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PRIVACY POLICY PART I.
  1. This Privacy Policy Part I (“Privacy Policy Part I”) applies to the SonetShraddha OTT Platform of Sonic Octaves Pvt. Ltd. (“SonetShraddha”) digital Site(s)/ App(s) platforms including without limitation www.shraddha.sonet.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 SonetShraddha and its subsidiaries or affiliated companies. (collectively, “SonetShraddha” or “we”, “us” and “our”).
  2. This Privacy Policy Part I 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.
  3. Please read this Privacy Policy Part I 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 Part I. 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 Part I with your parent or guardian.
SUMMARY OF KEY POINTS
  • A. 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.
  • B. We provide interactive features that engage with third-party social media Site(s)/ App(s), such as Facebook ,Whatsapp etc.  Any data that we obtain about your use of such features is subject to this Privacy Policy Part I. Any data that the social media Site(s)/ App(s) gather about you is subject to your terms with them.
  • C. 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.
  • D. 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.  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 Part I. 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.
  • F. 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 PART I
(i) 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 part in 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. (ii) Whenever you visit or interact with the Site(s)/ App(s) or SonetShraddha content, SonetShraddha, 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 SonetShraddha associates it with you as a specific and identifiable person, SonetShraddha treats it as Personal Information. SonetShraddha 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). (iii) The technologies used on the Site(s)/ App(s) to collect Usage Information, including Device Identifiers, have been detailed herein below.
  1. COOKIES AND OTHER TRACKING TECHNOLOGIES
(i) 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 behaviour 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. (ii) 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. (iii) 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. (iv) SonetShraddha may use cookies and web beacons for a number of purposes, including to:
  • a. Provide general internal and customer analytics.
  • b. 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, SonetShraddha keeps track of the domains from which people visit, and also measures/tracks visitor activity on SonetShraddha Site(s)/ App(s). However, these tracking records are performed and maintained in ways that keep the data non-identifiable.
  • c. Keep track of preferences you specify while you are using SonetShraddha products or services.
  • d. Support security measures, such as requiring re-login into an SonetShraddha product or service, after a certain amount of time has elapsed.
  • e. 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.
  • f. Assist in identifying possible fraudulent activities.
  • g. Tell if an email has been opened and acted upon.
(v) 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 SonetShraddha. SonetShraddha employs Adobe Flash cookies in certain situations where we use Flash to provide some content such as video clips or animation. SonetShraddha 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 SonetShraddha 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. SonetShraddha at its sole discretion may employ any other third-party(ies) analytics services, as may be required.
  1. 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.
  1. 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), SonetShraddha 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 Part I 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 SonetShraddha does not knowingly collect data of users younger than 18 years of age.
  1. 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.
  1. HOW WE SHARE YOUR PERSONAL INFORMATION
  • 6.1 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 Part I and business practices of that third-party. You may also specifically request SonetShraddha, 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.
  • 6.2 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 fulfillment, 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.
  • 6.3 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 SonetShraddha, 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.
  • 6.4 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. SonetShraddha 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, SonetShraddha 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 SonetShraddha’s assets, or other corporate change including, without limitation, during the course of any due diligence process
  • 6.5 POTENTIAL INVESTORS Certain investors may be interested in investing funds in SonetShraddha. For the purposes of securing such investment, SonetShraddha 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 SonetShraddha be held liable for use of such Personal Information/ Information by itself and the aforementioned third parties.
  1. 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.
  1. LINKS TO OTHER SITE(S)/ APP(S) AND SERVICES, AND SONETSHRADDHA CONTENT 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 showtimes” 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 Part I and is usually governed by their own terms of use and Privacy Policy Part I. By clicking through to these third-party Site(s)/ App(s) applications, you will be governed by such third-party’s Privacy Policy Part I/ 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. SonetShraddha is not responsible for the privacy practices or business practices of any third-party Site(s)/ App(s). SonetShraddha 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 Part I/ 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. SonetShraddha is not responsible for the privacy practices or business practices of any third-party Site(s)/ App(s).
  1. 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.
  1. 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 Part I 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 SonetShraddha 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.
  1. INFORMATION WE RECEIVE FROM THIRD PARTIES
SonetShraddha 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 SonetShraddha 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 Part I. 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 Part I to any Personal Information received, unless we have disclosed otherwise.
  1. WE MAY USE AD SERVING AND TRAFFIC MEASUREMENT SERVICES; HOW TO “OPT OUT” OF RECEIVING ADVERTISING RELEVANT TO YOU
SonetShraddha 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, SonetShraddha 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.
  1. 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.
  1. 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 [email protected] (name and contact no of the Grievance office not mentioned. Who ) or write to us at: Legal Department Sonic Octaves Pvt. Ltd. A/202 Dwarkamai, Pannalal Ghosh Marg, Somwar Bazar, Malad West, Mumbai 400064 We request you to please provide the following information in your complaint:-
  • a. Identification of the information provided by you
  • b. Clear statement as to whether the information is Personal Information or sensitive Personal Information
  • c. Your address, telephone number or email address.
  • d. 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.
  • e. 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 Part I using the contact information mentioned above.
  1. NOTIFICATION OF CHANGES AND YOUR ACCEPTANCE OF THE PRIVACY POLICY PART I
We reserve the right to change the terms of this Privacy Policy Part I 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. SonetShraddha will use your Personal Information in a manner consistent with the Privacy Policy Part I in effect at the time you submitted the information.
  1. 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.
  1. 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.
  1. 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.
  1. GRIEVANCE OFFICER
The grievance officer for the purpose of this Privacy Policy Part I 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 [email protected]. 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 Part I and applicable laws with respect to this Privacy Policy Part I.
  1. 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 Part I.
  1. 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 Part I. IN ADDITION TO THE ABOVEMENTIONED TERMS/PROVISIONS OF THE PRIVACY POLICY PART I, BELOWMENTIONED GDPR COMPLIANCE PROVISIONS SHALL BE CONSTRUED AS PART II OF THE PRIVACY POLICY AND SHALL BE APPLICABLE ON THE SUBSCRIBER(S)/USER(S) RESIDING IN EUROPEAN UNION:   GDPR COMPLIANCE PROVISIONS (PRIVACY POLICY PART II) SonetShraddha 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 Part I) 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.
  1. PURPOSE OF COLLECTING YOUR INFORMATION
  2. One of the prime purposes of uploading the Privacy Policy Part II 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 Part II to understand how Your Information would be processed and the purpose for processing Your Information.
  1. We process Information to pursue our legitimate interest to run, maintain and develop our services inorder 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.
  2. To optimise 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 [email protected]. We will stop the use of Your Information for such purposes as soon as it is reasonably possible to do so.
  3. 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.
  4. 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.
  5. HOW DO WE USE YOUR INFORMATION?
SonetShraddha 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.
  1. 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.
  1. WHERE DO WE PROCESS/STORE YOUR INFORMATION?
Our servers are managed by the third party vendors and may be located anywhere in the world and its completely the discretion of the third party vendor on which SonetShraddha does not have any control. We also have support, engineering and other teams that manage the Site(s)/App(s), located in India. 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 of SonetShraddha or by the designated personnel from the third party vendor (identification of which may not be known to SonetShraddha)
  1. 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.
  1. HOW LONG DO WE RETAIN YOUR INFORMATION?
  2. You Information is retained for up to 10 (ten) years from the date when the Information is collected/received by us. You may instruct us to delete your Information collected by us by writing an email to us at [email protected]. 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.
  3. However, SonetShraddha will continue to retain your financial/ transactional data (detailed in clause 7(d) and 7(e) of Privacy Policy Part II ) 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.
  4. For Registered users of Site(s)/App(s, we will retain your Account ID and Email ID
  5. For subscribed user below is the list of Information that shall be retained by us.
  • 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
  • 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 SonetShraddha
  1. WHAT RIGHTS DO YOU HAVE OVER YOUR INFORMATION?
As a resident of EEA and a user of SonetShraddha, 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 [email protected]. CONTACT INFORMATION If you have any concerns or complaints regarding the use of the Site(s)/Apps(s), please contact us at [email protected]. Alternatively, you can reach out to the Data Protection Officer at [email protected] 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. Legal Basis (EU): Contract

  • To set up and log-in to a user account on SonetShraddha;
  • To notify you about changes to SonetShraddha;
  • To facilitate communication;
  • To provide you with user support;
  • To enforce our terms, conditions, and policies;
  • To communicate with you;
  • To provide personalised help and instructions;
  • To better understand how you access and use SonetShraddha;
  • To develop new and improve existing features;
  • To provide language and location customisation;
  • To protect any rights, property or safety of ours, our affiliate companies, or other users of SonetShraddha; and
  • To administer SonetShraddha 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. Legal Basis (EU): Contract

To provide quick access to previous searches.

Additional Account Security.
 Kids mode PIN (an optional security features for you), Managed Devices, Email address, Facebook, Whatsapps ID Token. Legal Basis (EU): Contract

To verify your identity account security.

Log File Information
 See definition above. Legal Basis (EU): Legitimate Interests

To better understand how you access and use SonetShraddha; To administer SonetShraddha; For internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management.

Android Device Permissions.
 Your on-device contact list, SMS, Location, Telephone Legal Basis (EU): Contract

To process payment for subscription via various payment gateways, wallets, mobile carrier billing, etc;

Transaction/ Financial information Legal Basis (EU): We process this data in accordance with our obligations under applicable law.

As per Indian law and jurisdiction, SonetShraddha is required to store information regarding any payment transaction attempted on the platform. Account ID (Customer ID)- created when a user registers on the app Order ID (generated when a user initiates a transaction) Location (Location from which the transaction was done) Package selected Duration of Package (Quarterly, Half-yearly, Yearly) Payment gateway through which transaction has been done Email Id of the user Date of transaction Type of transaction (Success/ Failure) Invoice issued to subscriber

Customer Support Information. Any information that you provide to our customer support team. Legal Basis (EU): Contract

  • To investigate your support issue.

Device Data. Media stored on your device. Legal Basis (EU): Contract

  • To facilitate the usage of the download feature of SonetShraddha.

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. Legal Basis (EU): Consent

  • To better understand how you access and use SonetShraddha;
  • To provide personalised help and instructions;
  • To develop new and improve existing services;
  • To improve SonetShraddha 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 SonetShraddha. Legal Basis (EU): Contract

  • 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

  • Analysis of what features or actions are taken within the app in order to improve app experience
  • Fraud detection and account safety analysis
  • User demographic analysis on items such as region, phone model, operating system platform, system language, and SonetShraddha version in order to better understand how our users are using SonetShraddha
  • Web and account traffic statistics of what content and services are used when users access third-party services on the SonetShraddha Open Platform as a method for informing third-party service providers basic analysis of how their service is being used by SonetShraddha users

Cookies. We further explain such collection in “Cookies and other Tracking Technologies” section. Legal Basis (EU):** Contract

  • 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 SonetShraddha; and
  • For financial reconciliation
  • To investigate fraud
  • To comply with Indian tax laws
  • To provide support and troubleshooting
 
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