1. Introduction

Telenity Systems Software India Private Limited (hereinafter referred to as “Telenity” “Company”, “We”, “Us” or “Our”) recognises the importance of maintaining your privacy. We value your privacy and appreciate your trust in Telenity. This Privacy Policy sets out how Telenity uses and protects any Personal Information that you share with us when you access our Platform for the purpose of availing the Services from Telenity.

This Privacy Policy sets out the requirements for ensuring that the Personal Information shared by you while accessing our Platform is collected, used, retained and disclosed in a secure and compliant manner.

All terms capitalized herein but not defined shall have the meaning ascribed to such term under the Terms of Use.

2. Scope of Coverage

This Privacy Policy applies to all current and former visitors and users of the Platform, employees, contractors, vendors, interns, associates, customers and business partners who may receive Personal Information, have access to Personal Information collected or processed, or who provide information to the Telenity, regardless of the geographical location.

By sharing Personal Information or registering for, accessing, using, and/or downloading any content on the Platform or the Services, you hereby consent to the collection, storage, use, processing and disclosure of such Personal Information in accordance with this Privacy Policy and you confirm that such use of Personal Information is in accordance with the provisions of this Privacy Policy shall not cause any wrongful loss to you and/or any third-party including the End User.

3. Personal Information that we collect

Telenity shall only collect such Personal Information that is required for providing the Services in accordance with the Master Agreement and/or Terms of Use for a particular purpose or purposes. Telenity shall have no obligation to ensure the correctness or validity of such information. Personal Information that may be collected by Telenity includes:

• Contact Details and Geographical Location:Phone number(s), email address(es), geographical location of the End Users or your geographical location.

• Transaction Information: Information related to your use of the Services, including the full Uniform Resource Locators (URL), the type of Services requested or provided to you, comments, domain names, search results, number of clicks, information and pages viewed and searched for, the order of those pages, length of your visit to our Services, the date and time with respect to use of the Services.

• Other Information:Our servers automatically record information (“Log Data”) created by your use of the Digital Platform. Log Data may include Transaction Information and Contact Details and Geographical Location, as well as information such as your IP address, browser type, operating system, the referring web page, pages visited, your mobile carrier, device, search terms, and cookie information. We receive Log Data when you interact with our Digital Platform. We use Log Data to provide our Services and to measure, customize, and improve them, as well as collect and use them in the aggregate.

4. How we collect the Personal Information:

• Personal Information collected directly from you: This is the information, including but not limited to identity, contact details, geographical location of the End Users or your geographical location or any other attitudinal or demographic information, submitted by you through the Platform. Furthermore, it includes information you provide when you register to use the Platform, avail the Services including any comment or query raised by you, participate in a promotion or survey, or other activities commonly carried out in connection with the Platform.

• Personal Information collected passively by Telenity: This Personal Information includes information regarding the usage of Platform by way of tracking tools like Google Analytics, Log Data.

• Personal Information received from third parties and publicly available sources: Telenity may receive Personal Information about you from various third parties and public sources including but not limited to any digital application store, analytics providers, advertising networks, search information providers and identity and contact data from publicly available sources.

5. Purpose of collection and processing of Personal Information

As you use, access and navigate the Platform or use the Services, Telenity may collect various Personal Information which may or may not be Personal Information. Telenity may, use, process and disclose such Personal Information including the Personal Information for purposes connected with its business activities including rendering the Services to you and for other reasonable and legitimate purposes. Without forgoing the generality of the aforementioned, such Personal Information may be used by Telenity for the following purposes:

• To provide Services: Personal Information provided by you enables Telenity to provide access to Platform and render Services;

• To improve customer service:Personal Information provided by you helps Telenity respond to customer service requests and support needs more efficiently;

• To improve the Platform or Services:Telenity may use the feedback provided by you to improve its products and Services;

• To send periodic communications:Telenity may use your contact details to respond to its inquiries, questions, and/or other requests;

• To run marketing campaigns, contest, survey or other Platform features: To send the Personal Information to you that it has agreed to receive about topics that may be of interest to you;

• For legitimate Interest:Where it is necessary for our legitimate interests (or those of a third party);

• Under regulatory obligations:To comply with any and all laws applicable to you and/or Telenity.

6. Disclosure and Transfer of Personal Information

Telenity may disclose the Personal Information to third party service providers who work on behalf of or with Telenity to provide the Services, to help Telenity to communicate with you or to maintain or render Services. You hereby provide your consent to share the Personal Information with such third party service providers. Telenity undertakes all such transfers strictly in accordance with applicable law. Generally, these third party service providers do not have any independent right to share this Personal Information, however, certain service providers who provide services on the Platform, including the providers of online communications services, online payment gateway services, mobile network operators will have rights to use and disclose the Personal Information collected in connection with the provision of these services in accordance with their own privacy policies.

Telenity may share the Personal Information with third parties who have a need or authority to receive such Personal Information, if Telenity on good-faith basis believes that access, use, preservation or disclosure of such Personal Information is reasonably necessary to comply with: (a) the orders of any authority having right to receive such Personal Information under laws applicable to Telenity; (b) any order of court; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) protect against harm to the rights, property or safety of Telenity, Telenity’s users/customers, End Users or the public as required or permitted by under laws applicable to Telenity and/or you. You hereby consent to such disclosure or transfer of your Personal Information in such instances, and Telenity shall have no obligation to inform you of such disclosure.

Further, from time to time, Telenity may make Personal Information available to other third parties including Telenity’s affiliates, sub-contractors, consultants, Service partners or other entities for fulfilling the purposes specified under Clause 5 of this Privacy Policy

Notwithstanding anything elsewhere set out in the Privacy Policy, it is clarified that any use or disclosure of Personal Information submitted on the Platform shall not be in any manner contrary to laws applicable to Telenity, as may be amended from time to time.

7. Cookies

Cookies are technologies that are used in analyzing trends, administering the site, tracking users’ movements around the Platform and to gather demographic information about Platform’s user base as a whole. Third-parties may use cookies to serve ads based on your use of the Platform. Telenity uses cookies on the Platform in order to personalize the Services for you. You may use the website of the third party and choose to opt-out of the use of cookies for interest-based advertising if the third party offers such an option.

You may set your browser to block all cookies (including but not limited to session ID cookies, persistent cookies, cookies associated with our Services), or to indicate when a cookie is being set by Telenity.

In the event the cookies are enabled, Telenity may place cookies on your device that store small amounts of data on its device about your use of the Platform. Cookies can identify the pages that are being viewed and this can assist Telenity in tracking which of Platform’s features appeal the most to you and what content you may have viewed.

8. Security of Personal Information

Platform has a risk management program that includes periodic risk assessment and provide an adequate framework of controls that safeguards the Personal Information.

Further, all information or data available, collected, provided through the Platform including Personal Information, any derivatives thereof is processed and/or stored on the servers provided by Cloud Based Web Services (“CBWS”). Telenity has implemented commercially reasonable technical and organizational measures designed to secure Personal Information, any derivatives thereof from accidental loss and from unauthorized access, use, alteration or disclosure through CBWS which are published by CWBS at [●]. Telenity currently uses Amazon Web Services (“AWS”) as the CBWS service provider, but Telenity reserves the right to replace AWS at any time with another provider of CBWS.

9. Retention of Personal Information

Telenity shall retain Personal Information for as long as necessary for the fulfillment of the purpose(s) for which it was collected, providing the Services, internal analysis purpose, resolution of disputes, establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing Telenity’s agreements, and comply with laws applicable to Telenity.

10. Compliance with Laws

The contents of this Privacy Policy are governed by the laws of India. You are not allowed to use the Services of the Platform if any of the terms of this Privacy Policy are not in accordance with the applicable laws of your country.

Further, please note that the Telenity’s stores the Personal Information with the cloud platform of CWBS, who may store this data on their servers located in India. Currently, The privacy policy adopted by the current CWBS are detailed in https://aws.amazon.com/privacy/.

11. Change in Privacy Policy

Telenity reserves the right to change the Privacy Policy at any time it may deem fit without consent from you. In the event Telenity decided to modify the Privacy Policy, it shall inform you by email along with the new Privacy Policy.

12. Contact Us

In case of any queries relating to the processing or usage of Personal Information provided by you in connection with this Policy or other privacy concerns, you may email Telenity at  [email protected]