improve Platform and yourexperience of Platform and Services. We may also analyse Technical Information thatdoes not contain Personal Information for trends and statistics.

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• In case of any discrepancy or grievance with respect to all or any Information shared withCompany, please feel free to contact our Grievance Officer:Attention: Shashank KumarEmail ID: shashank@pushowl.comAddress: 18, 80 Feet Road, Koramangala, 4th Block, Bangalore- 560034, Karnataka,India.

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• We assure you that we shall ensure implementation of the Privacy Policy and shallmake the Privacy Policy available to individuals and put our best efforts to redress thegrievances of the User expeditiously within one (1) month from the date of receipt of thegrievance.

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• Please feel free to reach out to us by e-mail at contact@pushowl.com in case of anyconcerns, grievances, or questions relating to our privacy or data related practices.

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YOUR ACCEPTANCE OF THE PRIVACY POLICY

BY USING OR VISITING THIS PLATFORM, YOU SIGNIFY YOUR AGREEMENT OF THIS POLICY. IF YOU DO NOT AGREE TO ANY OF THESE TERMS, PLEASE DO NOT USE THIS PLATFORM OR SERVICES.

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