Effective as of Oct 27th 2021
The mobile application ‘Aasaan’ and its related website, sub-domains, sites, services and (hereinafter collectively referred to as the “Platform”)., owned and operated by Lightbooks Technologies Private Limited, a private limited company, having its registered office at 1-65/2/A/46, Plot No 46, Cyber Hills, Kakateeya Hills Rd 9, Kakatiya Hills, Guttala_Begumpet, Hyderabad, Telangana 500081, India, Telangana State, India (“Aasaan”, “us” or “we”).
OUR COMMITMENT TO PRIVACY
This Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder. This Policy does not require any physical, electronic or digital signature.
BY USING OUR SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION AND/OR INFORMATION ABOUT AN END CUSTOMER, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD, AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS POLICY AND AGREE TO BE BOUND BY THE POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE, SHARING, AND DISCLOSURE OF YOUR INFORMATION AND INFORMATION OF AN END CUSTOMER AS DESCRIBED IN THIS POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS POLICY, AT OUR SOLE DISCRETION, AT ANY TIME SUBJECT TO THE TERMS CONTAINED HEREIN. IF YOU DO NOT AGREE WITH THIS POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF; AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS POLICY. YOU FURTHER REPRESENT THAT YOU, AS A USER, HAVE PROCURED THE END CUSTOMER’S CONSENT (WHERE NECESSARY) TO AASAAN’S USE, DISCLOSURE AND PROCESSING OF THEIR INFORMATION ACCORDING TO THIS POLICY AND UNDERSTAND THAT AASAAN SHALL NOT BE HELD RESPONSIBLE, LIABLE OR ACCOUNTABLE IN ANY MANNER OR TO ANY EXTENT WHATSOEVER, FOR YOUR FAILURE TO PROCURE SUCH CONSENT. THIS POLICY APPLIES TO ALL THE CURRENT AND FORMER VISITORS, USERS AND OTHERS WHO ACCESS THIS PLATFORM.
- LEGAL REQUIREMENT AND SCOPE
- This Policy is published in compliance with, among other things:
- Section 43A of the Information Technology Act, 2000;
- Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011;
- Regulation 3(1) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021.
- Aasaan will collect and process your personal and third-party data carefully, only for the purposes described in this Policy and only to the extent necessary as defined herein and within the scope of the applicable legal regulations. This Policy seeks to ensure that any personal information or third-party information handled by Aasaan is managed in a way that is ethical, compliant and adheres to best industry practices.
- This Policy describes the types of information Aasaan collects, why and how Aasaan uses the information, with whom Aasaan shares it, and the choices you can make about Aasaan’s use of the information. This Policy also describes the measures Aasaan takes to protect the security of the information and how you can contact Aasaan about its privacy practices.
- This Policy describes Aasaan’s current data protection policies and practices and may be amended/updated from time to time in accordance with the terms herein.
- TYPES OF INFORMATION
- Personal Information is defined as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
- Personal Information: Personal Information means any information that may be used to identify an individual, including, but not limited to, the first and last names, physical temporary and personal address, telephone number, date of birth, age, gender, e-mail address, or any other contact information, financial information including bank account details, credit/debit card details or such other payment information. Further, Sensitive Personal Data or Information (“SPDI”) of a person includes Personal Information about that person relating to: passwords, financial information (bank accounts, credit and debit cards or other payment instruments), physical information. Aasaan limits the collection of Personal Information of the User and/or the End Customer to that which is necessary for its intended purpose.
- Business Information: Business Information means any information that may be used to identify an individual’s business, including but not limited to the name and address of the entity, date of incorporation, e-mail address of the entity, contact information of the registered office, company identification number (CIN), financial information including bank account details, PAN details, names of the directors and such other information (hereinafter referred to as “Business Information”).
- Non-Personal Information: Non-personal information means information that does not specifically identify an individual or business, but includes information from you, such as your browser type, the URL of the previous websites you visited, your Internet Service Provider (ISP), operating system and your Internet Protocol (IP) address. Aasaan may gather any non-personal information regarding how many people visit the Platform, the User Domain, the pages they visit, their IP address, and the type of browser they use while visiting the Platform and/or User Domain and locations, operating systems, applications installed on your device, device ID, device manufacturer and type, device, connection information, screen resolution, usage statistics, default communication applications and other technology on the devices you use to access the Platform and/or User Domain, maximum products purchased by the End Customer. Such information shall also include all such Personal Information collected and stored by Aasaan that undergoes the process of de-identification and is no more identifiable to you or any natural person (hereinafter referred to as “Non-Personal Information”). Aasaan may also collect Non-Personal Information that you voluntarily provide, such as information included in response to a questionnaire or a survey conducted by Aasaan.
- Usage Information: Usage Information includes without limitation all data and information collected automatically through the Platform and/or User Domain (or through the third party analytics service providers), by use and access of the Platform and/or User Domain in the nature of system administrative data, statistical and demographical data, and operational information and data generated by or characterizing use of the Platform and/or User Domain including without limitation Non-Personal Information, cookies, Platform/User Domain traffic, time spent on the Platform/ User Domain, number of visits to the Platform/ User Domain and other similar information and behaviour indicating the mode and manner of use of the Platform/User Domain (hereinafter referred to as the “Usage Information”).
- Personal Information, SPDI, Business Information, Non-Personal Information, and Usage Information hereinafter shall be referred to as “Information”.
- REGISTRATION, COLLECTION, AND USE OF INFORMATION
- Registration and Information you provide:
When you access the Platform, you are required to register to use the Services. To provide you the Services, we must collect such Personal Information and other information as may be informed to you at the time of registration by Aasaan from time to time.
- Non-Personal Information and Usage Information we collect:
When you visit, download, and/or use any of our Services and/or the User Domain, we may collect certain Non-Personal Information and Usage Information, including, without limitation, information about your and the End Customer’s device hardware and software that is automatically collected by us when you and/or the End Customer download, access, and use the Platform and/or User Domain (as applicable). The Platform also may access metadata and other information associated with other files stored on your or the End Customer’s device. This may include both Personal and Non-Personal Information like photographs, personal contacts, address book information, etc.
- Information we collect from other sources:
We may receive Personal Information about you and/or the End Customer from third-party sources, such as ( social media platforms, when you log in or sign-up on the Platform using your social media account or the End Customers log in or sign-up on the User Doman (as applicable), we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; (iii) advertising and marketing partners to monitor, manage and measure our ad campaigns. Information collected by Aasaan from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.
- This information we collect is used by us to: (i) operate the services and provide the services (including those subscribed by the Users); (ii) deliver personalized services; (iii) expand and improve the quality of the service; (iv) provide general aggregated statistical data regarding the use of our services; (v) analyze our performance and marketing activities; (vi) improve data security and fraud prevention; and (vii) comply with applicable laws and regulations.
- All information, including Personal Information, disclosed by you, the User shall be deemed to be disclosed willingly by you to Aasaan and without any coercion. No liability pertaining to the accuracy/authenticity/genuineness/misrepresentation/ fraud/ negligence, etc., of the Information disclosed shall lie on Aasaan, nor will Aasaan be in any way responsible for verifying any information obtained from you.
- If we want to use the Information collected for purposes other than what is mentioned herein, we will obtain specific permission from you by advising you of the identified purposes for which information collected will be used or disclosed. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, you must provide notice to us in writing. If you do not want us to collect this information, do not download it or delete it from your device.
- SHARING/DISCLOSING PERSONAL INFORMATION
- We may share or disclose Non-Personal Information about you and/or the End Customer that does not identify any individual or device without restriction. We may share Personal Information that we collect or you provide or disclose to us with our parent company, subsidiaries and affiliates, contractors, service providers, and other third-party service providers we use to support our business activities and who are bound by contractual obligations to keep such Personal Information confidential and use it only for the purposes for which we disclose it to them in accordance with this Policy. We may disclose your Information with your consent to third parties to market their products or services and for any other purpose disclosed by us when you provide the Information.
- We may disclose the Personal Information shared with us, with or without notice, only if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or comply with the legal process served on us; (b) protect and defend our rights or property and Platform; and, (c) act under exigent circumstances to protect the personal safety of users of our Platform, or the public.
- END CUSTOMERS’ PERSONAL INFORMATION
- We collect, store and process certain Personal Information of End Customers (“End Customers’ Personal Information'') solely for and on our Users’ behalf and to facilitate the provision of Services to the Users via. the Platform. For example, each of our Users is able to import their e-mail contacts from third-party services like Gmail or otherwise collect and manage contacts via. their User Domain. Such contacts are then stored with Aasaan on the User’s behalf.
- All End Customers’ Personal Information disclosed by the End Customers shall be deemed to be willingly disclosed to you, the User, via. any transactions undertaken by such End Customers on the User Domain. You hereby agree that you have obtained explicit written authorization and consent from all such End Customers without any coercion, whose information you will be sharing with Aasaan. No liability pertaining to the accuracy/authenticity/genuineness/misrepresentation/ fraud/ negligence, etc., of such Personal Information disclosed shall lie on Aasaan, nor will Aasaan be in any way responsible for verifying any End Customers’ Personal Information shared by you.
- You are solely responsible for notifying your End Customers of the collection, processing, and use of their Information and informing them that their information will be transferred to and processed by Aasaan on your behalf.
- Cookies are small data files that are placed on your computer or mobile device when you visit our Platform or use our services. Cookies are used in order to make the Platform work or to work more efficiently, as well as to provide reporting information.
- You may turn off cookies in your browser via settings. You can block cookies on your browser by refusing cookies. You may delete cookies. If you turn off cookies, you can continue to use the Platform and browse its pages, but certain services will not work correctly.
- Google Analytics is an element of the Service. Our third-party service providers and we may use Google Analytics, which transmits website traffic data to Google servers located anywhere in the world. Google Analytics does not identify individual users or associate a user’s IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and Platform usage.
- Session cookies are automatically deleted from your hard drive once a session ends, and most cookies are session cookies. You may decline the cookies, however, if you decline the cookies, you may be unable to use certain features on the Platform, and you may be required to re-enter your password frequently. You may opt to leave the cookie turned on.
- STORING OF PERSONAL INFORMATION
- Personal Information provided by you or collected from you and/or the End Customers may be stored in data centres located anywhere in the world. We are committed to keeping such information, including, without limitation, Personal Information, protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
- While you can terminate your account at any time, your information may remain stored in the archive on our servers even after the deletion or termination of your account as long as the same is required to be retained by law. However, we will not sell, transfer, or use the information relating to the terminated account of an individual in any way.
- Aasaan may transfer your Personal Information and submitted content like images and business information uploaded by you the Platform collects from you to our servers located in India for processing and storing. By submitting your information, you agree to this transfer, storing, or processing. Aasaan will take all reasonable steps, including encryption of all information, to make sure that your Information is treated securely without any loss, misuse, or alteration of Information and in agreement with this Policy. Aasaan secures the Information you provide, protected from unauthorized access, use, or disclosure.
- We also regularly monitor our systems for possible vulnerabilities and attacks and regularly seek new ways and third-party services for further enhancing the security of our Services and protection of our Users’ privacy.
- Regardless of the measures and efforts are taken by us, we cannot and do not guarantee the absolute protection and security of your Information and the End Customers’ Personal Information , including without limitation, Personal Information, or any other information you upload, publish, or otherwise share with Aasaan or is shared with the User Domain or anyone else. We encourage you to set strong passwords for your Account and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
- Furthermore, because certain areas on our Services are less secure than others, and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
- The transmission of information via the internet is not entirely secure. Therefore, Aasaan cannot guarantee the security of data sent to us electronically, and communication of such data is therefore entirely at your own risk.
- You also agree and understand that access to your Account on the Platform and to your User Domain is via. your Login Credentials, which is the password, protected, and this helps to secure your account information. You are solely responsible for maintaining the confidentiality of your login credentials. To ensure safety of your Information, you are advised against sharing your login credentials with anyone. If you suspect any unauthorized use of your Account and/or your User Domain, you must immediately notify Aasaan by sending an email to firstname.lastname@example.org. You shall be liable to indemnify Aasaan for any loss suffered by Aasaan due to such unauthorized use of your Account and/or User Domain.
- For any loss or theft of Information due to unauthorized access to your device through which you use the Platform and/or User Domain or other reasons solely attributable to you, Aasaan shall not be held liable or responsible under any circumstance whatsoever. Further, Aasaan shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Aasaan’s reasonable control, including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the user, etc.
- For further details in relation to the security standards used by Aasaan, you may visit .aasaan.app/security.
- CONTROL OVER YOUR PERSONAL INFORMATION
You have the right to withdraw your consent at any point, provided such withdrawal of the consent is intimated to Aasaan in writing through an email at email@example.com requesting the same. Once you withdraw your consent to share the Personal Information collected by Aasaan, Aasaan shall have the option not to fulfil the purposes for which the said Personal Information was sought and Aasaan may restrict you from using the services on the Platform and/or the User Domain.
- RECTIFICATION/CORRECTION OF PERSONAL INFORMATION
- You shall have the right to review your Personal Information, Business Information and/or SPDI (as the case may be) submitted by you on the Platform and to modify or delete any Personal Information and/or SPDI (as the case may be), provided by you directly on the Platform. You hereby understand that any such modification or deletion may affect your ability to use the Platform. Further, it may affect Aasaan’s ability to provide its services to you.
- Similarly, the End Customer has the right to withdraw his/her consent at any point. Provided such withdrawal of the consent by the End Customer is intimated to Aasaan by you, in writing through an email at [insert details] requesting the same. Provided however that this will not make processing which we undertook before such withdrawal of consent unlawful.
- Aasaan reserves the right to verify and authenticate your identity and your account information in order to ensure accurate delivery of Services. Access to or correction, updating or deletion of your Personal Information, Business Information and/or SPDI (as the case may be) may be denied or limited by Aasaan if it would violate another person’s rights and/or is not otherwise permitted by applicable law.
- DATA RETENTION
- We may retain your Personal Information (as well as your End Customers’ Personal Information) for as long as your Account is active, as indicated in this Policy, or as otherwise needed to provide you with our Services, subject to applicable law.
- We may continue to retain your Personal Information after you cancel/deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or End Customers, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
- We may store Non-Personal Information and Usage Information received by us in perpetuity, provided such storage and retention is in accordance with applicable law.
- You agree that you will not submit any false information or any illegal or damaging content to the Platform.
- Aasaan reserves the right to terminate access to or the ability to interact with the Platform and/or the User Domain in response to any concerns Aasaan may have about false, illegal, or damaging content, or for any other reason, in its sole discretion.
The Platform and/or the User Domain may contain links to other third-party websites such as Google Pay and others. We are neither responsible for the privacy practices of such websites or services nor endorse them. We encourage you to be aware when you leave the Platform and/or your User Domain and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Policy does not apply to such linked third-party websites and services.
- PUBLIC FORUMS AND USER CONTENT
Our Services offer publicly accessible blogs and support contact through email. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request the removal of your Personal Information from our blogs, feel free to contact us at: firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third-party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such a third party, you must log in to such an application or contact its provider if you want to remove the Personal Information you posted on that platform.
- In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.
- If you upload any User Content to your Account or post it on your User Domain and provide it in any other way as part of the use of any Service, you do so at your own risk.
- Although we have put adequate security measures in place to protect your Personal Information, we cannot control the actions of other Users or members of the public who may access your User Content and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Domain (including, for instance, password-protected areas on your User Domain). You understand and acknowledge that even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your End Customers) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
- MINOR AND USAGE ON BEHALF OF ANOTHER PERSON
Aasaan does not intend to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. Aasaan does not intentionally or knowingly collect Personal Information through the Platform and/or User Domain from anyone under that age. Aasaan encourages parents and guardians to be involved in the online activities of minors to ensure that no Personal Information is collected from a minor without their prior consent. If you are using the Platform on behalf of someone else, including but not limited to, on behalf of your minor child/children/employer, you represent and warrant that you are authorised by such person to accept this Policy on their behalf and to consent on behalf of such person to Aasaan’s use of such person’s Personal Information as described in this Policy.
- BUSINESS TRANSITION
In case Aasaan undergoes a business transition, such as a merger, acquisition by another company, to or the sale of a portion of its assets, the Personal Information shared with us will, in most instances, be part of the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy and that any acquirer of ours or that acquirer’s assets may continue to process the Personal Information as set forth in this Policy. If, as a result of the business transition, the Personal Information will be used in a manner different from that stated at the time of collection, the relevant data subjects will be given a choice not to have their information used in this different manner as described in the Changes to this Policy section, below.
- UPDATES/CHANGES TO THIS POLICY
Aasaan will occasionally update this Policy to reflect company and customer feedback, and applicable laws personal information that reflects changes to our Personal Information collection, usage, and storage practices. We shall notify you at least once in a year or whenever there is a change in the Policy, as the case may be by email or by posting a prominent announcement on the Platform. However, we encourage you to periodically review this Policy to inform how Aasaan is protecting your information. Your continued use of the Platform after we make changes is deemed to be an acceptance of those changes.
- LIMITATION OF LIABILITY
- Aasaan shall not be liable to you for any loss of profit, production, anticipated savings, goodwill or business opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive, exemplary or consequential losses arising out of performance or non-performance of its obligations under this Policy.
- Aasaan is not responsible for any actions or inactions of any third parties that receive your Information.
- Notwithstanding anything contained in this Policy or elsewhere, Aasaan shall not be held responsible for any loss, damage, or misuse of your Information, if such loss, damage, or misuse is attributable to a Force Majeure Event. The term “Force Majeure Event” shall mean any event that is beyond the reasonable control of Aasaan and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, pandemic or national/state lockdown due to any reason and any other similar events not within the control of Aasaan and which Aasaan is not able to overcome.
- COMMUNICATION POLICY AND OPT-OUT
- Service and billing messages: We may contact you with necessary information regarding our Services or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; or send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Domain; or notify you of material changes in our Services.
- Promotional messages: We may use your Personal Information to send you promotional content and messages by email, text messages, notifications within our Platform, marketing calls, and similar forms of communication from our partners or us (acting on our behalf) through such means.
- You may choose to “Opt-Out”/stop receiving our newsletter or marketing emails by following the unsubscribe link included in these emails or by sending an email to email@example.com. However, you will not be able to opt-out of receiving administrative messages, customer service responses or other transactional communications. Also, opting out of the Platform’s collection of location information will cause only its location-based features to be disabled.
Any heading, caption, or section title contained herein, is provided only for convenience and in no way defines or explains any section or provision hereof or legally binds any of us in any way. Any mention in the singular is inclusive of plural, and mention in any gender is inclusive of other genders also.
- GOVERNING LAW
This Policy shall be governed by and interpreted, and construed in accordance with the laws of India. The place of jurisdiction shall exclusively be in Hyderabad, Telangana. In the event of any dispute arising out of this Policy, the same shall be settled by a binding arbitration conducted by a sole arbitrator, appointed jointly by both parties and governed by the Arbitration and Conciliation Act, 1996. The venue of arbitration shall be Hyderabad, India.
- GRIEVANCE REDRESSAL MECHANISM
In accordance with the Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Grievance Officer are provided below:
Name: [Murali Gottumukkala]
Address: [1-65/2/A/46, Plot No 46, Cyber Hills, Kakateeya Hills Rd 9, Kakatiya Hills, Guttala_Begumpet, Hyderabad, Telangana 500081, India]
For registering your complaint, please write to the Grievance Officer at the above-mentioned email address in relation to any violation of this Policy or the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. The Grievance Officer shall redress the complaint in accordance with the provisions of the Information Technology Act, 2000, and the Rules made thereunder.
- CONTACT INFORMATION
Aasaan welcomes your comments and questions regarding this Policy. If you believe that Aasaan has not adhered to this Policy, please contact Aasaan at firstname.lastname@example.org, or you can write to the following address-
Lightbooks Technology Private Limited
Cyber Hills, Kakateeya Hills Rd 9,
Kakatiya Hills, Guttala_Begumpet,