Introduction

This Privacy Policy for Partner App (the “App”) describes the types of information, including but not limited to personal data, we may collect from you or that you may provide when you interact with us, use our application, and/or related products or services, including any subdomains and any content, functionality and services offered on, by or through it or them, or any other websites, e-mails, applications that link to this Privacy Policy (collectively referred to as “Services”), all of them provided by Aditya Infotech Ltd (“CP Plus”, “Aditya”, “we” ,”us” or “our”), acting as a data controller. This Privacy Policy also describes how we collect, use, maintain, share, protect, disclose or otherwise process that information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

“Personal Data” as in this Privacy Policy shall mean any information that identifies you or can, identify you directly or indirectly, in particular if in combination with another identifier of you.

This privacy Policy includes the following contents:

  1. Information We Collect About You and How We Collect it
  2. Children under the Age of 16
  3. How we use your information
  4. Information sharing
  5. Data Security Measures
  6. International Transfers
  7. Your Rights
  8. Changes to our Privacy Policy
  9. Contact

  1. Information We Collect About You and How We Collect it

    We collect several types of personal information from and about you that is necessary to provide our services to you. We also collect information that is about you, but individually does not identify you, such as demographic data, and information about your internet connection, the equipment you use to access our Services & usage details. You have the right to choose whether or not to provide the information we have requested. However, in some cases, we may not be able to provide you with our Services or reply if you do not provide your personal information.

    Including information that identifies you personally, such as name, postal address, e-mail address, telephone number, profile photo, job position, geographical location(“personal data”).

    1. Information you provide to Us

      • The information we collect on or through our Services may include:

        Information that you provide at the time of registering for use of or access to our Services

        We collect Contact details such as your name, postal address, telephone number, e-mail address, profile photo, job position when you sign up with the App.

      • Information that you provide when you use certain features of our Services

        You may provide your name, telephone number, postal address or other needed information if you enter into promotional activities or you engage with our marketing or win a prize or redeem a gift.

    2. Information that we collect in your use of our Service

      • Location Information and Browser language standard

        You may provide your geographical location to allow us to communicate with you and inform you about the progress and result (if applicable) of the marketing activity you have opted in for and display the products information of the district you locate.

      • Information for password reset

        You may provide your telephone number and e-mail address when you would like to reset your password.

  2. Children under the age of 16

    Our App are not generally targeted at children under 16 years of age. No one under age 16 should provide any personal data to or on our Services. We do not knowingly collect personal data from children under 16.

    CP Plus strongly recommends that parents take an active role in supervising the online activities of their children. If you believe we might have any information from or about a child under 16, please contact us at care@adityagroup.com

  3. How We Use Your Information

    We use information that we collect about you or that you provide to us, including any personal data for the following main purposes:

    1. To provide our Services to you

      We process a username & password when you register at the App to have access to the Services such as training courses, access to marketing materials of products you have purchased from us, and the prize or gift you want to redeem. In addition to the account details, we also use this data to send you invitations to our marketing activities for which you have registered your interest via our App.

    2. To communicate with you

      We use your contact details to communicate with you, provide you with information you request about us, answer your questions or when we handle your complaints.

    3. For statistical research

      General, we use automatic tools to perform statistical research into general trends regarding the use of our services, apps and social media and the behaviour and preferences of our customers sand users. We also send periodically enquiries to our customers and prospects to gain insight in their opinions and preferences.

      Data To perform our research, we may merge and analyze the different types of data as described above. We may also combine such aggregated data with information we receive from our group companies or from market research. Without your consent we will not use sensitive data for this statistical research.

      Interests and benefits Statistical research helps us to develop better services and offerings, to provide more responsive customer support and to improve the design and content of our App and products.

    4. For direct marketing

      General We may use your personal information to send you newsletters, promotions or other marketing communications, including invitations to our exhibitions.

      Categories of data. To understand what is relevant for you we may use automatic tools to analyze your personal information. For this purpose, we may use & combine the information described above. We may also combine such data with information we receive from our group companies or from other sources, such as market research or public information. Without your consent we will not use sensitive data for statistical research.

      Interest & benefits. We use the results of our analysis to tailor our marketing communications to your (and the company you represent), specific interests and preferences. For example, if we notice that you work in a specific sector, such as banking, we may customize our offers, invitations to exhibitions and newsletters to this sector.

      Channels. We use different channels for our marketing communications, such as e-mail, apps, social media and your personal online account.

      Object or revoke. You may object or revoke your consent for receiving marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us sales@cpplusworld.com

    To comply with statutory obligations

    We may be required by law to collect and share your identifying information & personal data with public or governmental organizations for the purpose of compliance with the law, a court order, or to respond to any government or regulatory request.

    We only use “Aggregated” or “De-identified” information to:

    1. Understand users preferences.
    2. Enhance & optimize users experience.
    3. Improve the functional design to better support the users.
    4. Provide better customer care and customer service.
    5. Pather analytical data.

    We process your personal data on the basis of the following legal grounds: on the basis of your consent, for the performance of a contract with you, to comply with legal obligations we are subject to and on the basis of our legitimate interests or the interest of a third party as described in this policy. When we process your personal data for our legitimate interests or the interests of a third party, we will take reasonable measures to prevent unwarranted harm to you. Our legitimate interests may for example be improving our newsletters and App by analysing which parts of our communications are most relevant for persons interested in our activities or securing our App and facilities. For more information on these interests, please contact us to understand the purposes for which we process your personal data (see below).

  4. Information Sharing

    We may disclose your personal data with certain trusted third parties that perform business functions for us or provide services to us, being our subsidiaries and affiliates; or contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.

    The main purposes of sharing are:

    • To deliver your orders and provide you the services requested from us

      To deliver you the products you order & the services you request such as redeeming gift & other marketing activities, we may share your personal data with our group companies, and other companies involved in facilitating you with services. For more information about our group companies, please visit our website under About Us or feel free to contact us.

    • For statistical research and direct marketing

      We may share your personal data within our group for the purpose of statistical research and direct marketing.

    • To let you benefit special offers of partners of CP Plus

      We may share your personal information with our partners to let you benefit from the services of these partners that we integrate or offer in our own services and apps. For example, when we cooperate with resellers or when we offer services via the DHOP platform or when we organize or participate in exhibitions & other marketing events organized by third parties, either in their entirely or in cooperation with us.

      All such third parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws.

      We may also disclose your personal data:

      • To comply with any court order, law, or legal process, including to respond to any government or regulatory request or for investigations (e.g., disclosure to prevent crime or fraud, or to comply with a court order or legislation).
      • If we believe disclosure is necessary or appropriate to protect the legitimate rights, property, or safety of CP Plus, our customers or others.
  5. Data Security Measures

    We have implemented appropriate technical and organizational measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a username and password for access to certain parts of the Site, you are responsible for keeping these credentials confidential. We ask you not to share your credentials with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site. We periodically review the technologies used and policies implemented for securing the collected information.

    Your personal data will be retained for as long as required for the purposes described in this Privacy Policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  6. International Transfers

    We offer our Services through the use of servers located in different countries. As such, your information might be transferred outside the region and country you use our Site and Services, including to regions/countries outside the European Economic Area ("EEA") which might have different legal rules and might not offer an adequate level of protection as determined by the European Commission. However, we have taken the necessary measures to ensure that your information is processed in conformity with the applicable laws and appropriate technical security measures are adopted to safeguard your privacy. Where necessary we use Standard Contractual Clauses, which are approved by the European Commission to comply with applicable legislation.

  7. Your Rights

    You can review and change your personal data by logging into your account on our App. If you are not able to find your personal data you may also send us an e-mail at sales@cpplusworld.com to request access to or require us to correct or delete any personal data that you have provided to us. You may also object to or request us to restrict your processing. If we process your personal data based on consent, you may withdraw your consent at any time by contacting us (see below). A summary of your legal rights is set out below:

    1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
      • If you want us to establish the data’s accuracy.
      • Where our use of the data is unlawful but you do not want us to erase it. or
      • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
      • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
    6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
    8. For any security reasons, we will take steps to authenticate your identify before providing access to your personal data. You also have the right to lodge a complaint with the relevant Data Protection Authority.
  8. Changes to Our Privacy Policy

    We keep this Privacy Policy under review and modify this Privacy Policy from time to time. We will inform you for any modifications on the Privacy Policy. We will also provide a notice of the modifications on the homepage for a short period. The date the Privacy Policy was last revised is identified at the top of the page.

  9. Contact Information

    To ask questions or comment on this Privacy Policy or our privacy practices, please contact our Data Protection Officer through email at care@adityagroup.com, or by mail at:

    Aditya Infotech Ltd

    A-12. Khemka Square

    Sector – 4,

    Noida - 201301