Effective date: May 25, 2018. Last Updated: September 16, 2020
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.1.1
Please be advised that any Information (as defined herein below) procured by us, shall be:2.1
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; andd.
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.2.2
BY USING THE SERVICES, YOU EXPLICITLY ACCEPT, WITHOUT LIMITATION ORQUALIFICATION, THE COLLECTION, USE AND TRANSFER OF THE DATA IN THEMANNER DESCRIBED HEREIN.2.3
Such an intimation to withdraw your consent can be send to firstname.lastname@example.org
Types of information collected by us:
“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).4.1
“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.4.2
“Locational Information” shall mean and include the information obtained through GPSor other means, such as the geographical location of the User.4.3
“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.b.
(The Personal Data, Technical Information, Locational Information and Non-PersonalInformation are collectively referred to as “Information).
Purpose of Collection and Usage of this Information:
The data collected by us shall be used for availing our Platform and utilised for otherfunctions including but not limited to:5.1
to render Services (as defined in the Terms and Conditions);a.
maintaining the Platform;b.
to evaluate the quality and competence of our personnel;c.
to resolve any complaints, you may have and ensure that you receive the highestquality of Services;d.
notifying you about changes to our Platform;e.
allowing you to participate in interactive features of our Platform when You choose todo so;f.
providing analysis or valuable information so that we can improve the Platform;g.
monitoring the usage of the Platform;h.
detecting, preventing and addressing technical issues;i.
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.5.2
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.5.3
Disclosure and Sharing of Information:
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:b.
under applicable law, including laws outside your country of residence;i.
to comply with legal process;ii.
to respond to requests from public and government authorities including publicand government authorities including public and government authoritiesoutside your country of residence;iii.
to protect our operations or those of any of our affiliates;iv.
to protect our rights, privacy, safety or property, and/that of our affiliates, youor others;v.
to allow us to pursue available remedies or limit the damages that we maysustain; orvi.
to protect against legal liability;vii.
to protect the personal safety of Users of the Platform;viii.
to prevent or investigate possible wrongdoing in connection with the Platform.ix.
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;c.
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;d.
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.e.
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.6.2
Transfer of Information
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.7.1
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.7.2
You retain several rights in relation to your Personal Information as provided underapplicable law. These may include the rights to:
access, confirm, and review Personal Information you may have provided;a.
correct Personal Information that may be inaccurate or irrelevant;b.
deletion and erasure of your Personal Information from the publicly available pagesof the Platform;c.
receive Personal Information we hold about you in a portable format;d.
object to or restrict any form of processing you may not be comfortable with;e.
In order to exercise these rights, please contact us on the email address provided inClause 3.3 above.
If we become aware that we have collected Personal Data from children withoutverification of parental consent, we take steps to remove that information from our servers.
Control the collection or use of the Information
If you have any reservations, constraints or apprehensions regarding the access to,collection, storage, or any other use of the Information which you have provided to us, youmay withdraw your consent in the manner as set out in Clause 3.3 above.
Retention of Information
All Information provided by you, save and except upon withdrawal or termination, shall beretained in locations outside the direct control of Company (for instance, on servers ordatabases co-locates with hosting providers). We will delete Information based on arequest received from you within a reasonable period and latest within 90 (ninety) days ofreceiving a deletion request. However, we may retain such portion of Information and forsuch periods as may be required under Applicable Law. Notwithstanding anythingcontained herein, Company may retain data after account deletion for reasons includingbut limited to the following purposes: If there is an unresolved issue relating to youraccount, or an unresolved claim or dispute; If we are required to by applicable law; and/orin aggregated and/or anonymized form; or Company may also retain certain information ifnecessary for its legitimate business interests, such as fraud prevention and enhancingUsers' safety and security.
Cookies and other Tracking Technologies
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.12.1
Third Party Services
We may use your Information to send you promotional Information about third partieswhich, we think you may find interesting, if you tell us that you wish this to happen. Weshall not be responsible for any disclosure of Information due to unauthorized third partyaccess or other acts of third parties or acts or omissions beyond our reasonable controland you agree that you will not hold us responsible for any breach of security unless suchbreach has been caused as a direct result of our negligence or wilful default.
We use certain physical, managerial, technical or operational safeguards as per industrystandards and established best practices to protect the Information we collect. We usereasonable security practices and procedures and use secure servers as mandated underapplicable laws for the protection of your Information. We review our Information collection,storage, and processing practices, including physical security measures to guard againstunauthorized access to systems. However, as effective as these measures are, no securitysystem is impenetrable. We cannot guarantee the security of our database, nor can weguarantee that the Information you supply will not be intercepted while being transmitted tous over the internet. You accept the inherent security implications of data transmissionover the internet and the internet cannot always be guaranteed as completely secure.Therefore, your use of the Platform will be at your own risk. If you have any concerns,please feel free to contact us at the details given in clause 3.3.
Changes and updates to Policy
Discrepancies and Grievances with Company
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: email@example.comAddress: 18, 80 Feet Road, Koramangala, 4th Block, Bangalore- 560034, Karnataka,India.16.1
Please feel free to reach out to us by e-mail at firstname.lastname@example.org in case of anyconcerns, grievances, or questions relating to our privacy or data related practices.16.3
Governing Laws and Jurisdiction
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.
Effective date: May 25, 2018. Last Updated: May 24, 2018
Creatorbox Softwares Private Limited (PushOwl, “us” “our” or “we”) is the owner and operator of pushowl.com.
When you access the Website, or through any interaction with us via emails, telephone calls or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. You hereby consent to the collection of such information by PushOwl. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
- Contact Data such as name, mailing address, e-mail address, and PushOwl user-name, account number, and password;
- Demographic Data such as your zip code, age, and gender;
- Company Data such as your business name, size, and business type
PUSHOWL collects non-personally identifiable information from you regarding your usage of our Website ("Non-Personally Identifiable Information"). Non-Personally Identifiable Information may include, without limitation, Website pages viewed, articles, presentation and videos viewed, time spent using certain features of the Website, demographic data such as server locations, cookies existing on your computer, search criteria used and results, date, time, connection speed, and other information which does not specifically identify you. We collect this information using various technologies, including, but not limited to, cookies and server logs.
"Cookies" are pieces of information that may be placed on your computer by a Website for the purpose of facilitating and enhancing your communication and interaction with that Website. "Server logs" can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.
The Website also contain web beacons, which are electronic images that are used along with cookies to compile statistics so we can analyze how the Website is being used. Our e-mails may also contain web beacons so we can track how many people open the message or click on links within the message. This information helps us improve our communication and marketing efforts. By using this service we are able (for example) to see how many people visit a given page or clicked on a given link. This information helps us optimize the performance of the Website.
COLLECTION OF INFORMATION
PUSHOWL will use information to better serve you and enhance your experience with the Website. Here are some examples of the ways we use your information:
- To send you updates about the Website
- To administer your account
- To respond to customer service inquiries
- To send marketing materials
- To improve our Website and marketing efforts
- To meet any regulatory requirements
- To send you receipts
- To facilitate the processing of a transaction between you and a third party
PUSHOWL may make your information available on its Website and visible to other users of or visitors to the Website. For instance, subject to certain preferences and permissions as to visibility you will be allowed to make, information you provide about yourself in response to questionnaires on our Website may be made available to others. As such, other users of our Website may be able to personally identify you based on your information made available on our Website. As a further example, if you utilize Third Party Services to log into our Website, other users to whom you may be connected to through such Third Party Service may be able to view or follow information about you on our Website.
DISCLOSURE OF INFORMATION
(i) comply with a court order or other legal process,
(ii) to protect our rights or property,
(iii) in connection with our sale, merger, consolidation, change of control, or transfer of substantial assets, or
(iv) to enforce our Terms of Service. Please keep in mind that while we take reasonable precautions to safeguard your Personal Information no amount of protection can guarantee its security.
We may provide any of these services through third parties, which may necessitate sharing information with them.
PUSHOWL does not and will not sell any of your personal information to any third party for purposes of advertising, soliciting, or telemarketing. However, We may allow third-parties to serve ads and collect certain anonymous information when you visit the Website. These companies may use non-personally identifiable information during your visits to the Website and other Websites in order to provide advertisements about goods and services likely to be of interest to you.
PUSHOWL employs or contracts with other third parties, companies, or individuals to perform certain functions or services on its behalf. As such, these third parties, companies, or individuals may have access to your information, including Non-Personally Identifiable Information or Personally Identifiable Information, as needed to perform their functions or services, and may not use it for other purposes.
In addition to the above, our Website contains links to other Websites and services not maintained by PUSHOWL. In addition, other Websites and services may also reference or link to the PUSHOWL Website.
We employ procedural and technological security measures, which are reasonably designed to help protect your personal information from unauthorized access or disclosure. PUSHOWL may use encryption, passwords, and physical security measures to help protect your personal information against unauthorized access and disclosure. No security measures, however, are 100% complete and reliable. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or private communications will not be collected and used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. PUSHOWL shall not be responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your account via unauthorized password activity.
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this policy at any time. Any changes or updates will be effective immediately upon posting to the Website or sending a notification to all registered users via email regarding such update. You should review this notice regularly for changes. Your continued use of our Website following the posting of any changes to this notice means you accept such changes.
APPLICABLE LAW AND JURISDICTION