PRIVACY POLICY EFFECTIVE DATE – May 21, 2024
1. INTRODUCTION
1.1. PURPOSE OF POLICY
NeoImpact Advisory Private Limited (“us,” “we,” or “Company”) is committed to respecting the privacy rights of its customers, visitors, and other users of the Company Website (the “Site”). We created this Website Privacy Policy (this “Policy”) to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. This Policy is only applicable to the Site, and not to any other websites that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy.
1.2. NOTICE CONCERNING CHILDREN
PLEASE NOTE: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete or deidentify any personal information in that user’s account.
1.3. ABOUT THE GENERAL DATA PROTECTION REGULATION
The General Data Protection Regulation (GDPR) takes effect on May 25, 2018 and includes substantial changes to the European Union data protection laws. The purpose is to standardize data protection laws across the EU, enable people in the EU enhanced rights to their data and require businesses to meet technical and organizational controls around the collection and processing of personal data. The Company has made changes in line with these new standards, which changes are set forth below in Section 7.
Please read this statement carefully and contact our Data Protection Officer at [email protected] if you have any questions about our privacy practices or your personal data choices, and please also feel free to contact your supervisory authority, contact details for which may be found here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
2. INFORMATION COLLECTION PRACTICES
2.1. WHAT BASIC INFORMATION DOES THE COMPANY COLLECT? We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
We obtain the categories of personal information listed above directly from you through the forms you complete or the products and services you purchase.
2.2. WHAT ADDITIONAL INFORMATION DOES COMPANY COLLECT?
The categories of information described below are collected indirectly from you:
(a) AUTOMATIC COLLECTION. The Site may also gather “traffic data,” from sources such as Google Analytics, Google Tag Manager, and Cloudflare. This data may include your IP address and browser history. This information is used for marketing purposes or for improving the services we offer.
(b) COOKIES. From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to our Site. We do not employ any data capture mechanisms on our Site other than cookies. Cookies help us learn which areas of our Site are useful and which areas need improvement. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this function, your experience at our Website may be diminished and some features may not work as they were intended.
3. USE AND SHARING OF INFORMATION
3.1. WHAT DOES COMPANY DO WITH COLLECTED INFORMATION?
(a) PERSONAL INFORMATION. We will not share your personal information with any third parties without your consent, except as necessary to provide you with the services offered by us or to comply with the law. We may use your personal information to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Site. For instance, your payment information is collected and processed by our payment processor Stripe.com. You may view Stripe.com’s privacy policy at https://usa.visa.com/legal/privacy-policy.html. We may also use your contact information to inform you of any changes to the Site, or to send you additional information about Company. We provide email addresses to our marketing firm/s, and our email distributor, if any, for the purpose of marketing new services and products to you. If you give your permission during the account registration process, we may share your contact information with our business partners or other companies so that they may send you promotional materials.
(b) ANONYMOUS INFORMATION. We use anonymous information to analyze our Site traffic, but we do not examine this information for individually identifying information. In addition, we may use anonymous IP addresses to help diagnose problems with our server, to administer our site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.
(c) USE OF COOKIES. We may use cookies to deliver content specific to your interests, to save your password so you don’t have to re-enter it each time you visit our site, or for other purposes. Promotions or advertisements displayed on our site may contain cookies. We do not have access to or control over information collected by outside advertisers on our site.
(d) DISCLOSURE OF PERSONAL INFORMATION. We may disclose personal information for the purposes disclosed in Section 3.1(a) above, or if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on Company or its parent company, subsidiaries or affiliates, (2) protect and defend the rights or property of Company or the users of the Site, or (3) act under exigent circumstances to protect the safety of the public or users of the Site.
(e) SALE OF INFORMATION. In order to accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the information collected through this Web site. If Company or substantially all of its assets are acquired, customer information will be one of the assets transferred to the acquirer.
(f) ACCESS TO INFORMATION. Unfortunately, we do not maintain any procedures for you to review or request changes to the information that we collect about you, except that you may request that we remove all information about you from our database by contacting us in accordance with Section 6.1 below.
4. SECURITY
The Site has security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.
5. WEBSITE AREAS BEYOND COMPANY’S CONTROL
5.1. PUBLIC FORUMS
The Site may include interactive forums such as message boards and chat rooms. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.
5.2. THIRD PARTY WEBSITES
The Site may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.
6. CONTACT INFORMATION AND POLICY UPDATES
6.1. CONTACTING US
If you have any questions about this Policy, our practices related to this Site, or if you would like to have us remove your information from our database, please contact us at the following: [email protected].
6.2. UPDATES AND CHANGES
We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms.
6.3. UNSUBSCRIBE POLICY
You can unsubscribe your name from our email/telephone and marketing lists by writing to us at [email protected].
7. GDPR PRIVACY POLICY
If you are a user in an EU Member state, this Section 7 of the policy applies to you. Should you have any questions or concerns about this GDPR Privacy Policy, please feel free to contact the Company. The Global Headquarters of the Company are located at A-Block, BHIVE Workspace – No.112, AKR Tech Park, 7th Mile Hosur Rd, Krishna Reddy Industrial Area, Bengaluru, KA, 560068 India and may be reached by calling +91-950-323-2902 or by email at [email protected]. The Company’s Data Protection Officer is Brian Haven who may be reached at [email protected] and please also feel free to contact your supervisory authority, contact details for which may be found here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
7.1. THE COMPANY AND YOUR PERSONAL DATA
Your privacy is important to us, and we have prepared this Privacy Policy to explain how we collect, use, and protect your information when you use our Site, and to illustrate your choices for managing your information preferences. This includes your rights regarding your personal data in accordance with the EU GDPR. Personal data in this regard means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, including by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
If you are a user in an EU Member state, please be advised that we transfer all information to India for storage and processing, and your consent to this Policy represents your consent to this transfer, storage, and processing.
7.2. PERSONAL DATA WE COLLECT
When you register on our Site, request information, make a purchase from us or perform other actions on the Site, you provide us with information about you such as your name, username, password, email address, and phone number. When you make a purchase from us, our payment processor Stripe.com collects your credit card information and billing address to complete the transaction. Stripe.com provides us with the last four (4) digits of your credit card number as an identifier for your transaction.
Please see Section 2 above for further details about the personal data we collect and the additional data that we collect.
The legal basis for processing the personal data we collect (in accordance with the policies of the Company, including this Policy), as well as the mechanism for transferring that personal data from the European Union, is the affirmative consent you provide when interacting with our Site. You may withdraw such consent at any time by email to our DPO at: [email protected].
7.3. HOW WE USE AND STORE YOUR PERSONAL DATA
We use the personal data you provide through our Site to complete the sale of products, to alert you of updates to such purchased products, and to inform you of products we think you may be interested in. We will not share your personal data with any third parties without your consent, except as disclosed in Section 3 above, as necessary to provide you with the services offered by us, or to comply with the law. We may use your personal data to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Site. We may also use your contact information to inform you of any changes to the Site, or to send you additional information about the Company. If you give your permission during the account registration process, we may share your contact information with our business partners or other companies so that they may send you promotional materials.
We use anonymous information to analyze our Site traffic. We may use anonymous IP addresses to help diagnose problems with our server, to administer our site, or to display the content according to your preferences.
We may use cookies to deliver content specific to your interests, to save your password so you don’t have to re-enter it each time you visit our site, or for other purposes. Promotions or advertisements displayed on our site may contain cookies. We do not have access to or control over information collected by outside advertisers on our site. You can change your web browser settings to not accept cookies, but doing so may impact your experience with our Site.
Your information is not stored unless you purchase a product or otherwise submit a form providing affirmative consent for us to collect your personal data for providing the uses set forth herein. Your information will no longer be stored when it is no longer used for the purpose for which it has been collected.
We have implemented a variety of commercially standard encryption and security technologies and procedures to protect information, including your personal information, stored in our computer systems from unauthorized access. Please be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure, thus we strive to use commercially acceptable means to protect your personal information, but we cannot guarantee its absolute security.
We also maintain standard physical and electronic procedural safeguards that limit access to your personally identifiable information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, need to access your personally identifiable information.
7.4. SHARING AND DISCLOSURE OF PERSONAL DATA
We use service providers to provide certain services to us, such as credit card processing, analytics tools, DNS providers, data management services, Web hosting, and Web development. We provide our service providers with only the information necessary for them to perform these services for the purpose of performance of our contractual obligations or for measures in preparation for such a contract with you upon request in accordance with Art. 6 (1) b GDPR.
We may share information we collect with our affiliates. If the Company is merged, sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer information we collect in connection with such a transaction on the basis of our prevailing legitimate interests in participating in cooperating with our affiliates or being subject to such transactions in accordance with Art. 6 (1) f GDPR.
We may disclose information about you to third parties if (a) that disclosure is necessary to comply with any applicable law, regulation, legal process, or governmental request (Art. 6 (1) GDPR), (b) to enforce our agreements, policies, and terms of service (Art. 6 (1) f GDPR), (c) to protect the security or integrity of our Services (Art. 6 (1) lit. f GDPR), (d) to protect the property, rights, and safety of us, our customers, or the public from harm or illegal activities (Art. 6 (1) f GDPR), (e) to respond in an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person (Art. 6 (1) d GDPR), or (f) to investigate and defend ourselves against any third-party claims or allegations (Art. 6 para. 1 lit. f GDPR).
7.5. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
7.5.1. You may review, correct, update, or change your account registration information by accessing your settings in your user profile on the Site or by contacting our DPO at [email protected].
7.5.2.4. Receive a copy of your personal data, request your personal data be transferred (“right to data portability”).
7.5.3. In addition, you may object to any processing of your personal data, where such processing is legally based on our prevailing legitimate interests in accordance with Art. 6 (1) f GDPR by contacting our DPO at [email protected] or through any other contact provided under section 9 below and providing personal reasons why such processing should be discontinued. We will comply with your objection unless we can demonstrate prevailing legitimate interests in continuing to process your personal data, including the necessity of using your personal data for protecting legal claims or defending against such.
7.5.4. Without regard to the foregoing, you may object to any processing of your personal data for advertising purposes without having to provide any reasons by contacting our DPO at [email protected] or through any other contact provided in the Policy.
7.5.5. You may opt out of receiving promotional email communications from us by using the unsubscribe link included within each email. Even after you opt out from receiving promotional messages from us, you will continue to receive such messages from us regarding our products and services.
7.5.2. With regard to any personal data processed by us in accordance with this privacy policy, you are by law entitled to:
7.5.2.1. Access your personal data processed by us;
7.5.2.2. Have your personal data rectified or erased (“right to be forgotten”);
7.5.2.3. Have the processing of your personal data restricted, effectively barring further access;
9. Call recording
NeoImpact Pvt. Ltd. records all outgoing and incoming calls for training & development purposes and for effective client requirement assessment only. All recordings are kept highly confidential. In case you wish us to delete the call recordings or not record calls at all, please notify us via an email or while on a phone call with any representative of NeoImpact Pvt. Ltd.
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