PRIVACY POLICY

This privacy policy (“Policy”) forms an integral part of Our Terms of Use and Service (“Terms”). You must read, understand and agree to, and be bound by, the Privacy Policy. You must not access the Platform (as defined in the Terms), in any manner, in case You do not expressly accept this Policy in its entirety.

This Policy explains how ‘Leovy Solutions Private Limited’ and/or its affiliates, subsidiaries, Counsellors (as defined in the Terms), associates, partners, advertisers or advisors (hereinafter referred to as "We" or "Us" or "Our" or “Company”) collects, uses, discloses and protects the Personal Information (as defined hereinafter) and Sensitive Personal Information (as defined hereinafter), obtained explicitly through the Platform, or collected from You through Your direct submission or disclosure while availing the Services (as defined in the Terms), and also other information collected automatically without direct submission by You as a user of Platform (hereinafter referred to as “You”, “Your”, “User”). This Policy governs all the Services, features, products, properties and content, either on a subscription model or otherwise, We offer directly or indirectly through the Platform.

By accessing the Platform, You agree to this Policy with respect to the collection, processing and use of Your personal data or information by Us. Please do not access and register on the Platform or avail the Services if You do not wish to share the mandatory personal information requested at the time of registration on the Platform or while availing the Services. Registration procedure cannot be completed until information requested in the non-optional fields is provided.

  1. Collection of Information

We collect certain information from and about its users directly from the user, and amongst other means, from server logs and other data files.

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, We put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information collected online.

In order to allow access and to gain an authorized access to the contents on the Platform, We obtain certain information from the user, such as contact information (full name, address, and telephone number), e-mail address, and method of payment and other, through the process of registration.

a.  “Personal Information” is information that relates to a user and which, either directly or indirectly, in combination with other information available or likely to be available with the Company, is capable of identifying such person.

The following data may be collected as Personal Information by the Company from You through Your manual inputs:

  • Name;

  • Date of birth;

  • Telephone number;

  • Email address;

  • Postal/Contact address;

  • PAN (as applicable);

  • The IP address of Your computer and mobile systems, its type and language;

  • The date and the time of Your accessing the Platform;

  • Your photograph for the purpose of testimonials and other promotions;

  • Any communication, in any manner, between You and Us.

  • Any other information that is defined as “personal information” in law;

Additionally, the following information may be automatically collected, when You visit and use the Platform:

  • The type of device and hardware You use;

  • Your IP address;

  • Your browser type;

  • information about Your use of the Platform (when, how, how long, account used to log in, features/groups used while logged in; status and quantity of devices; operation mode);

  • installations / smart devices (Soft-/Firmware versions of gateway & devices);

  • first activation date;

  • clicks;

  • GPS and/or WIFI Position;

  • Your used language etc.

The information We collect helps Us administer the Platform, analyze its usage, protect the Platform and its content from inappropriate use and improve the user experience.

b.   “Sensitive Personal Information” shall include account passwords and financial information such as bank account, credit card, debit card or other payment instrument details, and may also include the follows:

 

  • physical, physiological and mental health condition;

  • sexual orientation;

  • medical records and history;

  • Biometric information;

  • any detail relating to the above clauses as provided to the Company for providing Services;

  • any of the information received under this clause Company for processing, stored or processed under lawful contract or otherwise:

  • Any other information that is defined as “Sensitive personal data or information” in law;

Log Files: Our Platform may collect and uses the data contained in log files. The information in the log files will include browsing habits and usage behavior, areas of the Platform that are visited. We routinely use this log information in the aggregate in order to administer and improve the Platform & ensure security.

Cookies: Our Platform may store and use ‘cookies’ to collect and receive certain information (that is not Personal Information and Sensitive Personal Information). A user has the option to disable the cookies through the appropriate functioning of its browsers.

Our Platform may offer the functionality of registration through “third-party social networking accounts” (“Social Accounts”). In case, You choose to register this way, You will have to log-in and link Your Social Account with the Platform, subject to being permitted by Your Social Account service provider. You may link Your Social Account either by providing Your Social Account login information to us through the Platform; or allow us to access Your Social Account, in accordance with the applicable terms and conditions that applies to Your usage of each Social Account. We shall make use of and store Your personal information and other public information stored in Your Social Accounts to create Your account and profile; however, such usage shall be restricted by the terms and conditions and the privacy settings that You may have applied on Your Social Accounts.

2.  How and why do We use Your personal information

We use Your personal information (including Personal Information and Sensitive Personal Information) to offer You Our Services and provide You with the access to Our Platform. We use Your personal data for the following purposes:

  • To enable You to access the Services and use the Platform;

  • To provide, maintain and improve the Platform and Our Services to You;

  • To inform You about new versions or features of the Platform;

  • To respond to Your questions and requests, including Your customer service enquiries;

  • To send You communications and marketing material about products, services, offers, promotions, properties, rewards, and events offered by us or by any of Our affiliates; and provide news and information We think will be of interest to You; These offers may include targeted special offers tailored to You that are offered by us or by any of Our affiliates;

  • To send You promotional emails about products, services, offers, promotions, properties, rewards and events offered by us or by any of Our affiliates;

  • For authentication and protection against identity fraud and identity theft;

  • To monitor and analyze trends, usage and activities in connection with the Platform;

  • To send You emails related to Your use of the Platform and the Services in general, including alerts;

  • To send You technical notices, updates, security alerts and support and administrative messages;

  • To safeguard from unlawful activities including any money laundering activities or other misuse;

  • For research and analytics;

  • For enforcing the terms and conditions;

  • For billing and collection purposes;

  • As We may notify You from time to time;

  • As permitted by applicable law;

  • Any other permitted use.

 

3.  Information Sharing:

We may share Your personal information (including Personal Information and Sensitive Personal Information) collected for the following purposes:

  • Legal Purposes: We may share Your information to the law enforcement and other government agencies, courts and other bodies on their legal requests to comply with the law and aid to the ongoing and impending legal proceedings. We may also use Your information when it is necessary to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process or to comply with any law in force or to address threats to the physical safety of any person or to safeguard the rights of Our employees, users, or the public at large;

  • to enforce its Terms of Use and Service and this Privacy Policy;

  • for prevention of fraud;

  • in the event of any perceived threat or risk to Your health;

  • for issues involving information security, or to protect Your rights, or rights of Company, or rights of general public.

 

4.  Aggregate Information:

We may collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information may be derived from analysis of Personal Information. This statistical information is not Personal Information and cannot be tied back to You, Your account.

 

5.  Consent:

All users of Our Platform must consent to the use of their Personal Information and Sensitive Personal Information by Us for the purposes stated in this Policy. We restrict access to such information to Our employees, contractors and agents and only allow access to those who need to know such information in order to provide Services or to process it further on Our behalf.

Users are entitled to withdraw consent to the use of their Personal Information and Sensitive Personal Information by emailing a specific request to Us. Withdrawal of consent to use all or any part of Personal Information and Sensitive Personal Information may result in the immediate withdrawal of any rights provided to the user, including access to the Services provided by Us. Withdrawal of consent by users shall not restrict the right of Use to use personal data for the analysis of user data.

Users’ providing photographs to Us grant irrevocable rights to Us to use them for marketing purposes and it is solely Our discretion to delete or not use them any further.

Consent to email communication

When You register Your email address with Us, You agree to receive email communication from Us, entities specifically authorized by Us, and other users. You also agree and acknowledge that when You use Our referral program, if any, for referring someone, We may send emails to the person referred by You on Your behalf and the email headers will carry Your email address as the address from which such emails are sent. We may also access and store such information relating to Your contacts to send invitations and other promotions to them periodically.

Consent to telephonic communication

Any telephonic communication between You and Our customer support staff may be recorded for the purposes of employee training and quality management, as well as the speedy resolution of Your queries.

 

6.  Data Security

We take appropriate security measures to protect user data from unauthorized access and its unauthorized alteration, disclosure or destruction. These measures include internal reviews of Our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where We store users’ personal information. We have a comprehensive information security program and information security policies that contain managerial, technical, operational and physical security control measures adopted by Us for the protection of Personal Information and Sensitive Personal Information.

Information gathered by Us is stored securely using several information security applications including firewalls. However, security is always relative and We cannot guarantee that the security measures are absolute and cannot be breached. Data transmitted over the internet is inherently exposed to security risks or threats. Therefore, We cannot guarantee any security for such information in the course of transmission through the internet infrastructure or any unsolicited disclosures made by any user using the Services on the Platform.

When You register with Us, Your account is protected by means of login information, including a username and a password, which is known only to You. Therefore, You should not provide Your login and other Personal information to anyone whosoever; breach thereof shall constitute violation of this Policy and may result in closure of Your account in certain cases. If You become aware of or reasonably suspect any breach of security, including compromise of Your login information, it is Your responsibility to immediately notify Us.

We have a policy of not sharing any personally identifiable information with anyone other than the entities specifically authorized by Us, which may include Our advertisers and sponsors. However, We may use information like Your name, photo, login ID (without password) and the state from where You are participating when announcing the results of any contests hosted on the Platform. Such contests are further governed by terms and conditions, which shall be available on the Platform as and when such contests are hosted on the Platform. We conduct periodic analysis and survey of the traffic to the Platform and associated website for market research and advertising purposes. We reserve the right to share Your registration information with Our appointed market research and advertising companies or firms from time to time for the said purposes. We may also use cumulative non-personal information for auditing and analysis purposes with the aim of improving the services.

 

7.  Changes to this Policy

By signing up for the Services on the Platform, the User consents to the collection and use of the previously mentioned information on the Platform. We may periodically change this Policy without notice, and User is responsible for checking the policy periodically for revisions. All amended terms become effective upon Our posting to the Platform, and any use of the Platform after such revisions have been posted signifies the consent of the User to the changes. Where the changes are significant, a more prominent notice through email notification will be sent.

8.  Data retention and account deletion

You have the option to terminate Your account by visiting the relevant section on the Platform. We will remove all of Your public information and posts, if any, on such termination and shall dissociate them from Your account so that it is seen anonymous and not attributed to Your identity. However, We may retain certain information about You for the purposes authorized under this Policy and Terms of Use and Service unless prohibited by law. The information is retained to prevent, investigate, or identify possible wrongdoing in connection with the Services or to comply with legal obligations.

9.  Privacy measures for minors

Our Platform, Services and contests, if any, are meant only for persons aged 18 or above. If You are under 18 years of age, You are not permitted to use Our Platform. If You are a parent and/or guardian and believe that We may have inadvertently collected personal information from Your child, You can notify us immediately by sending an email to ‘hello@lostalittle.com’.

 

10.  Limitation of Liability

We confirm that this Privacy Policy is only a description of its operation regarding user information. This Privacy Policy is not intended to create, and does not create, any legal rights in Your favor or in favor of any other person. The liability of Company shall be limited to the removal of Sensitive Personal Information from the system of the Platform and the removal of personally identifiable elements of other Personal Information. Notwithstanding anything to the contrary contained in this Policy and elsewhere, the aggregate liability of Company for all claims for damages pursuant to the provisions of Services on the Platform, including claims in respect to the violation of this Policy, shall be governed by the provisions under the Terms. Your continued use of the Platform constitutes Your agreement to this Privacy Policy and any amendments thereof.

 

11.  Applicable Laws

This Privacy Policy and collection and processing of any data shall at all times be governed by the applicable data privacy and protection laws of India as may apply to the Company in the jurisdictions where Services are offered.

 

12.  Grievance Officer

All communications relating to personal data may be sent to the Company at ‘hello@lostalittle.com’.

 

 

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