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SCOPE AND APPLICABILITY OF THIS POLICY
TYPES OF SENSITIVE PERSONAL DATA OR INFORMATION WE COLLECT
- The term “Sensitive Personal Data or Information” in this Policy refers to personal information which does and/or is capable of identifying You as an individual. The types of Sensitive Personal Data or Information that We may collect consist of following personal information relating to You:
- name, gender, home address, telephone number, date of birth, marital status, email address, emergency contacts or other contact information (including the gender, age, nationality and passport information of any relatives and beneficiaries);
- photographs; racial or ethnic origin, nationality and passport information; religious or philosophical beliefs;
- financial information such as bank account/credit card/debit card or other payment instrument details; taxpayer identification number;
- physical, physiological and mental health condition; sexual orientation;
- medical and health records and history; biometric information;
- affiliations, interests, work history, technical skills, educational background, professional certifications and registrations, language capabilities, training courses attended;
- voicemails, e-mails, password, correspondence and communications;
- About the pages You visit/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.
- the results of credit and criminal background checks, screening, health certifications, driving licence number, vehicle registration and driving history;
- information required to comply with laws, statutory obligations, the requests and directions of law enforcement authorities or court orders;
- acknowledgements regarding SA 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 SA; and
- any of the information received under above clauses by SA 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 We collect is the data or information that is willfully and knowingly 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.
- YOUR CONSENT
We will obtain Your permission in writing through a letter or fax or email (“Consent”) before collecting Your Sensitive Personal Data or Information with respect to the purpose of usage of such data or information. If You give Your Consent, it means You have done so freely and voluntarily and agree to this Policy. You always have the right to refuse 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 are 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 that the Sensitive Personal Data or Information is being collected;
- purpose for which the Sensitive Personal Data or Information is being collected;
- intended recipients 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, SA will observe the following 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;
- Sensitive Personal Data or Information 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 current 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; and
- Appropriate measures will be taken to prevent unauthorized access or use, unlawful processing, and unauthorized or accidental loss, destruction, or damage to such Sensitive Personal Data or Information.
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:
- 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 or services You have obtained from us, managing company assets;
- processing Your order, corresponding with You, fulfilling Your transaction requests and delivering the programs, products, information, and services requested by You or other services related inquiries;
- 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 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 the rights or property of SA 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;
- 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 Sensitive Personal Data or Information may be provided to affiliates and associate companies, employees/staff of SA and 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;
- 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; and
- in connection with the business of SA.
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 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 parties 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 or on behalf of SA 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 SA. SA 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, SA nor any of its affiliates are responsible for the availability of such third party websites or their contents. SA 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, acknowledges and agree that neither SA 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 on an “as is” and “as available” basis, without warranties of any kind, either express or implied, including, without limitation, implied warranties of merchantability, fitness for a particular purpose. Although SA has taken adequate safeguard and in case of any breach SA shall take action to remedy such breach. In addition to taking all the reasonable precautions as required under law, SA 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 SA’s control or due to heavy traffic on network”.