This Privacy Policy (“Policy”) outlines Creador Conscientia LLP’s and its affiliates’ (collectively, “Creador”, “we”, or “us”) practices in relation to the collection, storage, use, processing, and disclosure of personal data that you have chosen to share with us when you access our website available at https://www.multiply.org.in (“Website”) or the mobile application made available on the Google PlayStore at https://play.google.com/store/apps/details?id=com.stagingmultiplyorgin.myapp (“App”). The Website and App are collectively referred to as the “Platform”.
At Creador, we are committed to protecting your personal data and respecting your privacy. Please read this Policy carefully to understand our practices regarding your personal data and how we treat it. The Policy sets out the basis on which any personal data that we collect from you or that you provide to us will be processed by us.
This Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us, nor does it affect any right that we may have at law in connection with the collection, use, disclosure, or retention of your personal data.
Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in our Terms and Conditions, available at https://staging.multiply.org.in/en/terms-and-conditions/ (“Terms”). Please read this Policy in consonance with the Terms.
1. BACKGROUND AND KEY INFORMATION
a) This Policy applies to all individuals who access or use the Platform or Services (“you”).
b) By interacting with us, submitting information to us, or using the Platform, you confirm that you have read this Policy and consent to the collection, use, disclosure, and/or retention of your personal information in accordance with the processing activities described under this Policy.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
a) Personal data is information that relates to a natural person which, either directly or indirectly, or in combination with information that is available or likely to be available with us, is capable of identifying such person. It does not include data where the identity has been removed (for example, anonymised data).
b) We may collect, use, store, and transfer different kinds of personal data about you in connection with your use of the Services, including but not limited to:
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- Identity and profile-related data: This includes identity data, including first and last name, username, passwords, date of birth, and gender;
- Contact data: This includes contact details including email address, alternate email address, and phone number;
- Technical and device data: This includes technical data, including IP addresses, browser types and versions, internet service provider details, time zone settings, location data, details of operating systems, access time, device ID, device type, and other technology on the devices you use to access the Services;
- Usage data: This includes information about how you use the Services, your activity on the Platform, user taps and clicks, time spent on the Platform, page views, and links you click on the Platform; and
- Marketing and communications data: This includes marketing and communications data including your preferences about receiving marketing from us and your communication preferences, any feedback you provide to us, and survey responses.
c) We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature of the Platform. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
d) What happens if I refuse to provide my personal data?
Where we need to collect personal data by law, or under the terms of a contract (such as the Terms), and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with the Services). In this case, we may have to cancel or limit your access to the Services, but we will, where reasonably practical, notify you if this is the case at the time.
3. HOW WE COLLECT PERSONAL DATA
We use different methods to collect and process personal data about you, including through:
a) Direct Interactions. You provide us with your personal data when you interact with us. This includes personal data you provide when you, for example:
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- create an account or profile with us at the time of registration;
- use the Platform or the Services;
- enter a promotion, user poll, or online surveys;
- request marketing communications to be sent to you; or
- report a problem with the Platform and/or our Services, give us feedback, contact us, or provide testimonials.
b) Automated technologies or interactions. We automatically collect technical and device data about your equipment, browsing actions, and patterns each time you use the Services. We collect this personal data by using cookies, web beacons, pixel tags, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites that use our cookies.
c) Third parties and publicly available sources. We receive personal data about you from various third parties and public sources including those set out below:
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- analytics providers such as Google and Facebook;
- search information providers;
- identity and contact data from publicly available sources.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data where we need to provide you with access to the Platform or the Services, or where we need to comply with a legal obligation. We use your personal data for the following purposes:
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- to verify your identity and create your user account with us on the Platform at the time of registration;
- to provide the Services to you;
- to monitor your activities on the Platform;
- to monitor trends and personalise your experience;
- to improve the functionality of our Services based on the information and feedback we receive from you;
- to improve customer service to effectively respond to your requests, grievances, and support needs;
- to send periodic notifications to manage our relationship with you including to notify you of changes to our Services, and to receive occasional company news and updates related to us or the Services;
- to assist with the management of the Services offered to you, including to send you information and updates about the Services you have availed of;
- to administer and protect our business and the Services, including for troubleshooting, data analysis, system testing, and performing internal operations;
- to improve our business;
- to perform our obligations that arise out of the arrangement we are about to enter or have entered with you;
- to enforce our terms and conditions;
- to market our Services to you;
- to comply with our legal obligations; and
- to respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims.
b) By using our Services or accessing the Platform, you authorise us, our associate partners, and affiliates to contact you via email, phone, WhatsApp messaging, or otherwise. This is to enable us to provide the Services, provide you with marketing material, and ensure that you are aware of all the features of the Services.
c) You allow us to collect, compile, and share any and all information pertaining to you, whether or not you directly provide it to us (via the Services or otherwise), including but not limited to personal correspondence such as emails, instructions from you, etc., in order to render the Services to you. This may include but not be limited to vendors, social media companies, third party service providers, storage providers, data analytics providers, consultants, lawyers, and auditors. We may also share this information with our group entities in connection with the above-mentioned purposes.
d) You authorise us to share data without your consent when it is required by law or by any court or government agency or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.
5. COOKIES
a) We collect data using cookies. Cookies are small data files which are sent to your browser and are stored on your computer or device (hard drive) to recognise your browser and to capture and remember certain information.
b) We use cookies to help us understand and save your preferences for future visits, keep track of advertisements, and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. This helps us to provide you with a good experience when you use or browse our Platform and allows us to improve the Platform and Services.
c) The cookies shall enable you to access certain features of the Platform and Services. Most web browsers and devices can be set to notify you when you receive a cookie or prevent cookies from being sent. If you do prevent cookies from being sent, it may limit the functionality that we can provide when you visit the Platform.
d) Additionally, you may encounter cookies or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of the cookies by third parties. If you send us personal correspondence, such as email or letter, or if other users or third parties send us correspondence about your activities or postings on the Platform, we may collect such information into a file specific to you.
6. DISCLOSURES OF YOUR PERSONAL DATA
a) We may share your personal data with third parties set out below for the purposes set out in Clause 4:
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- Internal third parties, such as our affiliates; and
- External third parties, such as:
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- trusted third parties such as our associate partners and service providers that provide services to us or on our behalf. This includes hosting and operating our Platform, providing marketing assistance, conducting our business, transmitting content, and to enable us to provide the Services to you;
- analytics service providers and advertising networks that conduct web analytics to help us improve our Platform and Services. These analytics providers may use cookies and other technologies to perform their services; and
- regulators and other bodies, as required by law or regulation.
b) We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. ACCESSING AND UPDATING YOUR PERSONAL DATA
a) You must ensure that all personal data that you provide us with is accurate, up-to-date, and true. When you use our Services, we make best efforts to provide you with the ability to access and correct inaccurate or deficient data, subject to any legal requirements.
8. TRANSFER OF PERSONAL DATA
a) We comply with applicable laws in respect of storage and transfers of personal data. As a part of your use of the Services, the information and personal data you provide to us may be transferred to and stored in countries other than the country you are based in. This may happen if any of our servers are from time to time located in a country other than the one you are based in, or one of our service providers is located in a country other than one you are based in.
b) By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data in the manner described above.
9. THIRD-PARTY SERVICES
a) The Platform may, from time to time, contain services provided by or links to and from the websites of our partner networks, advertisers, and affiliates (“Third Party Services”). Please note that the Third Party Services that may be accessible through our Platform have their own privacy policies. We do not accept any responsibility or liability for such policies or for any personal data that may be collected through the Third Party Services. Please check their policies before you submit any personal data to such websites or use their services.
b) We may use third party user experience improvement services (including but not limited to those provided by Google LLC and/or its affiliates) and applications to better understand your behaviour on the Platform.
c) Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit or restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.
d) The place of processing information depends on each third party service provider, and you may wish to check the privacy policy of each of the service providers to identify the data shared and its purpose. You will be subject to a third party’s privacy policy if you opt in to receive communications from third parties. We will not be responsible for the privacy standards and practices of third parties.
10. DATA RETENTION
a) You are aware that your personal data will continue to be stored and retained by us for a reasonable period after we accomplish the purpose for which it was collected and/or after the expiry or termination of the Terms and this Policy in compliance with the applicable laws.
b) In some circumstances, we may aggregate or anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
11. DATA SECURITY
a) We implement appropriate security measures to protect your personal data from unauthorised access, and follow standards prescribed by applicable law.
b)However, you agree and acknowledge that the abovementioned measures do not guarantee absolute protection to your personal information, and by accessing the Platform you agree to assume all risks associated with disclosure of personal information arising due to breach of firewalls and secure server software.
12. BUSINESS TRANSITIONS
a) You are aware that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.
13. UPDATES TO THIS POLICY
a) We regularly review and may occasionally update this Policy. If we make changes to this Policy, we will notify you of the changes through the Platform or through other reasonable means. We encourage you to periodically review this Policy for the latest information on our privacy practices.
b) To the extent permitted under applicable law, by accessing our Platform or Services after such notice, you consent to updates made to this Policy.
14. CONTACT US
You may contact us at [email protected] for any enquiry relating to this Policy or your personal information (for example, accessing, reviewing, updating, or seeking deletion of your personal information). You can also do so by writing to our Grievance Officer at the address provided below:
Name: Surya Banda
Address: 207, 2nd Floor, Vikas Center, 96/A, CG Rd, Chembur East, Mumbai, Maharashtra 400074, India
Email: [email protected]
