(formerly known as eMinds Systems Lifecycle Pvt. Ltd.)
CIN: U72900HR2016PTC066520
Privacy Policy
(Last updated 15th August, 2020)
INTRODUCTION
Complinity Technologies Pvt. Ltd. (the "Company", "we", "us" or "our") through its website www.complinity.com ("Portal") provides a comprehensive cloud-based Governance, Risk and Compliance software that helps organizations manage theirCompliances, Contracts, Litigations, Audits, Secretarial, Registrations, Insurance, Risks,Controls and more ("Services").
We respect your privacy and are committed to protect it through our compliance with this Privacy Policy ("Policy"). Please read this Policy carefully to understand how we collect and use personalinformation and under which circumstances we share the personal information collected from you (hereinafter referred as "User" or "you") with any third party.
This Policy describes:
(i) the types of personal information that we may collect from you when you access or use the Portal including but not limited to any personal information shared by you for posing queries or for opting for a demo of the services offered by the Company through the Portal; and
(ii) our practices for collecting, using, maintaining, protecting and disclosing the personal information.
The Policy applies only to the personal information collected by us during your use of the Portal, through email and through other electronic communications sent through the Portal.
By accessing or using the Portal and/or registering for an account on the Portal, you agree to this Policy and you consent to our collection, use, retention and disclosure of your personal information in accordance with this Policy.
In the event you do not provide the personal information required by us, we may not be able to provide you complete use/access of the Portal or the Services provided thereto. Please note that while you will be accessing the Portal and sharing your personal information on behalf of your employer body corporate, which is the recipient of our Services ("Customer"); the information pertaining to the Customer which is entered, accessed or stored on the Portal, is governed by the confidentiality obligations contained in the terms of engagement with the Customer and therefore does not fall within the ambit of this Policy.
COLLECTION OF PERSONAL INFORMATION
We respect your privacy and are committed to protecting it in all respects from any unlawful disclosure. In order to facilitate your use of the Portal, we collect several types of personal information from and about you, including:
(i) Information about the internet connection you use to access the Portal.
(ii) The personal information that can be used to identify a specific person including but not limited to your name, email address, mobile number, designation, department and the name of your employer. We collect personal information about you to contact you with respect to your use of the Services, your queries or for customer support. Our Services and customer support are provided through many platforms, including but not limited to thePortal, email, and telephone.
Information which is freely available and accessible in the public domain or is furnished to any authority, organization, department or public at large,without any default by us shall not be considered as personal information.
Personal information is collected by us either directly from you when you or your employer provide it to usand/orautomatically as you login to your User Account on our Portal (IP addresses and session variables) as follows:
(i) Personal information that you provide us:
Upon creation of your user login, your personal information is either added by us, upon the instructions of the Customer; or is directly added by the representativeof the Customer designated as "the admin".
(a) In case you make an enquiry for demo or information, the personal information collected is as follows: Your name, name of your employer, your email address and your mobile number
(b) The personal information collected while registering your User Account is as follows: Your full name, email address, mobile number, password, department, designation, location and other personal information that youor the admin may provide with your account.
(ii) Personal information that we collect through Data Collection Technologies:
We may automatically collect certain personal information about your use of the Portal:
(a) Your browsing information: We use session variables to oversee how long you actively use the Portal. In case of continuous inactivity for 30 minutes, your session is automatically logged out.
(b) Your IP Address: Your Internet Protocol (IP) address is tracked to ensure that you are accessing the Portal and the Services through IP Addresses authorized by the Customer.
(iii) Cookies
We do not use any cookies, flash cookies, pixel tags or mobile ids, to track your usage of the Portal or customize your user experience at the moment. However, we may use cookies in the future, in which case this Policy will be adequately amended to cover the use and purpose of the cookies deployed by us. We only use session variables to ensure that each logged session is automatically logged out in case of inactivity of more than thirty minutes. The session variables are maintained for a period of 30 minutes or the duration of the browsing session, whichever is shorter.
(iv) Anonymous Data
We may anonymize personal information collected from you through the Portal or via other means, including via the use of third-party web analytic tools. As a result, our use and disclosure of aggregated anonymized personal information is not restricted by this Policy, and it may be used and disclosed to others without limitation.
STORAGE, PROCESSING AND SHARING OF PERSONAL INFORMATION
We take appropriate security measures to protect against any unauthorized access, alteration, modification, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption to guard against unauthorized access to systems where we store personal data. We have implemented appropriate electronic, and managerial procedures to safeguard and help prevent unauthorized access to your personal information and to maintain data security. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
All the personal information gathered from you is securely stored and on our behalf on third¬-party infrastructure provider Amazon Web Services.The database is stored in an encrypted form and processed on the servers provided by Amazon Web Services; with the access to the servers being password-protected and strictly limited. You can find more information about Amazon Web Services' security practices at https://aws.amazon.com/security/. However, as effective as the security measures are, no security system is impenetrable. We cannot guarantee the security of the database, nor can we guarantee that the personal information supplied to us by you will not be intercepted while being transmitted to us over the Internet. Internet is an ever evolving medium.
We assume no liability or responsibility for disclosure of your personal information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your personal information secure. You should not share your login credentials, or other security information for your User Account with anyone.
We do not share your personal information with any third party and are not bound to discloseyour information to any third party unless required by law.
USE OF PERSONAL INFORMATION
We use the personal information we collect from and about you for a variety of purposes, including:
a) contacting you to understand your requirements for the Services, including sharing quotations for the Services;
b) organizing physical demonstration of the Services offered through the Portal;
c) sharing notifications in relation to updates in the Services, including but not limited to the content provided through the Services;
d) tracking software usage;
e) processing and responding to your queries, complaints, bugs reported by you through the helpdesk;
f) sharing reminders pertaining to the compliances under the Services;
g) providing you customer support;
h) carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collection;
i) assisting you in password retrieval and policy changes;
j) preserving history as governed by existing law or policy;
k) sending information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
l) meeting any applicable law, regulation and legal process;
m) responding to law enforcement authority or other governmental official request;
n) enforcing applicable Terms and Conditions, including investigation of potential violations;
o) detecting, preventing or otherwise addressing fraud, security or technical issues;
p) protecting against harm to our rights, property or safety, or harm to our users or the public, as required or permitted by law;
q) disclosing for the purpose of our audits or investigating a complaint or security threat; or
r) any other purpose, for which we have obtained your consent.
SHARING OF PERSONAL INFORMATION
We do not disclose the personal information that we collect or you provide, as described in this Policy, to any third party, save and except for the following purposes:
Legal Purposes: We may share your personal information when we believe in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. We may also share your personal information to investigate and address threats or potential threats to the physical safety of any person, to investigate and address violations of this Privacy Policy or the Terms and Conditions, or to investigate and address violations of the rights of third parties and/or to protect the rights, property and safety of the Company, its employees, users, or the public. This may involve the sharing of your personal information with law enforcement agencies, government agencies, courts, and/or other organizations in response to legal requests, such as summons, court orders or government demands to comply with the law.
Contractual Rights: We may be required to disclose your personal information to enforce or apply our Terms and Conditions and other agreements.
Consent: We may share your personal information in any other manneras may have been consented to by you.
Customer Testimonials / Comments / Reviews: From time to time, we post customer testimonials on the Portal, which may contain personal information such as your name and designation. We always obtain the customers' consent prior to posting their names along with their testimonials
.
CORRECTING THE INFORMATION
We will take reasonable steps to accurately record the personal information that you provide to us and any subsequent updates. In case you wish to review, update, and correct the personal information that we maintain about you, or you wish to delete the personal information about you that is inaccurate, incomplete, you may do so by contacting the Privacy Officer (described in the Section below).
Subject to the applicable law, your right to review, update, correct, and delete your personal information may be limited:
(i) Where the rights or safety of another person or persons would be encroached upon, or
(ii) If the information requested relates to any pending or threatened legal proceedings between you and the Company.
Your right to review, update, correct, and delete your information is subject to our records retention policies and applicable law, including any statutory retention requirements.
TERMINATION OF ACCOUNT
In case of termination of your User Account, pursuant to the instruction of the Customer, or upon the termination or expiry of the engagement between us and the Customer, we will either delete your personal information or de-identify it so that it is anonymous and not attributable to you. We may retain information about you for the purposes authorized under the applicable law.For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Portal or to comply with legal obligations.
TO CONTACT OUR PRIVACY OFFICER
If you have an enquiry or a complaint about the way we handle your Personal Information, or seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows: By Email: neera.singh@complinity.com By Mail: Unit No. 544, Tower B-2,
Spaze i-Tech Park,
Sohna Road Sector 49,
Gurugram - 122018,
Haryana
While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above.
AMENDMENTS
We reserve the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and use practices, the features of our Services, or advancements in technology. Use of information we collect is subject to this Privacy Policy in effect at the time such information is used. If we make any material changes to this Privacy Policy, we will notify the changes to you through the Portal. Please review the changes carefully. Your continued use of the Services following the posting of changes to this Privacy Policy will constitute your consent and acceptance of those changes.