PRIVACY POLICY
Privacy pledge
We believe privacy is a fundamental right of every individual. Every person should have the freedom to choose what they wish to share and who they wish to share their personal information with. We, at India Assist value the trust you put in us and assure that we will protect your privacy. We pledge to never share your personal information with any third party entity for unsolicited purposes.
Your personal information is safe with us.
1. INTRODUCTION
1.1. India Assist Insights Pvt. Ltd (“We”, “Our”, “India Assist” or the “ Company”) is a company registered under the Indian Companies Act, 2013. The Company seeks to facilitate Foreign Tourist Arrivals (“FTAs”) into India as a first point of contact and provide assistance through its mobile application called ‘India Assist’ (the “App”) by connecting the user with the correct solution. This facility of the Company is aimed at bridging the information gap between FTAs and local resources and seeks to help FTAs reach solutions faster, using various tools (the “Services”). India Assist uses third party service providers in rendering assistance (“ Third Parties”) to Users. Any person who wishes to procure the Services (the “User”, “Your” or “ You”) may access our App and, subject to submission of the required documents, fulfilment of certain criteria discussed in this Policy and Terms of Use and provision of information which may include Personal Information (defined below) of the User. For avoidance of doubt, this Privacy Policy shall apply to all Subscribers of the App as well.
1.2. This Privacy Policy is to serve as a testament to our sincere efforts to uphold privacy laws. The protection and security of Your Personal Information and Usage Information (as defined below) is one of our top priorities. This Privacy Policy discloses and explains how we collect, use, share and protect Personal Information, Usage Information or any other information about You. We also provide information regarding how You can access and update Your Personal Information and make certain choices about how Your Personal Information is used by us. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources.
1.3. This Privacy Policy explains what information of yours will be collected by India Assist when You access the App, how the information will be used, and how You can control the collection, correction and/or deletion of information. We will not use or share Your information with anyone except as described in this Privacy Policy. The use of information collected through our App shall be limited to the purposes under this Privacy Policy, as may be amended from time to time.
1.4. Capitalised words used in this Privacy Policy but not defined herein, shall have the same meaning as ascribed to such terms in the Terms of Use of India Assist available athttps://indiaassist.com/terms
2. INFORMATION COLLECTION BY THE COMPANY
2.1. Data Controller and Data Processor:
India Assist controls, collects, owns and directs the use of the Personal Information and Usage Information on its App and India Assist is the data controller and data processor as regards the Personal Information and Usage Information collected on its App as per applicable law. Even though India Assist is not obligated to, this Policy is also in compliance with the European Union General Data Protection Regulation (Regulation 2016/679). For any queries regarding this Privacy Policy and the collection and use of data collected or processed under this Privacy Policy, India Assist can be contacted by mail at Asset One, G1, Hyatt Andaz Residences, Aerocity, New Delhi India, 110037 ; by phone at +91-9811664898 or by e-mail atinfo@indiaassist.com
2.2. Legal basis for collection and processing of Personal/Usage Information:
The legal basis for collection and processing of any information collected and processed by India Assist including the Personal Information is (i) Your consent at the time of providing the Personal Information; (ii) where it is in our legitimate interests to do so and not overridden by Your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to Your communications, the operation of networks of groups by the network administrators, and improving our App). In some cases, we may also have a legal obligation to collect information about You, or may otherwise need the information to protect Your vital interests or those of another person. We may also process information to comply with a legal requirement or to perform a contract.
2.3. Basic Information
2.3.1. Personal Information: “ Personal Information” is Information collected that can be used to uniquely identify or contact You. Personal Information for the purposes of this Privacy Policy shall include, but not be limited to:
a) Your user name along with Your password,
b) Your name, address, date of birth, gender, contact details, country of origin, travel itinerary and those of Your co-travelers,
c) Information regarding Your transactions on the App, (including purchase history),
d) Your financial information such as bank account information or credit card or debit card or other payment instrument details including OTP,
e) Internet Protocol address,
f) Any other items of ‘sensitive personal data or information' as such term is defined under the Information Technology (Reasonable Security Practices And Procedures And Sensitive Personal Data Of Information) Rules, 2011 enacted under the Information Technology Act, 2000;
g) Identification code of Your communication device which You use to access the App or otherwise deal with India Assist,
h) Any other Information that You provide during Your registration process, if any, on the App.
2.3.2. Such Personal Information may be collected in various ways including during the course of You:
(i) registering as a user on the App,
(ii) availing Services offered on the App. Such instances include but are not limited to online purchase, communicating with India Assist's customer service by phone, email or otherwise or posting user reviews on the App, or
(iii) otherwise using the App or otherwise dealing with India Assist. We may receive Personal Information about You from third parties, such as social media services, commercially available sources and business partners. If You access App through a social media service or connect a service on App to a social media service, the information we collect may include Your user name associated with that social media service, any information or content the social media service has the right to share with us, such as Your profile picture, email address or friends list, and any information You have made public in connection with that social media service. When You access the App or otherwise deal with India Assist through social media services or when You connect any App to social media services, You are authorizing India Assist to collect, store, and use and retain such information and content in accordance with this Privacy Policy.
2.4. Additional Information
India Assist may also collect information other than Personal Information from You through the App when You visit and / or use the App. Such information may be stored in server logs. Such information would not assist India Assist to identify You personally. This information may include:
2.4.1. Cookies: India Assist may use standard “cookie” browser application feature to collect and understand website usability trends. Cookies are text files that we may place in Your computer browser to store Your preferences. Cookies are used to record various aspects of Your visit and assist us in providing You with uninterrupted service. One of the primary purposes of cookies is to store Your preferences and other information on Your Device in order to save You time by eliminating the need to repeatedly enter the same information and to display You personalized content. The user may change browser settings to accept or reject cookies on personal preference. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but You can usually modify the browser setting to decline cookies if You so prefer. If You choose to decline cookies, You may not be able to sign in or use other interactive features of the App that may depend on cookies. If You choose to accept cookies, You also have the ability to later delete cookies that You have accepted. If You choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated. [We process and keep all data for our own use and, if You wish to opt-out from tracking by India Assist You can do so by writing to us atinfo@indiaassist.com]
2.4.2. Information Collected Automatically: In addition to any Personal Information or other information that You choose to submit to us, we may use a variety of technologies that automatically (or passively) collect certain information whenever You access the App and/or our website (“Usage Information”). This Usage Information may include the URL that referred You to our App, Your geographic location, the operating system of the device, among other information. Usage Information may be non-identifying or may be associated with You, details of Your telecom service provider or internet service provider. Whenever we associate Usage Information with Your Personal Information, we will treat it as Personal Information and the conditions relating to Personal Information under this Privacy Policy will be followed. Traffic data, while anonymous, is gathered and analysed for business needs.
2.4.3. Information Third Parties Provide About You: We may, from time to time, supplement the information we collect about You through our App and/or website with outside records from third parties obtained rightfully in order to enhance our ability to serve You, to tailor our content to You and to offer You opportunities to use such of our Services that we believe may be of interest to You. We may combine the information we receive from such third party sources with information we collect through the App or through independent research conducted by India Assist, with Your consent. In these cases, we will apply this Privacy Policy to any Personal Information received, unless otherwise provided. We may process such information received from third parties for the legitimate commercial purposes or to enter into contractual obligations with You or to fulfil certain contractual obligations or where You have requested third parties to provide information about yourself to us.]
2.4.4. Ads: India Assist may use third-party service providers to serve ads on India Assist's behalf across the internet and sometimes on the App. They may collect non Personal Information about Your visits to the App, and Your interaction with our Services on the App. Please do note that Personal Information and non Personal Information may be treated differently as per this Privacy Policy.]
2.5. Processing of Data:
India Assist may also process any Personal Information or Usage Information collected from You for legitimate commercial purposes including to provide You with the requisite information requested. A list of uses of the Personal Information and Usage Information collected is provided at Section 3 of this Policy (Use of Information Collected).
India Assist implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals such as (i) only sharing and providing access to Your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible; (ii) using secure servers to store Your information; (iii) verifying the identity of any individual who requests access to information prior to granting them access to information; and (iv) using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions You make on or via our App.
2.6. Right of a User in relation to data submitted:
Any User who has submitted Personal Information on the App has the right to (i) access, correct, delete such Personal Information subject to us successfully verifying Your identity; (ii) object to us processing Your Personal Information on legitimate grounds; (iii) to withdraw Your consent to our use of Your information at any time where we rely on Your consent to use or process that information; (iv) opting out of receiving any promotional or marketing material by clicking on the “Unsubscribe” button or by sending an email to info@indiaassist.com ; (v) right to have the Personal Information transferred to another data controller; and (vi) lodge a complaint with a supervisory authority. Any request received by us by the user in relation to the aforesaid shall be acknowledged by us within Thirty-Six hours (36) hours. Please note that if You withdraw Your consent, this will not affect the lawfulness of our use and processing of Your information on the basis of Your consent before the point in time when You withdraw Your consent.
3. USE OF INFORMATION COLLECTED
3.1. Business Purposes:
India Assist does not share any Personal Information with any third party without Your consent, except when directed by the law. India Assist can use this data to verify user identity in line with engagement initiated by the user. [We will communicate with You using the contact information provided by You in order to respond to any queries that You may have and to provide information in relation to the Services. We may communicate with You either by written, physical communication, email, telephone, SMS or via notifications on Your Device]. We may also send service-related announcements to You periodically and when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send You an email, text message, flash notification or telephone call. If You do not wish to receive such alerts, You have the option to unsubscribe from such emails or opt out by sending an email to info@indiaassist.com . However, by opting out of such communication, you agree and acknowledge that the Services may be affected to the extent that India Assist may not be able to provide you the Service or may severely affect the quality of Service.
We may use Personal Information or Usage Information collected through the App in the following ways:
(i) To help You address Distress;
(ii) To remember the basic information provided by You for effective access;
(iii) To confirm Your identity in order to determine Your eligibility to use the App and avail the Services;
(iv) To operate and improve our App and tools associated with the App;
(v) To create aggregated and anonymized information to determine which App features are most popular and useful to users, and for other statistical analyses;
(vi) To reinforce, prevent, discover and investigate violations of this Privacy Policy or the Terms of Use, and to investigate fraud or other matters;
(vii) To customize the content or the Services on the App for You, or the communications sent to You through the App.
(viii) To help provide You the Services;
(ix) To observe, improve and administer the quality of Service;
(x) To provide You with information about Services available on the App and to send You information, materials, and offers from India Assist;
(xi) To send You important information regarding the App, changes in Terms of Use, user agreements, policies and/or other administrative information, Service related alerts and other similar communication with a view to optimizing the efficiency of the App;
(xii) To analyze how the App is used, diagnose technical problems;
(xiii) To notify You about any changes to the App;
(xiv) To enable India Assist to comply with its legal and regulatory obligations;
(xv) Doing market research, troubleshooting, protection against error, project planning, fraud and other criminal activity;
(xvi) To conduct internal reviews and data analysis for the App;
(xvii) To facilitate seamless purchase experience while making a transaction by pre-populating the OTP received through SMS/ email by you;
(xviii) To facilitate various programmes and initiatives launched by India Assist or third party service providers and business associates;
(xix) To undertake forensics of the concerned computer resource as a part of investigation or internal audit; and
(xx) To trace computer resources or any person who may have contravened, or is suspected of having or being likely to contravene, any provision of law including the Information Technology Act, 2000 that is likely to have an adverse impact on the services provided on any app or by India Assist.
3.2. No trade:
We do not sell, share, rent or trade the information we have collected about You, including Personal Information, other than as disclosed within this Privacy Policy or at the time You provide Your information. We do not share Your Personal Information with third parties for those third parties’ direct marketing purposes unless You consent to such sharing at the time You provide Your Personal Information.
3.3. Administrative and Legal Reasons:
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose Your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of India Assist, our Services, the App or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without notice to You.
3.4. Business Transfer:
We may share Your information, including Your Personal Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the App or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process. You will be notified via email and/or a prominent notice on our App of any change in ownership or uses of Your personal information, as well as any choices You may have regarding Your Personal Information. We will endeavor that the transferee who is the recipient of Personal Information and Usage Information commits to privacy measures which are substantially similar to the measures under this Privacy Policy.
4. THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES
We do not include or offer third party products or services on our website.
5. DATA TRANSFER
Your information may be stored and processed in India or any other country in which India Assist or its subsidiaries, affiliates or service providers maintain facilities. India Assist may transfer information that we collect about You, including Personal Information, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. These countries may have data protection laws that are different to the laws of Your country and, in some cases, may not be as protective. We shall take appropriate safeguards to require that Your information will remain protected in accordance with this Privacy Policy.
6. DATA RETENTION
7. SECURITY
[This website, in compliance with PCI – DSS norms, has a number of security measures to ensure there is no loss, misuse or illegal alteration of information collected from its users.] Personal Information and Usage Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting Your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information You supply won't be intercepted while being transmitted to us over the Internet or wireless communication and any information You transmit to India Assist You do at Your own risk. If, despite our best efforts, an unauthorised breach of our security measures occurs, resulting in the unauthorised access, duplication, removal or alteration of any Personal Information, third party information, or Usage Information, India Assist, its directors, officers, employees, promoters, or affiliates will not be held responsible for any loss resulting from such breach.
8. COMPROMISE OF PERSONAL INFORMATION
In the event that personal information is compromised as a breach of security, India Assist will notify the supervisory authority in compliance with applicable law, within 72 hours of the breach coming to its notice.
9. CONTACT & POLICY UPDATES, CHANGES TO THE PRIVACY POLICY
9.1. In case on any queries on this Privacy Policy, please contact us at info@indiaassist.com . India Assist reserves the right to update or modify any part of this policy or make any changes without prior notice to the user. The user is advised to check this page periodically to stay abreast of any policy changes by us.
9.2. Any changes in this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on the App. If we make any material changes, we will notify You by email (sent to the e-mail address specified in Your account) or by means of a notice on the App prior to the change becoming effective. We encourage You to periodically review this page for the latest information on our privacy practices.
10. CHANGE OF INFORMATION AND CANCELLATION OF ACCOUNT
You are responsible for maintaining the accuracy of the information You submit to us, such as Your contact information provided as part of account registration. If Your Personal Information changes, or if You no longer desire to access the App, You may correct, delete inaccuracies, or amend information by contacting us through info@indiaassist.com and we will respond within 48 hours of receipt of communication.
You have the right to request that we rectify or delete the personal data or restrict the processing of Your personal data, if You think they are inaccurate. Furthermore, You have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on Your request. Additionally, You also have the right to data portability if it should become relevant. You have a right to lodge a complaint with Your local supervisory authority.
[You may also cancel or modify Your communications that You have elected to receive from the App by logging into Your user account and changing Your communication preferences.
If You wish to cancel Your account or request that we no longer use Your information to provide You details with respect to our Services and the App, please write to us at info@indiaassist.com
11. OPT IN
11.1. If You wish to opt for receiving non-essential communications such as promotional and marketing-related information regarding the App and the Services, please send India Assist an email at info@indiaassist.com
12. GRIEVANCE REDRESSAL
12.1. If You have any questions or concerns about this Privacy Policy, please feel free to contact us by writing to us at:
Ms. Moqierish Tak, the designated grievance officer under Information
Technology Act, 2000
E-mail: mt@indiaassist.com
or using the details provided on our ‘Contact Us’ page. We will use reasonable efforts to respond promptly to requests, questions or concerns You may have regarding our use of personal information about You. Except where required by law, India Assist cannot ensure a response to questions or comments regarding topics unrelated to this policy or Company’s privacy practices.
12.2. The details of the grievance officer may be changed by us from time to time by updating this Privacy Policy.
13. CONSENT
By consenting to the terms under this Privacy Policy, You are expressly granting India Assist the right to collect, share, transfer, store, retain, disseminate or use the Personal Information/Usage Information collected by India Assist from Your usage of the App in accordance with the terms of the Privacy Policy.
14. FURTHER ACKNOWLEDGEMENTS
14.1. You hereby acknowledge and agree that this Privacy Policy:
a) is clear and easily accessible and provide statements of India Assist policies and practices with respective to the Information;
b) provides for the various types of personal or sensitive personal data of information to be collected;
c) provides for the purposes of collection and usage of the Information;
d) provides for disclosure of Information; and
e) provides for reasonable security practices and procedures.