PRIVACY POLICY.
- This Privacy Policy (“Privacy Policy”) applies to the Dekhore (“Dekhore”) digital Site(s)/ App(s) platforms including without limitation www.dekhore.com and other related Site(s)/ App(s), mobile applications and other online features (each a “Site(s)/ App(s)”). The Site(s)/ App(s) are offered by Max Play Digital Private Limited and its subsidiaries or affiliated companies. (collectively, “Max Play” or “Dekhore” or “we”, “us” and “our”).
- This Privacy Policy should be read in conjunction with the Terms of Use available on the Site(s)/ App(s). Personal Information/Data/Information (defined below) of a user(s) is collected if the user(s) registers with the Site(s)/ App(s), accesses the Site(s)/ App(s) or takes any action on the Site(s)/ App(s) or uses or accesses the Services as defined in the Terms of Use. The terms ‘Personal Information’ and ‘Sensitive Personal Information or Information’ shall have the meaning ascribed to it under the Indian Information Technology Act, 2000 read with the Information Technology.
- Please read this Privacy Policy carefully as your use of this Site(s)/ App(s) constitutes your consent to the processing of your Personal Information as described in the Privacy Policy. If you are younger than 18 years of age, and you wish to provide us with your Personal Information to participate in a promotion or contest, you must read this Privacy Policy with your parent or guardian.
SUMMARY OF KEY POINTS
· We use Personal Information to allow you to participate in the features on the Site(s)/ App(s), to process your registration, and to provide you with other requested content related to our content and other offerings.
· We provide interactive features that engage with third-party social media Site(s)/ App(s), such as Facebook and Twitter. Any data that we obtain about your use of such features is subject to this Privacy Policy. Any data that the social media Site(s)/ App(s) gather about you is subject to your terms with them.
· We use cookies and other technologies to track the use of our Site(s)/ App(s). We allow third parties to place such technologies on our Site(s)/ App(s) to allow them to display advertising and for other purposes.
· If you are under 18 years old, you must obtain the permission of your parent or guardian before participating in a contest or engaging in other activities. The only exceptions are if you simply sign up for a newsletter.
· We may disclose your Personal Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors, etc. insofar as necessary for the purposes set out in this Privacy Policy. We may also disclose Personal Information when you request or agree to such sharing with business partners or other third parties, when we engage a third-party to process data on our behalf, when such sharing is required by law, or in certain other situations.
·
This Site(s)/ App(s) may be
hosted on web servers in jurisdictions outside India. Your use of the Site(s)/
App(s) constitutes your consent to the transfer of Personal Information to any
other jurisdiction that may not provide the same level of data protection as
your home country.
1. INFORMATION COVERED BY THIS PRIVACY POLICY.
a. We may collect Personal Information/Information, including your name, email or street address, date of birth, telephone number, your preferences and interests, or other information you provide to us or grant us access to when you register for newsletters, communicate with us, or take an interactive games, features or competitions. The Site(s)/ App(s) may also ask you to provide other information about yourself, such as demographic, geographic information (gender, zip code, age, etc.) or certain information about your preferences and interests. If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as personal information. Please note that information submitted to the Site(s)/ App(s) via a “contact us” or other similar function may not receive a response. We will not use the information provided to contact you for marketing purposes unrelated to your request unless you agree otherwise.
b. Whenever you visit or interact with the Site(s)/ App(s) or Dekhore content, Max Play, any third-party advertisers, content providers and/or service providers, may use a variety of technologies that automatically or passively collect information etc. about how the Site(s)/ App(s) are accessed and used (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time, and the preceding page & video views etc. Usage Information is generally non-identifying, but if Dekhore associates it with you as a specific and identifiable person, Dekhore treats it as Personal Information. Dekhore also automatically collects your IP address or other unique identifier (“Device Identifier”) from the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Site(s)/ App(s). A Device Identifier is a number that is automatically assigned to your Device when you access a Site(s)/ App(s) or its servers, and our computers identify your Device by its Device Identifier. Some mobile service providers or our third-party service provider may also provide us with information regarding the physical location of the Device used to access the Site(s)/ App(s).
c.
The technologies used on the
Site(s)/ App(s) to collect Usage Information, including Device Identifiers,
have been detailed herein below.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
a. By using the Site(s)/ App(s), you consent to the use of cookies in accordance with the provisions of this clause. A cookie is a data file placed on a Device when it is used to visit the Site(s)/ App(s). A “Flash Cookie” is a data file placed on a Device via the Adobe Flash plug-in that may be built-into or downloaded by you to your Device. Cookies and Flash Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. If you choose to disable cookies or Flash Cookies on your Device, some features of the Site(s)/ App(s) may not function properly. The use of cookies on the Site(s)/ App(s) allows you to enjoy more seamless visits and more accurately measures your behavior on the Site(s)/ App(s). There are two types of cookies that we may use: session and persistent. Session cookies exist only during an online session. They disappear from your Device when you close the browser software. Persistent cookies remain on your Device after the browser has been closed. The cookies used on the Site(s)/ App(s) do not identify you personally. They merely recognize your browser, unless you choose to identify yourself voluntarily. You may choose to identify yourself for any one of the following reasons: by asking the browser to remember your username and password, by responding to a promotional offer, or by personalizing a web page or requesting more information on a product or service.
b. Web beacons (also known as clear gifs) are used in combination with cookies to help Site(s)/ App(s) operators understand how you interact with their Site(s)/ App(s). A web beacon is typically a transparent graphic image (usually 1-pixel x 1 pixel) that is placed on a Site(s)/ App(s) or in an email. The use of a clear gif allows the Site(s)/ App(s) to measure your actions in opening the page that contains the clear gif.
c. Embedded scripts are programming codes that are designed to collect information about your interactions with the Site(s)/ App(s), such as the links you click on. The code is temporarily downloaded onto your Device from our server or a third-party service provider, is active only while you are connected to the Site(s)/ App(s), and is deactivated or deleted thereafter.
d. Dekhore may use cookies and web beacons for a number of purposes, including to:
· Provide general internal and customer analytics.
· Study traffic patterns in order to improve Site(s)/ App(s) performance, to customize the user experience, and to better match the users’ interests and preferences. For example, Dekhore keeps track of the domains from which people visit, and also measures/tracks visitor activity on Dekhore Site(s)/ App(s). However, these tracking records are performed and maintained in ways that keep the data non-identifiable.
· Keep track of preferences you specify while you are using Dekhore products or services.
· Support security measures, such as requiring re-login into an Dekhore product or service, after a certain amount of time has elapsed.
· If you login to our products through the Site(s)/ App(s), cookies can also be used to save the username so that we can process the saved login information and quickly log you into the product.
· Assist in identifying possible fraudulent activities.
e.
Tell if an email has been
opened and acted upon. Controlling our use of Cookies: The Adobe Flash Player
(“Flash”) is an application and web tool that allows rapid development of
dynamic content. Flash (and similar applications) use technology to remember
settings, preferences and usage similar to browser cookies, which may be used
by Max Play. Dekhore employs Adobe Flash cookies in certain situations where we
use Flash to provide some content such as video clips or animation. Dekhore does
not use Flash Cookies to serve interest-based advertising. Flash Cookies are
managed through the Flash Player Settings Manager, which is a different
interface than the one provided by your web browser. This Settings Manager lets
you manage global Privacy Settings, Storage Settings, Security Settings, and
Automatic Notification Settings. This Site(s)/ App(s) may also use Google
Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics
uses cookies, text files that are stored on your Device and allows an analysis
of your use of the Site(s)/ App(s). If Google Analytics is used, the
information generated by the cookie about your use of the Site(s)/ App(s)
(including the IP address) will be transferred to and stored on a server of
Google in the US. Google will use such information to analyze your use of the
Site(s)/ App(s), to create reports about the Site(s)/ App(s) activities for Dekhore
and to provide further services associated with the use of the Site(s)/ App(s)
and the internet. Furthermore, Google may transfer such information to third
parties, to the extent legally required or if such third parties process the
data on behalf of Google. In no event will Google associate your IP address
with other information of Google. By using this Site(s)/ App(s), you consent to
the processing of your information collected by Google as described above and
for the purposes described above. Google Analytics can be disabled through this
link: http://tools.google.com/dlpage/gaoptout. Dekhore at its sole discretion
may employ any other third-party(ies) analytics services, as may be required.
3.
LOG
FILE INFORMATION
Our servers automatically
collect limited information about your Devices' connection to the internet,
including your IP address, Device and/or MAC ID, etc., when you visit our
Site(s)/ App(s). Your IP address is a number that lets computers attached to the
internet know where to send your data -- such as the web pages you view. Your
IP address, Device and/or MAC ID, etc., does not identify you personally but
may be combined with your Personal Information which then may identify you
personally.
4.
MINOR'S
PERSONAL INFORMATION
Certain Site(s)/ App(s) may
attract individuals younger than 18 years old of age (“Minor” or “Minors”). On
those Site(s)/ App(s), Dekhore may collect the e-mail address and age of Minors
in order to send them newsletters and engage them in other limited activities.
If you are a Minor, and you wish to provide us with your Personal Information
for any other purposes, such as to participate in a promotion or contest, you
must read this Privacy Policy with your parent or guardian and must not provide
your Personal Information without obtaining your parent's or guardian's prior
consent and under their supervision. If we are notified or otherwise learn that
a Minor has submitted Personal Information to us through any of our Site(s)/
App(s) other than under the conditions set forth above, we will delete that
Minor's Personal Information. Children younger than 18 years of age may only
surf the Site(s)/ App(s) and play with the features, but Dekhore does not knowingly
collect data of users younger than 18 years of age.
5.
HOW WE
USE YOUR INFORMATION
We will use Personal
Information collected through the Site(s)/ App(s) to: (1) allow you to
participate in the features we offer on the Site(s)/ App(s); (2) provide you
with information that you request or agree to receive; (3) improve the Site(s)/
App(s) and for internal business purposes; (4) contact you with regards to your
use of the Site(s)/ App(s), and any changes to our policies; (5) tailor
content, advertisements and offers we serve you; and (6) fulfil other purposes
disclosed at the time you provide your Personal Information or otherwise with
your consent.
6. HOW WE SHARE YOUR PERSONAL INFORMATION
a. WHEN YOU AGREE TO HAVE YOUR PERSONAL INFORMATION SHARED
While on our Site(s)/ App(s), you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your Personal Information with a third-party. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third-party and the Personal Information you disclose will be subject to the Privacy Policy and business practices of that third-party. You may also specifically request Max Play, sometimes, through your use of an interactive feature, a widget or an application, that we share your Personal Information with a third-party and we will typically do so under those circumstances. In addition, if you choose to register for a promotion, such as a competition, prize draw or contest, your Personal Information may be disclosed to third parties for the purposes of administration of such promotions.
b.
FOR
SWEEPSTAKES, CONTESTS AND PROMOTIONS.
The Site(s)/ App(s) may offer
sweepstakes, contests, and other promotions (each, a “Promotion”) that may
require registration. If you choose to enter a Promotion, your Personal
Information may be disclosed to third parties in connection with the administration
of such Promotion, such as in connection with winner selection, prize
fulfilment, and as required by law, such as on a winners list. By entering a
Promotion, you are agreeing to the official rules that govern that Promotion,
which may contain specific requirements from you, including, except where
prohibited by law, allowing the sponsor and/or other parties to use your name,
voice and/or likeness in advertising or marketing materials.
c.
ON
SITE(S)/APP(S)THIRD PARTIES PROVIDING SERVICES ON OUR BEHALF
We may engage any third
parties to perform functions on our behalf, such as hosting or operating our
Site(s)/ App(s), sending e-mail communications, and data analysis. We may share
Personal Information with third parties in order for them to provide content or
otherwise perform services for us, and we will require such parties to maintain
appropriate security to protect such data from unauthorized access or
processing. It being clarified that in no event shall Max Play, or any of its
directors, employees, or any representatives, be held liable for use of such
Personal Information by itself and the aforementioned third parties.
d.
FOR
AFFILIATE SHARING AND BUSINESS TRANSFERS
We may share your Personal
Information with other entities (group entities and/ or affiliates) for
internal reasons, primarily for business and operational purposes. Dekhore or
any of its assets, including the Site(s)/ App(s), may be sold, or other
transactions may occur in which your Personal Information is one of the
business assets of the transaction. In such case, your Personal Information may
be transferred. Hence, Dekhore reserves the right to disclose and transfer user
information, including Personal Information in connection with a corporate
merger, consolidation, restructuring, the sale of certain of Max Play's assets,
or other corporate change including, without limitation, during the course of
any due diligence process
e.
POTENTIAL
INVESTORS
Certain investors may be
interested in investing funds in Max Play. For the purposes of securing such
investment, Dekhore may be required to disclose data pertaining to your
Personal Information or to your Usage Information. We will require such parties
to maintain appropriate security to protect such data from unauthorized access
or processing. It being clarified that in no event shall Dekhore be held liable
for use of such Personal Information/ Information by itself and the
aforementioned third parties.
7.
LEGAL
PROTECTIONS AND OTHER DISCLOSURES
We may transfer and disclose
information, including your Personal Information, Usage Information and Device
Identifier (including IP address, Device and/or MAC ID, etc), to third parties:
to comply with a legal obligation; when we believe in good faith that the law
requires it; at the request of governmental authorities conducting an
investigation; to verify or enforce the Site(s)/ App(s)'s Terms of Use or other
applicable policies; to respond to an emergency; or otherwise to protect the
rights, property, safety, or security of third parties, visitors to this
Site(s)/ App(s) or the public. Pursuant to valid requests by law enforcement
agencies, we may also use Device Identifiers to identify users, and may do so
in cooperation with copyright owners, internet service providers, wireless
service providers or law enforcement agencies, at our discretion. Such
disclosures may be carried out without notice to you.
8.
LINKS
TO OTHER SITE(S)/ APP(S) AND SERVICES, AND DEKHORECONTENT FOUND ON OTHER
SITE(S)/ APP(S)
The Site(s)/ App(s) may
provide links to other Site(s)/ App(s) applications. This includes links from
advertisers, sponsors and partners that may use our logo(s) as part of a
co-branding agreement. Certain content on the Site(s)/ App(s) may be hosted and
served by third parties, which may include third-party widgets (such as those
that allow you to “like” or “share” content with third-party Site(s)/ App(s)
and interactive services, or third-party “get tickets and show times” widgets).
The use of these third-party Site(s)/ App(s) applications and any information
collected, stored and transferred by them is not subject to this Privacy Policy
and is usually governed by their own terms of use and Privacy Policy. By
clicking through to these third-party Site(s)/ App(s) applications, you will be
governed by such third-party's Privacy Policy / Terms of Use. We have no
control over these third parties. These third parties may send their own
cookies to your Device; they may independently collect data or solicit Personal
Information and may or may not have their own published privacy policies. Dekhoreis
not responsible for the privacy practices or business practices of any
third-party Site(s)/ App(s).
Dekhore may also display its content/ widgets on third-party Site(s)/ App(s)
/Application(s). Please note that in such an eventuality, your use of the
third-party Site(s)/ App(s)/ Application(s) shall continue to be governed by
the third-party's Privacy Policy / Terms of Use. We have no control over these
third parties. These third parties may send their own cookies to your Device;
they may independently collect data or solicit Personal Information and may or
may not have their own published Privacy Policies. Dekhoreis not responsible
for the privacy practices or business practices of any third-party Site(s)/
App(s).
9.
PERSONAL
INFORMATION YOU DISCLOSE PUBLICLY ON OUR SITE(S)/ APP(S)
Our Site(s)/ App(s) may offer
message boards, chat rooms, alternative reality games, multi-player games and
other public areas (collectively, “Community Forums”) where you can engage in
social networking, interact with others, as well as have the opportunity to
submit photographs, writings, music, video, audio recordings, computer
graphics, pictures, data, questions, comments, suggestions or other content,
including Personal Information (collectively, “User Submissions”). To
participate in certain Community Forums, you may be asked to select a username,
screen name or member name and password. Furthermore, any such User Submissions
that you publish on our Site(s)/ App(s) or submit for publication on our
Site(s)/ App(s) may be available, via the internet, around the world, and we
cannot prevent the use or misuse of such information by others.
10.
NOTE
THAT ANYTHING YOU POST TO A COMMUNITY FORUM IS PUBLIC
User Submission(s) may be used
or shared with any third parties. Information you choose to post or make
available in the Community Forums may be viewed, collected and used by others
and we shall have no control over the manner and mode of such use. If you
choose to voluntarily disclose User Submissions, the protections of this
Privacy Policy will not cover such disclosure of information. Think carefully
before you post and use caution before disclosing any Personal Information.
Also, functionality on the Site(s)/ App(s) may permit interactions between the
Site(s)/ App(s) and a third-party Site(s)/ App(s) or service, such as enabling
you to “like” a product on our Site(s)/ App(s) or “share” content to other
Site(s)/ App(s) or services. If you choose to “like” or “share” content on the
Site(s)/ App(s) or to otherwise post information from or via the Site(s)/
App(s) to a third-party's Site(s)/ App(s), service, feature or application,
etc. that information will become public and the third-party may have access to
information about you and your use of our Site(s)/ App(s).
User Submissions may be published online or offline in any media or format
(currently existing or hereafter developed). We may also publish your name,
voice, likeness and other Personal Information with your User Submissions, and Dekhore
may use the content, or any portion of the content, for advertising, marketing,
publicity, promotional or any other activities. For full terms and conditions
regarding User Submissions you submit to the Site(s)/ App(s), please refer to
our Terms of Use.
11.
INFORMATION
WE RECEIVE FROM THIRD PARTIES
Dekhore may receive
information about you from third parties. For example, if you are on another
Site(s)/ App(s) and you opt-in to receive information from Dekhore that
Site(s)/ App(s) will forward to us your email address and other information
about you so that we may contact you as requested. You may also choose to
participate in a third-party application or feature on our Site(s)/ App(s)
(such as logging in through Facebook Connect or otherwise linking the Site(s)/
App(s) with another Site(s)/ App(s) or interactive service) or on a third-party
Site(s)/ App(s) or service (such as one of our Facebook applications or a
similar application or feature on a third-party Site(s)/ App(s) or service)
through which you allow us to collect (or the third-party to share) information
about you, including Personal Information. When you choose to participate, you
may be opting to link your activity on our Site(s)/ App(s) with that
third-party Site(s)/ App(s) or service, which may then collect information
about your visits to our Site(s)/ App(s) and may publish that activity as you
request to your “profile” or similar feature with that third-party (such as if
you choose to share content you find on one of our Site(s)/ App(s) with your
“connections” on the third-party's Site(s)/ App(s) or service). The information
we collect is subject to this Privacy Policy. However, the information
collected and stored by the third-party remains subject to the third-party's
privacy practices, including whether the third-party continues to share
information with us or with other third parties, the types of information shared,
and your choices with regard to what is visible to others on that third-party's
Site(s)/ App(s) or service. The third-party may allow you to remove the
application or feature, in which case we will no longer collect information
about you through the application or feature, but we may retain the information
previously collected. In addition, we may receive information about you if
other users of a third-party Site(s)/ App(s) or service give us access to their
profiles and you are one of their “connections” or information about you is
otherwise accessible through your “connections” web page, profile page, or
similar page on a social networking or other third-party Site(s)/ App(s) or
interactive service.
We may also supplement the information we collect about you through the
Site(s)/ App(s) with outside records from third parties in order to enhance our
ability to serve you, to tailor our content to you and to offer you
opportunities to purchase products or services that we believe may be of
interest to you. We may combine the information we receive from these third
parties with information we collect through the Site(s)/ App(s). In those
cases, we will apply this Privacy Policy to any Personal Information received,
unless we have disclosed otherwise.
12.
WE MAY
USE AD SERVING AND TRAFFIC MEASUREMENT SERVICES; HOW TO “OPT OUT” OF RECEIVING
ADVERTISING RELEVANT TO YOU
Dekhore licenses technology to
serve advertisements on its own Site(s)/ App(s) and within its videos and other
content as that content is served across the internet. In addition, Dekhore may
use third-party network advertisers to serve advertisements and third-party
analytics service providers to evaluate and provide us with information about
the use of the Site(s)/ App(s) and viewing of our content. We do not share
Personal Information with these third parties, but ad network providers, the
advertisers, the sponsors, and/or analytics service providers may set and
access their own cookies, web beacons and embedded scripts on your Device and
they may otherwise collect or have access to information about you, including
Usage Information. With regard to advertisements, we and our network
advertisers may target advertisements for products and services in which you
might be interested based on your visits to both the Site(s)/ App(s) and other
Site(s)/ App(s). Cookies and web beacons, including those set by third-party
network advertisers, may be used to, among other things, target advertisements,
prevent you from seeing the same advertisements too many times, or to conduct
research regarding the usefulness of certain advertisements to you. We may
share Usage Information about visitors to the Site(s)/ App(s) with third-party
advertising companies for the same purposes. We may use a variety of companies
to serve advertisements.
13.
SECURITY
We incorporate commercially
reasonable safeguards to help protect and secure your Personal Information.
However, no electronic data transmissions or storage of information can be
guaranteed to be 100% secure. You acknowledge that we cannot ensure or warrant
the security of any information you transmit to us, and you use the Site(s)/
App(s) and provide us with your information at your own risk.
14.
PERSONAL
INFORMATION SITE(S)/ APP(S) AMENDING OR REMOVING YOUR PERSONAL INFORMATION,
CONTROLLING MARKETING COMMUNICATIONS, AND PRIVACY QUESTIONS
You have the right to access
your Personal Information held by us and, if necessary, have it amended or
deleted. You can also request not to receive email, SMS, and MMS marketing
communications from us. You may opt out of receiving email newsletters and other
marketing communications by following the opt-out instructions provided to you
in those emails. If you sign up to receive SMS or MMS messages, you may
unsubscribe from any SMS or MMS messages received by replying “STOP.” Please
note that we may still need to send you certain communications relating to your
account or use of the Site(s)/ App(s) and these transactional account messages
may be unaffected if you choose to opt-out from marketing communications.
For more details or any privacy questions please contact us by email at support@dekhore.com (name and contact no of the Grievance office not mentioned. Or write to us at:
Legal Department
Max Play Digital Pvt. Ltd.
A-402, Star Garden, Variyaav, Surat-395004 | Gujarat | India
We request you to please provide the following information in your complaint: -
· Identification of the information provided by you
· Clear statement as to whether the information is Personal Information or sensitive Personal Information
· Your address, telephone number or email address.
· A statement that you have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be.
· A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to you.
You may also contact us in case you have any questions / suggestions about the Privacy Policy using the contact information mentioned above.
15.
NOTIFICATION
OF CHANGES AND YOUR ACCEPTANCE OF THE PRIVACY POLICY
We reserve the right to change the terms of this
Privacy Policy at any time, without notice, by prominently posting notice of
the amendment on this Site(s)/ App(s). To the extent permitted by applicable
law, such changes will be applicable from the time they are posted. Dekhore
will use your Personal Information in a manner consistent with the Privacy Policy
in effect at the time you submitted the information.
16.
COMPLIANCE WITH
LAWS AND LAW ENFORCEMENT
We cooperate with mandated
government and law enforcement agencies or to any third parties by an order
under law for the time being in force to enforce and comply with the law. We
will also disclose any information including Personal Information or Information
about you to government and law enforcement agencies or private parties without
your permission as we, in our sole discretion, believe necessary or appropriate
to respond to valid claims and legal process, to protect the property and
rights of Site(s)/ App(s) or a third-party, to protect the safety of the public
or any person, or to prevent or stop any illegal, unethical or legally
actionable activity. Site(s)/ App(s) may also provide your Personal Information
including Sensitive Personal Information or Information to various authorities
upon any demand or request from them.
17.
EMAILS
We may use your Personal
Information or Information for the aforementioned purposes of the
services/Site(s)/ App(s). You have full control regarding which emails you want
to receive. If you decide at any time that you no longer wish to receive such
communications from us, please follow the instructions to unsubscribe, as
provided in any of the communications. Please note that once we receive your
request, it may take an additional period of time for your opt-out to become
effective.
18.
PHISHING
Identity theft and the
practice currently known as “phishing” are of great concern to us. Safeguarding
information to help protect you from identity theft is a top priority. We do
not and will not, at any time, request your credit card information or national
identification numbers in a non-secure or unsolicited email or telephone
communication.
19.
GRIEVANCE
OFFICER
The grievance officer for the
purpose of this Privacy Policy is already designated. If you have any questions
or grievance or want to delete or modify your Personal Information, you shall
mark your correspondence (given under the heading “Contact Us”) in the name of support@dekhore.com
Any communication which is not marked as such shall
not be treated as a valid and binding communication for the purpose of this
Privacy Policy and applicable laws with respect to this Privacy Policy.
20.
APPLICABLE
LAWS AND JURISDICTION
The present policy shall be
governed by the applicable laws of India and the courts of Mumbai only, shall
have the jurisdiction to deal with matters relating to this Privacy Policy.
21.
MISCELLANEOUS
The Terms of Use (as provided
on the Site(s)/ App(s)), and any other documents, instructions, etc. included
on the Site(s)/ App(s) shall be read in conjunction with and shall be an
integral part of these Privacy Policy.
IN ADDITION TO THE ABOVEMENTIONED TERMS/PROVISIONS OF THE PRIVACY POLICY ,
BELOWMENTIONED GDPR COMPLIANCE PROVISIONS SHALL BE CONSTRUED AS I OF THE
PRIVACY POLICY AND SHALL BE APPLICABLE ON THE SUBSCRIBER(S)/USER(S) RESIDING IN
EUROPEAN UNION:
GDPR COMPLIANCE PROVISIONS (PRIVACY POLICY)
Dekhore has endeavored to align its Privacy Policy in line with the newly enacted General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), made effective from May 25, 2018. Below are the key provisions of the GDPR for Your information and understanding.
1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
As mentioned in Clause 1 of
the Privacy Policy, We would collect Information (as defined in the Privacy Policy)
from You when You set up your account with the Site(s)/App(s). The Information
would include but not be limited to your full name, email address, mobile
number, location and date of birth. Upon You accessing/using the Site(s)/App(s)
as a registered user, we would also collect certain additional information
related to You such as demographic, geographic information (such as gender, zip
code, age, etc.), information about your preferences and interests to build a
better user friendly experience and/or product to continually endeavor to
provide better features, access and audio visual content to our end users.
2. PURPOSE OF COLLECTING YOUR INFORMATION
a.
One of the prime purposes of
uploading the Privacy Policy I on our Site(s)/App(s) is to inform You of who we
are and what business do we carry on for which we collect the Information. We
collect and use Your Information to better provide You with the required
services. We would therefore use Your Information in order to:(i) respond
diligently to queries or requests submitted by You;(ii) process financial
transactions or applications submitted by You;(iii) administer or otherwise
carry out our obligations in relation to any agreement you have with us;(iv)
resolve problems/complaints with any goods or services supplied to You;(v)
create products or services that may meet your needs and requirements.
Please refer to Annexure 1 to this Privacy Policy to understand how Your
Information would be processed and the purpose for processing Your Information.
b. We process Information to pursue our legitimate interest to run, maintain and develop our services in order to meet needs/requirements of our end users/viewers/subscribers. At times while consuming the services, You may be requested to grant Your consent for the processing/usage of Your Information. In this event, You may withdraw Your consent at any time post which we shall refrain from using Your Information in any manner whatsoever.
c.
To optimize our
Services, We may wish to use Your Information for marketing our services
whereby we send you emails, messages relating to our services and/or our
Site(s)/App(s). As We respect your privacy, We will only use Your Information
for the purpose of marketing our services when you are aware about the same and
if required We will request your consent prior to using Your Information for
such marketing purposes.
Additionally, if at any time You wish us to stop
using Your Information for any or all of the above purposes, you can reach out
to the Data Protection Officer at support@dekhore.com.
We will stop the use of Your Information for such purposes as soon as it is
reasonably possible to do so.
d. Except as set out in this Privacy Policy, We will not disclose any personally identifiable information (if any available with us in the Information) without Your permission to third party(ies) unless we are legally entitled or required to do so (for example, if required to do so by legal process or statutory requirements or regulatory policies or court orders or for the purposes of prevention of fraud or other crime) or if we believe that such disclosure is necessary to protect and/or defend our rights, property or personal safety and those of our users/viewers/subscribers or other individuals.
e. Please be assured that we will not use Your Information for any of the purposes if You have indicated that you do not wish us to use Your Information in any certain manner/way when submitting the Information or at any later stage.
3. HOW DO WE USE YOUR INFORMATION?
Dekhore and/or its
partners/third party firms and/or third party service providers may use Your
Information (i) to study how You use the Site(s)/ App(s) so we can make
improvements and provide you with better customer experiences (ii) to record
information about the pages You visit in the of the Site(s)/App(s), the
duration of time You spend on the pages of the Site(s)/ App(s), how You arrived
at the Site(s)/ App(s) and the content you clicked on when You visit the
Sites(s)/App(s), (iii) to provide targeted content recommendations to You based
on Your interests; (iii) for the purpose of A/B testing, (iv) marketing
communications (iv) to comply with legal obligations as per jurisdiction and
(v) to conduct various internal audits and analytics to understand customer
behavior and their interaction with features of the platform. We also use your
account information to deliver content based on subscription pack, country,
location and age.
4. WHO DO WE SHARE YOUR INFORMATION WITH?
We use third party service
providers for rendering support services, such as Email/ SMS service providers
for marketing, for conducting analytics purposes and for software development
purposes. We use these third-party services solely to obtain, process or store
Your Information for the purposes described in this policy. We may further
share your Information to track your usage of the services provided by us on
Site(s)/App(s), however the same is not shared with any third party(ies) who
are unauthorized to receive such Information.
5. WHERE DO WE PROCESS/STORE YOUR INFORMATION?
Our servers are located in
Singapore, United States of America, EEA (as defined in clause 6 this Privacy
Policy I) and India. We also have support, engineering and other teams that
manage the Site(s)/App(s), located in India and Denmark. Your Information may
be accessed from such locations. The Information is accessible only by
designated team members and rigorous internal control measures are undertaken
to strictly limit access to Your Information only by designated team members.
6. TRANSFER OF INFORMATION TO COUNTRIES OUTSIDE
EUROPEAN ECONOMIC AREA
The collected Information may
be transferred to selected third parties that own/operate our servers and/or
third party support, engineering teams that manage the Site(s)/App(s), which
may be located outside of the European Economic Area (“EEA”) as part of the
services offered to You through our site. By way of example, this may happen if
any of our servers are from time to time located in a country outside of the
EEA or one of our service providers is located in a country outside of the EEA.
These third parties will not use Your Information for any other purposes than
what we have agreed with them, unless the same is required by law or any court
order or any statutory requirement or regulatory policy. We respect Your need
to protect the Information and therefore, we will on best effort basis take all
requisite steps/precautions to ensure that your Information continue to be
protected if we transfer your information outside of the EEA. In addition, if
you use our services while you are outside the EEA, your information may be
transferred outside the EEA in order to provide you with those services.
7. HOW LONG DO WE RETAIN YOUR INFORMATION?
a. You Information is retained for up to 10 (ten) years from the date when the Information is collected/received by us.
b. You may instruct us to delete your Information collected by us by writing an email to us at support@dekhore.com. If you instruct us to delete your Information, your Information shall be deleted within 30 (thirty) working days from the date of receiving Your Information deletion request email.
c. However, Dekhore will continue to retain your financial/ transactional data (detailed in clause 7(d) and 7(e) of Privacy Policy I ) for a period of 8(eight) financial years to comply with tax authorities of India. For sake of clarity, a financial year in India starts from April 1 and continues till March 31 of succeeding year.
d. For Registered users of Site(s)/App (s), we will retain your Account ID and Email ID
e. For subscribed user below is the list of Information that shall be retained by us.
i. i. Account ID/Customer ID which is created when You registers on the Site(s)/App(s)
ii. Order ID which is generated when You initiate a financial transaction on the Site(s)/App(s)
iii. Location – which means the location from where the financial transaction was made
iv. Package selected – the subscription package price selected by user.
v. Duration of subscription package (which may be quarterly, half-yearly or yearly)
vi. Payment gateway through which transaction has been done
vii. You Email ID
viii. Date of the financial transaction
ix. Type of transaction (Success/ Failure)
x. Invoice issued to you by Dekhore or the payment gateway on behalf of Max Play
8. WHAT RIGHTS DO YOU HAVE OVER YOUR INFORMATION?
As a resident of EEA and a
user of Max Play, you have access to the following rights in compliance with
GDPR:
a. Right to be Informed: You have the right to be informed about anything that happens with your Information, what it is used for, you have the right to access it and to modify it and even to remove your consent to share Your Information with us. At the same time, you have the right to access your Information at your disposal.
b. Right to Restrict Processing: Under the GDPR, you have the right to restrict processing of Information in various circumstances. For example, you can restrict processing when You feel Your Information is not accurate. In this case You will be able to restrict the processing until the accuracy of Your Information has been verified. Another case when processing can be restricted is when You object to the processing of Your Information.
c. Right to Erasure: You have the right to request the deletion or removal of Your Information from our end. This right is not absolute, which means that there are circumstances when Your Information will not be erased at Your request. For sake of clarity, if Your Information is used to comply with a legal obligation, for scientific research or for the exercise or defense of legal claims, then the right to removal can be denied to You.
d. Data Portability: You also have the right to data portability. Unless other contractual issues pre-exist (of which you should be informed of before you allow your data to be processed) then you can move any data from the Information from one service provider to another in an easy and secure manner.
e. Rights related to Automated Decision Making And Profiling: The GDPR defines profiling as any form of automated processing intended to evaluate Your personal aspects, such as Your performance at work, Your health, personal preferences, economic situation, location and more.
f. Right to Rectification: You have the right to request rectification of inaccurate Information concerning You. You also have the right to have incomplete Information completed, including by means of providing a supplementary statement.
g. Right to Object: You shall have the right to object, on grounds relating to your particular situation, at any time, to process the Information concerning You. We shall no longer process Your Information in the event of receipt of the objection, unless We can demonstrate having compelling legitimate grounds for processing of the Information which may at times override Your interests and rights of the Information.
If You wish to exercise either or all rights mentioned above, write to us at support@dekhore.com
CONTACT INFORMATION
If you have any concerns or complaints regarding the use of the Site(s)/Apps(s), please contact us at Support@Dekhore.com
Alternatively, you can reach out to the Data Protection Officer at legal@Dekhore.com
ANNEXURE 1
The following is a comprehensive list of what /Information we collect, how we use it:
|
Information |
Purpose of
processing |
|
Registration
Data and Log-in Data. Your name, email,
mobile phone number, password, date of birth, gender, and IP address. |
· To set up and log-in to a user account on Dekhore; · To notify you about changes to Dekhore; · To facilitate communication; · To provide you with user support; · To enforce our terms, conditions, and policies. · To communicate with you. · To provide personalized help and instructions. · To better understand how you access and use Dekhore; · To develop new and improve existing features. · To provide language and location customization. To protect any rights, property or safety of ours, our affiliate companies, or other users of Dekhore; and To administer Dekhore and
for internal operations, including troubleshooting, data analysis, testing,
research, security, fraud-detection, account management, and survey purposes. |
|
User
Profile Search Data. Record of search
inquiries. |
To provide
quick access to previous searches. |
|
Additional
Account Security. Kids mode PIN (an
optional security features for you), Managed Devices, Email address, Facebook
Connect Token. |
To verify
your identity account security. |
|
Log File
Information See definition above. |
To better
understand how you access and use Dekhore; |
|
Android
Device Permissions. Your on-device contact
list, SMS, Location, Telephone |
To process
payment for subscription via various payment gateways, wallets, mobile
carrier billing, etc; |
|
Transaction/
Financial information |
As per
Indian law and jurisdiction, Dekhoreis required to store information
regarding any payment transaction attempted on the platform. |
|
Customer
Support Information. Any information that
you provide to our customer support team. |
To
investigate your support issue. |
|
Device
Data. Media stored on your device. |
To
facilitate the usage of the download feature of Dekhore. |
|
Surveys. If
you choose to participate in a survey, we may request certain Personal
Information from you. We may use a third- party service provider to conduct
these surveys and this will be notified to you prior to you completing the
survey. |
· To better understand how you access and use Dekhore; · To provide personalized help and instructions. · To develop new and improve existing services. To improve Dekhore and respond to customer requests and preferences. |
|
Contest
Information. Any information that you provide to us in
submitting an entry to a contest offered on Max Play. |
· To facilitate your participation in the contest; To award
prizes, if applicable. |
|
Anonymized
and Aggregated Data. We anonymize and
aggregate certain Information to improve our services |
|
|
Cookies.
We further explain such collection in “Cookies
and other Tracking Technologies” section. |
To
facilitate log-in and account verification. |
|
Payments
Information. Please note that where a payment is
processed by a third- party payment service provider, we do not collect or
store any Personal Information, though we may receive summary information
about transactions. |
· To facilitate your purchases within Dekhore; and · For financial reconciliation · To investigate fraud · To comply with Indian tax laws To provide
support and troubleshooting |