Last updated: September 2023
Thank you for choosing to be part of our community at Data Sutram,owned and operated by Extrapolate Advisors PrivateLimited ("Company”), having its registered office address at 269/1, Jodhpur Park, 1st Floor, Kolkata Parganas South 700068, West Bengal, India and its corporate office at 212, The Summit Business Bay (Omkar), Near WEH Metro Station, Andheri East, Mumbai, Maharashtra 400093 (hereinafter referred to as "we," "us," or "our") operates and owns the Website. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at email@example.com. When you visit our website https://www.datasutram.com (“Website”) and use our services, you trust us with your Personal Data. We take your privacy very seriously.
- a) Section 43A of the Information Technology Act, 2000;
- b) Rule 4 of Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“SPDI Rules”); and
- c) Rule 3(1) of the Information Technology (Guidelines for Intermediaries and Digital Media Ethics Code) Rules, 2021.
“Applicable Law(s)” means all statutes, enactments, acts of legislature or parliament, ordinances, rules, bye-laws, regulations, notifications, policies, directions, directives and orders as such are in effect as of the date hereof or as may be amended, modified, enacted or revoked from time to time hereafter or other governmental restrictions or any similar form of decision of, or determination by any government, statutory authority, tribunal, board, court having jurisdiction over the matter in question in India
“Grievance Officer” means the grievance redressal officer appointed by the Company in accordance with Applicable Law, from time to time;
“Sensitive Personal Data or Information” shall have the same meaning as ascribed to it under Rule 3 of SPDI Rules.
2. What information do we collect?
Personal information you disclose to us
We collect Personal Data that you provide to us such as name, address, contact information, passwords and security data, and payment information. We collect Personal Data that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Website or otherwise contacting us. The Personal Data that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The Personal Data we collect can include the following: name and contact details. We collect your first and last name, email address, postal address, phone number, and other similar contact details. We collect passwords, password hints, and similar security information used for authentication and account access. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions. All Personal Data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such Personal Data.
Information automatically collected
Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Website. We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
Information collected from other sources
We may collect limited data from public databases, marketing partners, and other outside sources. We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).
3. How do we use your information?
We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent. We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To send you marketing and promotional communications for Business Purposes. We and/or our third-party marketing partners may use the Personal Data you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
- To send administrative information to you for Business Purposes. We may use your Personal Data to send you the product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfil and manage your orders for Contractual reasons. We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through the Sites.
- We post testimonials on our Sites that may contain Personal Data. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please contact us at firstname.lastname@example.org and be sure to include your name, testimonial location, and contact information.
- Deliver targeted advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- Request feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of our Website and Services.
- To protect our Website for Business Purposes and/or for Legal Reasons. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies for Business Purposes.
- To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and evaluating and improve our Sites, products, services, marketing and your experience.
You acknowledge that Your Consent is being obtained for the purpose set out under Clause 3 above
5. Will your information be shared with anyone?
We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
- Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- With your Consent. We may disclose your personal information for any other purpose with your consent.
Notwithstanding the above, We are not responsible for the confidentiality, security or distribution of Your Personal Data by third parties outside the scope of our agreement with such third party (ies). The Company will not be responsible for any breach ofsecurity or for any actions of any third parties or events that are beyond the Company’s reasonable control, including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service and / or telephone service of the User etc.
7. Do we use google maps?
8. How long do we keep your information?
9. How do we keep your information safe?
We aim to protect your Personal Data through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Data we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Personal Data, the transmission of Personal Data to and from our Sites is at your own risk. You should only access the services within a secure environment.
10. What are your privacy rights?
In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here
11. Withdrawal of Consent Procedures
You can opt out of receiving our marketing emails and from collection or use of any Personal Data by our Platform. To stop receiving our promotional emails or to withdraw consent for collection and usage of Personal Data, please email unsubscribe to email@example.com. It may take up to 15 (fifteen) days to process your request.
12. Children's Privacy
We do not knowingly collect or solicit personal information from children under the age of 18 years and the Website and its content are not directed at children under the age of 18 years. In the event that we learn that we have collected personal information from a child under age 18 years without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18 years. Please contact the Grievance Officer at the contact information set out in Clause 15 below.
13. Link to Third Party Websites
14. Do we make updates to this policy?
15. How can you contact us about this policy?
In accordance with the applicable laws (including Information Technology Act, 2000 and the rules made thereunder), the name and contact details of the Grievance Officer are provided below. You may contact the Grievance Officer to address any discrepancies and grievances you may have with respect to your information with us. The Grievance Officer will redress your grievances expeditiously, in keeping with Applicable Laws. If you have questions or comments about this policy, please contact our Grievance Officer. The details of the Grievance Officer are as follows:
Name: Aisik Paul
17. Governing Law And Dispute Resolution
18. LIMITATION OF LIABILITY
THE WEBSITE IS PROVIDED BY THE COMPANY ON AN "AS IS" AND "AS AVAILABLE" BASIS. ALL WARRANTIES WHETHER EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, INCLUDING WITHOUT LIMITATION ANY IMPLIED WARRANTIES AS TO NONINFRINGEMENT, CORRESPONDENCE WITH DESCRIPTION, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE ARE EXCLUDED TO THE FULLEST EXTENT PERMITTED BY LAW
NO LIABILITY ARISING OUT OF ANY VIOLATION OF DATA PRIVACY LAW IN ANY OTHER COUNTRY OTHER THEN REPUBLIC OF INDIA SHALL RESIDE WITH THE COMPANY. THE USERS OF SUCH COUNTRY (OTHER THAN REPUBLIC OF INDIA) NEED TO BE AWARE OF THE DATA PROTECTION LAWS OF THAT COUNTRY AND ACCORDINGLY ASSESS THE RISK SINCE THE COMPANY CLEARLY DISCLAIMS ALL RESPONSIBILITY RELATED TO PROTECTION OF SUCH DATA
WITHOUT LIMITING THE GENERALITY OF ABOVE CLAUSE, THE COMPANY MAKES NO WARRANTY THAT (I) THE WEBSITE WILL MEET USERS’ REQUIREMENTS OR THAT USERS USE OF THE APP, OR ACCESS TO THE PRODUCTS, WILL BE UNINTERRUPTED, TIMELY, SECURE OR ERROR-FREE (II) THE QUALITY OF THE WEBSITE WILL MEET USERS’ EXPECTATIONS.
THE COMPANY SHALL NOT BE LIABLE FOR:
- i) ANY LOSS THAT USERS MAY INCUR AS A CONSEQUENCE OF UNAUTHORIZED USE OF USERS ACCOUNT OR ACCOUNT INFORMATION;
- ii) ANY INTERRUPTION OR NON-AVAILABILITY OF THE WEBSITE DURING PERIODIC MAINTENANCE OR FOR ANY OTHER REASON INCLUDING BUT NOT LIMITED TO SYSTEMIC FAILURES AND ACTS OF GOD;
- iii) ANY INACCURACY, ERROR, OMISSION, INTERRUPTION, COMPLETENESS, DELETION, DEFECT, FAILURE OF PERFORMANCE, COMPUTER-VIRUS, COMMUNICATION LINE FAILURE, ALTERATION OF, OR ANY USE OF CONTENT HEREIN, REGARDLESS OF CAUSE, FOR ANY DAMAGES RESULTING THERE FROM; OR
- iv) ANY LOSS OF PROFITS, SALES, BUSINESS OR REVENUE; BUSINESS INTERRUPTION; LOSS OF ANTICIPATED SAVINGS; LOSS OF BUSINESS OPPORTUNITY, GOODWILL OR REPUTATION; OR ANY INDIRECT OR CONSEQUENTIAL LOSS OR DAMAGE HOWSOEVER ARISING.
- v) ACCURACY, CORRECTNESS OR ORIGINALITY OF ANY DATA INCLUDING ALL INDICES PUBLISHED ON THE WEBSITE WHETHER THE SAME IS THIRD PARTY DATA OR OTHERWISE.