Privacy Policy

Introduction

This Privacy Policy shall be read in conjunction and together with the Terms of Use available on [.]. Capitalized terms not defined herein shall have the meaning attributed to them under the Terms of Use.

Courtly Technologies Private Limited (“Company”, “We”, “Us” or “Our”) respects the privacy of our users (“User”, “You” or “Your”) and has made this Privacy Policy to ensure protection of the same. This Privacy Policy is intended to for a User. Personal Information of a User(s) is required by the Company to enable him to register with the Website, so they can accesses the Website or uses or accesses the Services as described in the Terms of Use. The terms "Personal Information" and "Sensitive Personal Data or Information" shall have the meaning ascribed to it under the applicable laws of India. Your use of our services offered on the Website construes to mean that You consent to our collection, storage, processing and transfer of your Personal Information or Sensitive Personal Data or Information in accordance with this Privacy Policy and you consent to the Terms of Use of this Privacy Policy.

If You do not agree with any or all of the terms of this Privacy Policy, please do not provide any information to Us. If at any time You wish to discontinue Your access of the Service, You are free to do so.

SENSITIVE PERSONAL DATA OR INFORMATION

The Company will never ask you and you must never give your sensitive personal data or information to the Company or to any person/entity representing the Company. Disclosure of any sensitive personal data or information shall be at your sole risk and the company or its affiliates including its directors, key managerial personnel, officers and employees shall have no liability towards the same. You understand, acknowledge and agree that the company or any other person acting on behalf of the Company shall not in any manner be responsible for the authenticity of the personal information or sensitive personal data or information provided by You to the Company. The Company will never ask You and You must not disclose Your:

i. passwords;

ii. financial information such as bank account details, credit card details, debit card details, secure pin number, passwords, etc.;

iii. physical, physiological and mental health condition;

iv. sexual orientation;

v. medical records and history;

vi. biometric information;

vii. national identification numbers;

viii. and such other sensitive personal data or information.

Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of these rules.

Personal Information and its Use

The primary purpose of collection of Personal Information is to allow You to access and use the Service and various features on or in relation to the Service provided by the Company. We may collect the following as part of the Personal Information required to register You as a User and to provide you access to the Services.

i. Your registration details which may include your Name, Email Address, Mobile/contact details, Age, Gender, Password, Location, Pin Code, Area code, Occupation etc;

ii. Information that You submit to any Third-Party Service You access from links contained within the Service. You should check the privacy policy of such Third-Party Websites to find out how they will use Your personal information and sensitive personal data or information. The Company shall not be responsible or liable for use or misuse of the same by Third-Party Websites;

iii. If you access or engage with the website or services associated with the website through a social media service, we may collect your user id or user name, any information you have permitted the social media service to share with Us, and any information you have made public with the social media service. You undertake to comply to the Terms of Use including the Privacy Policy  and any additional Terms of Use stipulated by such social media platforms. In the event of any inconsistency, the Terms of Use including the Privacy Policy shall prevail to the extent of conflict;

iv. Details of the computer system or computer network which you use to visit the website and undertake any activity on the website, such as a unique device identifier including user behavior from web based cookies, session identifiers from device id, commercially available services, data aggregator platforms;

v. IP Address, Operating System, Browser Type, Browser Version, Browser Configuration, Name of Internet Service Provider, and other types of computer and connection related information relevant to identifying Your type of device, connecting to the website, enabling data exchange with You and Your Device, and ensuring a convenient use of the website;

vi. The uniform resource locator (URL) and IP address of the website from which You accessed, or were directed to, our website, including date and time;

vii. Subpages visited while on our website, links followed on the website, including date and time;

viii. The full URL click stream to, through and from the website, including date and time;

ix. Search terms entered;

x. Information collected by cookies or similar technologies (as described in the next paragraph);

xi. Newsletter subscriptions, enrollment for promotions, use of special offers, etc.;

xii. Consents, authorizations, etc. Granted;

xiii. Survey answers, reviews, ratings and other types of feedback provided;

xiv. Content of any communication sent through the website, including any information posted in social communities on the website or otherwise shared with platform and/or other users, as well as chat messages and chat transcripts;

xv. Any other information that you enter on, or upload to, the website (e.g., content that you fill into an online form, a photo that you upload);

xvi. If You choose to buy on the Website, we collect information about your buying behavior. If You transact with Us, We collect some additional information, such as a billing address, a credit / debit card number and a credit / debit card expiration date and/ or other payment instrument details and tracking information from cheques or money orders;

xvii. If You choose to post messages on our message boards, chat rooms or other message areas or leave feedback, We will collect that information You provide to Us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law;

xviii. We use Personal Information to provide the services you request. To the extent we use your Personal Information to market to you, we will provide you the ability to opt-out of such uses. We use your Personal Information to resolve disputes; troubleshoot problems; help promote a safe service; collect money; measure consumer interest in our services, inform You about online and offline offers, products, services, and updates; customize Your experience; detect and protect Us against error, fraud and other criminal activity; enforce our Terms of Use; and as otherwise described to you at the time of collection;

xix. Your personal information collected from Tracking Technologies may be used to aggregate it with information collected from other Users using the Service to attempt to provide a better experience on the Service. You understand, agree and acknowledge that Our collection, storage and processing of Your personal information is for a lawful purpose connected with the functioning of the Service. You hereby consent to the collection, storage, use, disclosure, transfer, processing of the personal information for the purposes set out herein;

xx. We may use Your Personal Information to send You feedback forms, offers, rating forms etc. If You no longer wish to receive such communications from the Platform Entities , please follow the unsubscribe instructions provided in any of the communications. Please note that once we receive Your request, it may take an additional period of time for Your request to be initiated.

Cookies and Web beacons

This Personal Information is collected through the use of server log files and tracking technologies to collect and analyze certain types of technical information and may include cookies and web beacons. If You do not consent to the use of cookies and/or device session tracking by the Platform, You may at any time adjust Your browser settings and/or delete and/or disable the cookies. However, please note that should You choose to delete/ disable the use of cookies or other tracking technologies on Your computer, certain sections of the Website and/or Services provided by the Platform may not be available to You.

Disclosure of Information

We may disclose your Personal Information to any third-party service provider to whom disclosure is necessary to enable Us to provide You with the services which You wish to access on or through the Service. We may further disclose such Personal Information to any third-party service provider to whom disclosure is necessary to enable Us to provide You with the gratification as a result of You participating in any contest, promotional or marketing activity organized by the Company. We may disclose Your Personal Information to Our joint ventures, business partners, agents or third parties for the purposes of the services provided by them or for any other marketing related activity undertaken by or on behalf of the Platform Entities and/or its joint ventures, and/or for the purposes of enhancing the quality of the services provided to You on the Website, and You expressly consent to the same.

We may further disclose Your Personal Information to:

i. any person/entity to whom disclosure is necessary in accordance with applicable law;

ii. any government or statutory authority or court of law or judicial forum to whom disclosure is necessary in accordance with applicable law;

iii. in circumstances We believe necessary or appropriate to respond to valid claims and legal process, to protect the property and rights of the Company, to protect the safety of the public or any person or User, or to prevent or stop any illegal, unethical or legally actionable activity;

iv. any person/entity to whom disclosure is necessary to enable Us to enforce Our rights.

We shall have the right to will also disclose Your Personal Information to government and law enforcement agencies 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 the Company 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. We may also provide Your Personal Information various statutory authorities including tax authorities upon any demand or request from them.

Service-related Announcements

We will send You strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if Our service is temporarily suspended for maintenance, We might send You an email advising You of this.

Third Party Websites

There are a number of places on our website or through our services where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on Our website, You may be taken to a website that We do not control. These third-party websites may independently solicit and collect information, including personal information, from You and, in some instances, provide Us with information about Your activities on those websites. We recommend that You consult the privacy statements of all third-party websites You visit by clicking on the "privacy" link typically located at the bottom of the webpage You are visiting.

Security of Your Personal Information

We use commercially reasonable security practices and procedures industry practices and procedures designed to help keep Your Personal Information or Sensitive Personal Data or Information safe We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. In addition, we use firewalls to help prevent unauthorized persons from gaining access to your personal information. We strive to protect your personal data against potential risks and exposures, though there is no absolute security in the online/ internet sphere. Therefore, you must not disclose any information on the service that is sensitive personal data or information. You understand that the transmission of information over the internet is not completely secure and there are risks associated with it. Although we strive to protect your personal information, we cannot guarantee the security of the same while it is being transmitted to our service and any transmission is at your own risk.

Storage of Personal Information

We retain Personal Information for as long as We believe it to be necessary for purposes set out herein for which the Personal Information was collected, subject to any legal requirements for the data to be retained for longer periods of time.

Visiting Our Websites from Outside India

This Privacy Policy is intended to cover collection of information on or via our website from residents of India. If you are visiting our website from outside the India, please be aware that your information may be transferred to, stored, and processed in India where our servers are located and our central database is operated. The data protection and other laws of the India and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, you understand that your information may be shared as per terms of the Privacy Policy.

Compliance with GDPR and CCPA

Our Company is committed to protecting Your Personal Data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). If You are located in the European Economic Area (EEA), we process Your personal data in compliance with GDPR principles such as transparency, lawfulness, and purpose limitation. Similarly, if You are a California resident, You have rights under the CCPA, including the right to access, delete, and opt-out of the sale of Your Personal Information. We ensure that Your rights are respected, and we have implemented appropriate measures to safeguard Your information.

Modification

We reserve the right, at Our sole discretion, to change, modify or otherwise alter this Privacy Policy at any time without prior notice. Such changes and/or modifications shall become effective immediately upon being posted/published on the Service herein. Your continued use of the Service following the posting of changes and/or modifications will constitute Your acceptance of any revised Privacy Policy. We retain the right at any time to deny or suspend access to all or part of the Service to anyone who We believe has violated any condition of this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy or the practices of Platform or Your dealings with the Website, You can contact Us at www.[•].com or you can write and send a letter to us at the below address: