Your privacy is critically important to us.
Effective Date: July 1, 2023.
Who are we?
PERSONAL DATA WHICH IS COLLECTED
We collect and process the following data from You/Users, including but not limited to:
- Name, email, address, mobile number, gender, etc. at the time of registering with our Website and/or while creating a User account, while filling questionnaires or forms, or when You subscribe to the Company’s updates by email and/or upload or submit any material or content while using the Services/platform and/or the Witrame’s website.
- Log-in/User details and password details during the User account sign-in/registration/change password etc. processes.
- Financial details regarding the subscriptions available on the platform/website.
- Your data on social media (say Facebook profile data) if You choose to log in through Facebook or other social media.
- All communications and emails and other correspondence between You and Us.
- The entire range of material or content You post on the Platform/Website.
- Your IP address(es), browser, and Operating System specifications include mobile browser and operating systems.
HOW YOUR PERSONAL DATA MAY BE USED?
We collect the data only for legitimate purposes for providing You access to the Website and for the usage of the Services through the Platform.
Your information shall be used for:
- Verification of identity at the time of signing into Your User account.
- Analyzing, and providing You with any statistical data on User account activity.
- Analyzing internet service providers’ user, visitor, and domain name data won’t involve any personal information at this event.
- Contacting You for queries posted on the Platform or contacting You in any regard.
- Used for other purposes that We may disclose to You when We request your information.
We do not use any of Your personally identifiable information for any other purpose than granting You access to Your User account or the Services and/or the Website. All Your payment (s) made through the partner payment gateway is/are secure.
If You choose to log in or sign up with Our Services through any social media like Facebook, etc. We request permission to access Your profile and seek appropriate permissions from You wherever required.
We may use Your contact information for marketing and promotional purposes about any prospective Service(s) of WItrame; however, if You decide and write to Us that We should refrain from using Your data/information with respect to any marketing or promotional purposes, We will honor Your decision. If You do not write to Us to let Us know of any objections to the use of the data/information, it shall signify that You have accorded us permission for such use of the data/information under the law.
Whichever way We use and process, please note that Your personal information shared by You is safe and We use and process any information under the applicable laws and on Your consent for such processing for lawful purposes and for providing You the Service(s) and access to the Platform/Witrame Website. Your creation of the User account and login every time You use Our Services and/or the Platform amounts to such valid consent.
Disclosure of your Information
In the event of a corporate sale, merger, reorganization, dissolution of Witrame or a similar event, Your personal data may be part of the transferred assets.
We may share Your information with third parties to whom You ask Us to send Your information.
Witrame may hire agents, consultants, and related third parties to perform certain business-related functions, say, mailing information, maintaining databases and processing payments and We may share information with them. Please note that when We employ another entity to perform such functions, We only provide them with the information that they need to perform their specific function.
In Our commitment to the applicable laws, We may disclose personal information if required to do so by law or to respond to government authorities/agencies for verification of identity or investigation, and in the event of a legal proceeding, court process or other legal process/process of the court of law where We would be bound to do so by/under the applicable laws in force, or where We are mandated to establish or protect Our legal rights, intellectual property, and if it is necessary to verify the identity, prevent, detect or take action against any illegal activities, whatsoever including but not limited to cyber accidents, suspected or apprehended fraud, or where there is a reasonable apprehension of any situation(s) involving potential/material threats to the physical safety of any person, property etc.
Witrame may disclose Your personal data if required to do so by law or in the good faith belief that such action is necessary in urgent circumstances to protect the personal safety of users of the Website or the public or to protect against legal liability including to resolve disputes, investigate problems, or enforce Our policies/agreements.
- Any such third-party service providers use the data/information shared with them for marketing their services; or
- The use of the data/information for any other purpose other than in connection with the services they provide to Us.
We may use various marketing tools to create a better user experience for users visiting Our Website/Platform. These marketing tools permit Us to look at aggregated data such as scrolling patterns, clicks, and allow Us to run tests to determine which pages result in the best actions. However, Your personally identifiable information is not used by any of these tools.
We may use third-party service providers for tracking user activity.
We may use remarketing tracking cookies and conversion pixels from vendors such as Google and Facebook to present special offers to You for Our products or services over the Google Content Network and via social networks. Therefore, You may see an advertisement for one of Our products or services because of visiting our Website. In addition, We may use custom audiences based on emails and phone numbers of users. This allows Us to present special offers for our products and services to you via Facebook and Google. However, Your personally identifiable information is not used by any remarketing service other than to present You special offers from Us.
We may use the third-party service providers for remarketing.
- Facebook Ads
- Google Adwords
We use MailChimp as Our email service provider and, through Our email service provider MailChimp, We collect contact information, distribute Our newsletter, and track actions You take that assist Us in measuring the performance of the Website and newsletters. Upon subscription, We may also track the pages You visit on the website through MailChimp. If You are a Campaign owner, information about the Services You take from Us is passed on to MailChimp.
Our newsletters may contain tracking pixels. This pixel is embedded in emails and allows Us to analyze the success of Our newsletters. Because of these tracking pixels, We may see if and when You open an email, which links within the email You click, and the pages You visit on Our Website. This behaviour is not passed to third parties. All data submitted at the time of subscription to Our newsletter is stored on MailChimp servers. You may remove your subscription to Our newsletter at any time by clicking on the unsubscribe button provided in each email.
We use services of third-party service providers such as Stripe, PayPal, PayU, Cashfree, PayTM, Razorpay, etc. for Our products and services. At no time is your banking information passed to the Website from any of the following third-party providers. We receive only information used for payment fulfillment.
We use 256 BIT bit level of SSL standard data protection practices and technologies, and Your data is therefore protected in the course of transmission. Your data security is important to Us, however as no method of transmission over the internet or any method of electronic storage is completely secure, We cannot guarantee You absolute security of Your data. However, We shall strive to use reasonable and commercially acceptable means and industry standards to protect Your data/information.
PERSONAL DATA TRANSFERS
Your data/information is processed on cloud servers in India. However, Your data/Information may even be stored, transferred, or transmitted over, and used, in such locations outside of Your state, region, county, province, country, or other governmental/state jurisdiction where the privacy laws may not be as stringent or protective as the privacy laws in Your jurisdiction. Your data/information may be subject to the local laws of the jurisdictions within which it is being collected, stored, used, and/or disclosed and may be accessed by courts, law enforcement agencies, regulatory agencies, and/or statutory authorities in such jurisdictions. In all such cases in the foregoing, by using or accessing The Service/Website/Platform, You unconditionally give Your consent to the access, storage, transfer, transmission of Your data/ information and the usage and disclosure of Your data/information in all respects whatsoever.
PERSONAL DATA RETENTION
We adhere to the applicable laws regarding the retention of your data/information and We retain Your data/information only until the User account is subsisting with Us in the event that the User account is terminated/disabled due to any reason whatsoever, We shall not be responsible either to maintain and/or hold any personal data/information whatsoever provided by You. To know more about the grounds for such termination of the User account.
RIGHTS UNDER THE INDIAN INFORMATION TECHNOLOGY (REASONABLE SECURITY PRACTICES AND PROCEDURES AND SENSITIVE PERSONAL DATA OR INFORMATION) RULES, 2011
If You are a user from India and subject to the laws of the Republic of India, You have the right To Access, Review Or Correct Object To Collection, Processing, Portability, And Erasure Of Data/Information
You may send a request in writing to Us to
- Allow access to Your data/information or for review of Your data or
- Allow You to correct inaccuracies (excluding that which would be a violation of the law) or deficient data
- Delete or erase any personal data/information and We shall comply with Your request.
- Withdraw Your consent to the process in which Your data is collected and/or processed, in which event You may not be able to use the Platform/Website/Services.
We do not and shall not undertake any responsibility for the authenticity or genuineness of the data/information provided/shared by You and neither Witrame makes/provides any representation(s), warranty(ies), guarantee(s), covenant(s), admissions, estoppels(s), whatsoever that the data/information which You provide is correct, accurate and shall be suitable, whether in whole or in part, for the purpose(s) for which it is/was provided by You during the access and/or use of Witrame’s Platform/Service(s).
Other Types of Data/Information
Non-Identifiable Data: When You use Our Services through the Website, We receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify You. We may store such information, or such information may be included in databases owned and maintained by Our affiliates, agents, or service providers. Witrame Website may use such information and pool it with other information to track, for example, the total number of visitors to our Website, the number of visitors to each page of Our Website, and the domain names of Our visitors’ Internet service providers. Please note that it is important to note that no personal data is available or used in this process.
Aggregated personal data: We may conduct research on Our visitor/customer demographics, interests, and behavior based on the personal data and other information provided to Us. This research may be compiled and analyzed on an aggregate basis, and We may share this aggregate data with Our affiliates, agents, and business partners. This aggregate information does not identify You personally. We may also disclose aggregated user statistics in order to describe Our Platform/Services to current and prospective business partners, and to other third parties for other lawful purposes.
PUBLICLY VISIBLE INFORMATION
If You create a User account on an Witrame Website/Platform or leave a comment on a Website/Platform, certain information, like Your name, may be publicly visible.
WHAT ARE COOKIES?
A cookie is a small text file that is sent to the computer or mobile device (hereinafter “Device”) by the web server so that a website can remember some information about Your browsing activity on the website. The cookie collects information relating to Your use of the website, information about Your Device such as the Device’s internet protocol (IP) address and browser type, demographic data, and, if You arrived at the Witrame Website via a link from third-party websites, the URL of the linking page.
In addition to cookies, the Witrame Website may use web beacons. Web beacons allow Us to count the number of users who have visited or accessed the Website and to recognize users by accessing Our cookies. We may employ web beacons to facilitate Website administration and navigation, to track the actions of users of the Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors to the Website. We may also include web beacons in HTML-formatted email messages that We send to determine which email messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF, and tracker GIF.
What are the different types of cookies and how do we use them?
Essential cookies: These are cookies that are essential for the running of Our Website. Without these cookies, parts of Our Website will not function. These cookies do not track where You have been on the internet and do not gather information about You that could be used for marketing.
Examples of how We may use essential Cookies include:
- Setting unique identifiers for each unique visitor, so that website numbers can be analyzed.
Functional cookies*:* These cookies are used to remember Your preferences on Our Website and to provide enhanced, more personal features. The information collected by such cookies is usually anonymized, so We cannot identify You personally. Functional Cookies do not track Your internet usage or gather information that could be used for selling, advertising, etc.
Examples of how we may use functional cookies include:
- Gathering data about visits to Our Website, including numbers of visitors and visits, length of time spent on the Website, pages clicked on or where visitors have come from.
- Eliminating the need for returning users to re-enter their login details.
Analytical Performance: Analytical performance cookies are used to monitor the performance of Our Website, for example, to determine the number of page views and the number of unique users Our Website has. We use this information to improve user experience or identify areas of the Website which may require maintenance. The information is anonymous (i.e. it cannot be used to identify You and does not contain personal information such as Your name and email address) and it is only used for statistical purposes.
Examples of how We may use analytical cookies include:
- Measuring users’ behavior
- Analyzing which pages are viewed, and for how long, and which links are followed to better develop Our Website.
Advertising cookies: Behavioral advertising cookies, which may be placed on Your device by Us or Our trusted third-party service providers, remember that You have visited a Website and Use that information to provide You with advertising which is tailored to Your interests. This is often called online behavioral advertising and is done by grouping together shared interests based on web browsing history. Your web browsing history can be used to infer things about You (e.g. your age, gender, etc.), and this information may also be used to make advertising on the Website more relevant to You. Although behavioral advertising cookies can track your activity around the internet, these cookies cannot identify You personally, even if you are signed in to our Website.
Examples of how We may use advertising cookies include:
- To market to specific users across Our Website and third-party sites, so that We and third parties can target advertising to users that will be more relevant to users’ interests.
Third Party Cookies: You may notice on some pages of Our Website that cookies have been set that are not related to Us. When You visit a page with content embedded from, for example, YouTube or Facebook, these third-party service providers may set their own cookies on Your Device. We do not control the use of these third-party cookies and cannot access them due to how Cookies work, as Cookies, can only be accessed by the party who originally set them. Please check the third-party websites for more information about these cookies.
How can You manage or opt out of cookies?
Cookies, including those which have already been set, can be deleted from Your hard drive. You can also change the preferences/settings in Your web browser to control cookies. In some cases, You can choose to accept cookies from the primary site but block them from third parties. You can block cookies from specific advertisers or clear out all cookies. Deleting or blocking Cookies may reduce the functionality of the Website. To learn more about how to reject cookies, go to the HELP menu within Your internet browser. If you experience any problems having deleted cookies, You should contact the supplier of Your web browser.
Opting out of Analytical performance cookies
If You would like to opt out of Analytics cookies, please do so by clicking on the links below: Opting out of Behavioral Advertising Cookies
If You would like to disable “third party” cookies generated by advertisers or providers of targeted advertising services, You can turn them off by going to the third party’s website and getting them to generate a one-time “no thanks” cookie that will stop any further cookies being written to Your Device/machine. Here are links to the main third-party advertising platforms We use, each of which has instructions on how to disable cookies.
Further Information and Contact Details
If You have questions about the cookie section, or if You would like more information on the cookies that We use and their purposes, please contact Us at firstname.lastname@example.org.
Rights Related to your Personal Data
Please note that while any amendments, corrections, or deletions will be reflected in active user databases (as updated within a reasonable period of time), We may retain all personal data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations We reasonably believe applicable.
We may retain your personal data to comply with applicable laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce Our contracts, and take other actions otherwise permitted by law.
Please contact us at email@example.com to submit a request or obtain information regarding any of the above.
Opt-out: You may opt out of future email communications by following the unsubscribe links in our emails. You may also notify us at firstname.lastname@example.org to be removed from Our mailing list.
SENSITIVE PERSONAL INFORMATION
Unless You choose to provide it to Us, We do not collect sensitive personal information from You while You are using the Website. This includes your Aadhaar/social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. If You decide to submit such information to Us, it will be subject to this Privacy and Spam Policy.
Witrame strongly opposes any spam mailing. We will only send emails to users that have explicitly requested and given their express consent to receive an email from Witrame. Users agree to the terms (EULA) and there is no tolerance for objectionable content or abusive users. Examples may include:
● Opt-in subscribers to Witrame Newsletter
● Users that complete a contact form
● All communication will be related to what You have requested.
Witrame’s Website may contain links to other websites. Please be aware that Witrame is not responsible for the privacy practices or the content of such other sites. It is Your responsibility to be aware when You leave Our Website to read the privacy and spam policies of every website that collects personally identifiable information. This Privacy and Spam Policy applies solely to information collected by Witrame only.
If You send us an email with questions or comments, We may use your personally identifiable information to respond to Your questions or comments, and We may save Your questions or comments for future reference. For security reasons, We do not recommend that You send nonpublic personal information, such as passwords, social security numbers, or bank account information, to Us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails We send, or as provided below; however, We reserve the right to send you transactional emails such as customer service communications.
Your access to and use of the Website may also be subject to any separate agreements or terms and conditions You have signed or agreed to with Witrame. Please refer to those agreements as needed.
How Do I Contact Witrame Support?
You can contact us at email@example.com in case of any grievances.