PRIVACY POLICY
REVISION HISTORY
| Ver No | Release Date | Change Description | Review Date | Approved By | Author |
|---|---|---|---|---|---|
1.0 | 08/01/2020 |
| 08/01/2020 | Shailendra | Judge Magnaye |
2.0 | 23/02/2022 |
| 23/02/2022 | Jaishankar | Kashish |
2.1 | 07/03/2022 |
| 07/03/2022 | Dhanesh | Jaishankar |
PLEASE READ THIS PRIVACY POLICY CAREFULLY.
INTRODUCTION
Peer Connexions respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and our mobile application, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”).
BY ACCESSING OR REGISTERING ON THIS SITE YOU AGREE THAT ANY PERSONAL DATA THAT YOU SHARE WITH US WILL BE GOVERNED BY THE PRIVACY POLICY DETAILED IN THIS DOCUMENT, IRRESPECTIVE OF WHICH COUNTRY YOU ARE A RESIDENT OF OR FROM WHICH COUNTRY YOU ACCESS OUR SITE.
IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE. BY REGISTERING TO AND USING THE SITE, YOU AGREE TO BE IMMEDIATELY BOUND BY THE TERMS AND CONDITIONS THEREOF AND BY THIS PEER CONNEXIONS PRIVACY POLICY.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the Revision History of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.
You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.
COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The information we may collect on the Site includes:
PERSONAL DATA
Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information that you voluntarily give to us when you register with the Site or when you choose to participate in various activities related to the Site. We do not collect your Gender information or Photograph, for you to access our website. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site and our mobile application.
DERIVATIVE DATA
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. If you are using our mobile application, this information may also include your device name and type, your operating system, your phone number, your country, your likes and replies to a post, and other interactions with the application and other users via server log files, as well as any other information you choose to provide.
Financial information, such as data related to your payment method (e.g., valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site or our mobile application. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processors.
MOBILE DEVICE DATA
Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.
THIRD-PARTY DATA
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.
MOBILE APPLICATION INFORMATION
If you connect using our mobile application:
- Geo-Location Information We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Data. We may collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and IP address.
- Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, use of such information collected about you via the Site, or our mobile application may include the following:
- Administration of promotions and rewards on the site.
- Compile anonymous statistical data and analysis for use internally or with third parties.
- Create and manage your account.
- Deliver targeted advertising, promotions, coupons, newsletters, and other information regarding promotions and the Site and our mobile application to you.
- Enable user-to-user communications.
- Fulfil and manage purchases, orders, payments, and other transactions related to the Site and our mobile application.
- Generate a personal profile about you to make future visits to the Site and our mobile application more personalized.
- Increase the efficiency and operation of the Site and our mobile application.
- Monitor and analyse usage and trends to improve your experience with the Site and our mobile application.
- Notify you of updates to the Site and our mobile applications.
- Offer new products, services, mobile applications and/or recommendations to you.
- Assist law enforcement if needed.
- Perform other business activities as needed.
- Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
- Process payments and refunds.
- Request feedback and contact you about your use of the Site and our mobile application.
- Resolve disputes and troubleshoot problems.
- Respond to product and customer service requests.
- Send you a newsletter.
- Solicit support for the Site and our mobile application; and
- Other related uses.
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
DATA PRIVACY LAWS
We implement generally accepted best practices with respect to data privacy. We will endeavour to follow local laws of every country of operation, whenever the same are notified. The status with respect to notification of Data Privacy laws in our countries of operations are as follows:
- India – Not Notified yet
- Indonesia – Not Notified yet
- Philippines – Philippines Republic Act No 10173
- Singapore – Personal Data Protection Act 2012
- Sri Lanka – Not Notified yet
- Thailand – Personal Data Protect Act 2019.
BY LAW OR TO PROTECT RIGHTS
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
THIRD-PARTY SERVICE PROVIDERS
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
MARKETING COMMUNICATIONS
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
INTERACTIONS WITH OTHER USERS
If you interact with other users of the Site and our mobile application, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, and following blogs.
ONLINE POSTINGS
When you post comments, contributions or other content to the Site or our mobile applications, your posts may be viewed by all users and may be publicly distributed outside the Site and our mobile application in perpetuity.
THIRD-PARTY ADVERTISERS
We may use third-party advertising companies to serve advertisements when you visit the Site or our mobile application. These companies may use information about your visits to the Site and our mobile application and other websites that are contained in web cookies to provide advertisements about goods and services of interest to you.
AFFILIATES
We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
BUSINESS PARTNERS
We may share your information with our business partners to offer you certain products, services, or promotions.
BUSINESS PARTNEROTHER THIRD PARTIES
The necessity to transfer PII data to third parties or across jurisdictions will be determined on one or more of the following criteria.
- The transfer of PII data is required in order to enable the business of the user on the platform
- The transfer of PII data is necessary in order for the 3rd party service provider to provide the services for which he is contracted and that these services are beneficial to the users of the platform and
- The transfer of PII data is mandated by law.
SALE OR BANKRUPTCY
If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur, and that the transferee may decline honour commitments we made in this Privacy Policy.
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
SALE OR BANRUPTCY
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
TRACKING TECHNOLOGIES
COOKIES AND WEB BEACONS
We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site and our mobile application to help customize the Site and our mobile application and improve your experience. When you access the Site or our mobile application, your personal information is not collected using tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies but be aware that such action could affect the availability and functionality of the Site or our mobile application. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.
INTERNET-BASED ADVERTISING
Additionally, we may use third-party software to serve advertisements on the Site and our mobile application, implement email marketing campaigns, and manage other interactive marketing initiatives.
WEBSITE ANALYTICS
We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Site and our mobile application using first party cookies and third-party cookies, to, among other things, analyse and track users’ use of the Site and our mobile application, determine the popularity of certain content and better understand online activity. By accessing the Site, or our mobile application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors.
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
THIRD-PARTY WEBSITES
The Site and our mobile application may contain links to third-party websites and applications of interest, including advertisements and external services that are not affiliated with us. Once you have used these links to leave the Site or our mobile application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site or our mobile application.
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
STANDARD OF CARE
We shall exercise at least the same degree of care as we use with our own data and confidential information in safekeeping Personal Data, but in no event less than reasonable care, to protect the same from misuse and unauthorized access or disclosure.
SAFEGUARDS AND UNDERTAKINGS
We shall use appropriate safeguards to protect the Personal Data from misuse and unauthorized access or disclosure, including but not limited to:
- Maintaining physical controls and password protections for any server or system in which the Personal Data is stored.
- Use appropriate encryption system for any Personal Data which is stored in mobile devices, and those which are transmitted electronically.
- Implement security measures and systems for data protection, including policies for evaluation, monitoring, and review of operations and security risks. These may include clear written guidelines and training modules for our, agents, and representatives and audit measures in relation to the (a) collection, processing, maintenance, and deletion or disposal of Personal Data; and (b) the sharing of Personal Data. Such measures shall aim to maintain the availability, integrity, and confidentiality of personal data, and prevent negligent, unlawful, or fraudulent processing, access, and other interference, use, disclosure, alteration, loss, and destruction of Personal Data.
- Implement reasonable and appropriate organizational, physical, and technical measures intended for the protection of Personal Data against any accidental or unlawful destruction, alteration, and disclosure, as well as against any other unlawful processing, or for such other purposes as may be required under the Data Privacy Law and its Implementing Rules and Regulations.
- Implement appropriate measures to protect personal information against natural dangers such as accidental loss or destruction, and human dangers such as unlawful access, fraudulent misuse, unlawful destruction, alteration, and contamination.
- Ensure that our employees, agents, and representatives who are involved in the processing of Personal Data operate and hold the same under strict confidentiality.
- Promptly notify the other party within twenty-four (24) hours from the time of discovery of any data breach.
- At the choice of the Disclosing Party or the data subject, delete, destroy, or return all Personal Data and copies thereof to the former after the end of the provision of services relating to the purpose, except if the retention thereof is allowed under the law and where transaction records are required to be maintained for reconciliation and analytics purposes.
- Implement measures that will enable data subjects to exercise all of their rights including their right to access, modify, or correct Personal Data.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and our mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. Most web browsers and some mobile operating systems and our mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.
OPTIONS REGARDING YOUR INFORMATION
ACCOUNT INFORMATION
You may at any time review or change the information in your account or terminate your account by:
- Logging into your account settings and updating your account
- Contacting us using the contact information provided below.
You may at any time review or change the information in your account or terminate your account by:
EMAILS AND COMMUNICATIONS
EXPRESS CONSENT
By agreeing to this Privacy Policy, you are giving your full and voluntary consent to the following:
- Making your Personal Data available for Peer Connexions, its affiliates, related entities, and partners to permit them to make your personal data available to (a) third parties who provide products and services to Peer Connexions and related entities for the same purpose as described above, and (b) to other related third parties, where required or permitted by law or contract, including regulatory authorities, and government agencies.
- The processing of your Personal Data, as provided under applicable laws, regulations, and Peer Connexions’ policies and guidelines. The Personal Data must be used to comply with the legitimate purposes hereinabove mentioned and/or an ailment of other services provided for by Peer Connexions.
- The processing of your Personal Data for research and education, profiling, historical or scientific purpose, as well as to generate statistical data relevant to Peer Connexions’ operation to aid its management team, board of directors and shareholders to review and analyse data relating to its operations and financial performance. You also warrant that, before providing us with the Personal Data of your legal representative, you have obtained their consent to:
- you are collecting their Personal Data.
- you are sharing the same with Peer Connexions and related entities and the third parties that Peer Connexions and related entities are dealing with as provided above.
- the processing of their Personal Data by Peer Connexions and related entities and third parties as provided herein, and for the purpose stated herein.
You fully understand and agree that the Personal Data you provide will be retained by Peer Connexions and related entities as prescribed by the law, or if necessary for the purpose of maintaining your records and to comply with applicable laws, rules, and regulations.
You are fully aware that you and your legal representative are entitled to certain rights in relation to the Personal Data that may be collected from you and your legal representative, including the right to access, correction and to object to the processing of the same.
YOU UNDERSTAND THAT:
- The consent you are giving through this Privacy Policy is in addition to any other consent that you may give or have given Peer Connexions regarding the use of your personal data.
- You hereby agree to hold Peer Connexions and its respective authorized representatives, agents and its clients and service providers free and harmless from all liabilities, claims, damages, suits, costs, and expenses resulting from or in connection with the implementation of the purposes and authorities conferred by you above.
- The consent will remain in full force until you revoke it by writing to us at dataprivacy@peerconnexions.com
