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PRIVACY POLICY

This Privacy Policy ("Privacy Policy") describes the types of information that Glowbox Media Private Limited ("Company", "We", "Us", "Our") may collect from a user ("You", "Your", or "User") on or through our mobile application ("Heyo") and website (collectively, the "Platform") and how We use, process, disclose, and protect such information. By accessing or using Our Platform, You acknowledge that You have read, comprehended, and agreed to the privacy policies contained in this Privacy Policy.
 
This Privacy Policy is in compliance with the following Laws and Regulations:
 
● Information Technology (Intermediaries Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediaries Guidelines”);
● Information Technology Act, 2000 (“IT Act”); and
● Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”).

General Norms and Terms to be Complied with:

By using this Platform or providing Us with Your information, You confirm that You have the legal capacity to enter into a legally binding contract under Indian law, specifically the Indian Contract Act, 1872, and that You have read, understood, and agreed to the practices and policies outlined in this Privacy Policy and agree to abide by them.
 
If You access or use Services on the Platform from an overseas location, You (or Your Guardian, as the case may be) are entirely responsible for compliance with any local laws.
 
You consent to the collection, use, sharing, and disclosure of Your information in accordance with this Privacy Policy. We reserve the right, in Our sole discretion, to alter, modify, add, or delete elements of this Privacy Policy at any time, and your continuing use of the Platform after any such amendments will be regarded as an implicit acceptance of the Privacy Policy in its revised form. You should review the Privacy Policy regularly to ensure that you are informed of any modifications or updates to the policy's terms.
 
If you do not agree to any of the terms and conditions included in this Privacy Policy, please do not use this Platform. This Privacy Policy is subject to change without notice at any time. Please check this policy on this Platform regularly to ensure that You are aware of any changes.

Information Collected by Us

You may provide or We may collect information that can specifically identify You or any other individual when you browse the Platform or use the Service(s). The categories of information that We may gather are listed below:
 

  • Information that You provide:

We gather registration information such as your phone number, full name, gender, your school/college details, class details, email address (as and when collected), and interest tags when you register on the Platform. We use a one-time password issued to Your phone number to validate Your phone number. You can choose not to provide certain information, but You will not have access to the full extent of the features available on our Platform.
 

  • Information from content and communication:

This can include information in or about the content that you provide (e.g., metadata), such as the location of a picture/photo or the date a file was created. Our systems automatically process content and communications that you and others provide to analyze context and what's in them for the purposes described below.
 

  • Information from your address book/contacts:

We may collect information from your address book/contacts if you give us such access. We may use this information to market our offers, promotions, or any such services to the contacts in your address book.
 

  • Sensitive personal data or information:

We may collect sensitive personal data or information as under the SPDI Rules about You when You use Our Service(s) on the Platform. By using the Service, You consent to the recording,].

Third Party Tracking Technologies:

"Cookies" and other tracking technologies are used by us. A "cookie" is a little text file that is used to gather information about activities on the Site or the App, for example. Some cookies and other technologies may be used to retrieve information that a User has already indicated or provided. Most browsers and mobile device settings allow You to manage cookies, including whether or not to accept them and how to delete them. Most browsers/mobile apps allow you to be notified when a cookie is received, or you may opt to ban cookies using your browser/mobile applications.
 
Tracking technologies may collect data such as internet domain and host names, IP addresses, browser software and operating system kinds, stream patterns, and the dates and times that Our Platform is viewed. We use cookies and other tracking technologies to enhance Our Platform, as well as Your experience.
 
You may refuse all cookies on Your browser or the App at any time by adjusting Your settings to the extent permitted on Your device. However, by doing so, You may be unable to access some Platform features or fully benefit from all products and preference-based advertising. You may delete cookies by following the instructions in your mobile device's "help" file or the browser.
 
Our App makes use of third-party Software Development Kits (SDKs). The majority of them are various payment methods via which You may pay for an order. To improve Your personal and overall experience, some tools are included.
 
When You engage with Us, we receive and retain certain sorts of information. For example, when Your web browser visits the Platform or advertising and other content offered by or on behalf of the Platform on other web sites, We collect certain kinds of information. 
Additionally, we may receive/store information on Your mobile device, such as a unique device identifier. We may analyse this data internally and use it to offer You with location-based services such as advertising, search results, and other tailored content.
The IT Act and the SPDI Rules govern the collection, use, retention, and disclosure of personal information, which is defined by the SPDI Rules as any information relating to a natural person that, when combined with other information available or likely to be available to a body corporate, is capable of identifying such person.
 
You acknowledge that You are freely submitting all information, including SPDI, to Us. Your affirmative consent is required for the collection, use, and dissemination of personal information and SPDI.
 
You are giving Us permission to use, collect, and disclose your personal information and SPDI. You may opt not to supply Us with personal information and SPDI; but, if You do, We will be unable to provide You with access to Our Platform, or to offer items or provide Services through Our Platform.

Parties who are Privy to Your Information

Our Company relies heavily on information about You and other Platform users. We will only share personal information with third parties as mentioned below after confirming that they have implemented data protection measures and are either subject to this Privacy Policy or follow policies at least as protective as those specified in this Privacy Policy.
 
You accept the terms of this agreement by using the Platform and hereby consent to the storage and processing of your personal information and SPDI by third parties. We have agreements with third parties (including those listed below) such as affiliates or group companies, service providers, retailers, payment gateways, and logistics partners who are the intended recipients and may have access to personal information and SPDI but will not disclose such information or SPDI to any other individual or entity. Some of the third parties are as follows:
 
Your personal information or SPDI may be shared with connected retail shops or businesses that provide and support Your use of the Services.;
 
Some of Your personal information or SPDI may be shared with third-party service providers including but not limited to merchants and logistical providers in order to provide Services and deliver Your purchase (s). 
The tools utilised by such third-party service providers to deliver the Services may also gather Your personal information or SPDI while doing so.
Furthermore, they must treat personal information in line with this Privacy Policy and in compliance with relevant legislation. It is expressly stated that We will not be held accountable or liable for the acts, omissions, or commissions of such third parties linked with Us. We may, however, assist You in addressing any issues You may have with such third parties.
 
Any third party to whom We transfer or sell Our assets, merge or consolidate, will have the right to use the information (including SPDI) submitted to Us in line with this Privacy Policy. We may release information in an anonymized and aggregate form to Our partners, affiliates, subsidiaries, group companies, investors, stakeholders, or future associates so that they, too, may learn how Users use Our Platform and help Us develop a better overall experience for You; and
We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies.
 
You acknowledge that We have the right to use a recorded copy of Your telephone conversation with Us, letters that You may write to us, and/or any other internet communications, including but not limited to the comments that You leave about us on various social media platforms, reviews that You leave about us on 3rd party websites, emails, for improving Our Services, marketing and promotional efforts, customising Your experience, and assisting You in obtaining the most effect. These uses help us enhance the Site, the App, and the Services and better adapt them to Your needs, resulting in a more efficient, safe, and tailored experience for You. We may send such personal information and SPDI to a third party, including individuals outside India, in order to improve product and service offerings, while taking commercially reasonable means to ensure that the recipient conforms to the applicable laws protecting data protection, as We do.
 
We may release account and other personal information when We believe in good faith that such release is appropriate to comply with applicable law including to:

 

  • Comply with legal standards or legal process;

  • To prevent a crime or to protect national security;

  • Protect rights, property, or related businesses; and

  • Ensure the personal safety of Our Users and the general public. 

 
We may also share Your personal information in order to enforce or apply Our Terms and other agreements, or to defend Our rights, property, or safety, as well as the safety of Our Users or others. This involves exchanging information with other businesses, organisations, governments, or regulatory agencies in order to combat fraud and reduce credit risk;
 
Subject to applicable legislation, We may transmit personal information and SPDI to any other body corporate (as defined in the Information Technology Act, 2000) based in India or any other country that provides at least the same level of data protection as We provide under the provisions of this Agreement.
 
By using the Platform, You consent to Us sharing and/or processing Your personal information and SPDI with third parties, including those located outside India, as long as they ensure that Your SPDI is protected in accordance with standards comparable to those in India or equivalent international standards.

Usage of Your Information

We make use of and gather information in a number of ways in order to deliver Services on the Platform and to run Our business, including the following:
 

  • To fulfil Our duties in connection with Your requests for goods and services via the Platform;

  • To run and maintain the Platform in order to enhance the user experience and the overall health of Our company;

  • For the purpose of processing and delivering Your purchase with Us;

  • To give You with access to Our Platform in order to buy items and services;

  • Data analysis, trend monitoring, algorithm development, and database creation for rating systems, recommendation engines, and similar applications;

  • We use the information You give to react to Your requests, improve Our Platform, and communicate with You.

  • For goals other than targeting, such as frequency limiting, compliance, payment, ad reporting or delivery, market research, or product development;

  • To adhere to all relevant laws;

  • To carry out audits and quality control processes;

  • To analyse how Our resources are being used, fix issues, and improve Our Products and Services, by using information about Your mobile device and software.

  • Contacting users throughout and after a purchase to provide updates, resolve customer service issues, confirm order information, or promote new items or services;

  • To investigate, prevent, or take action regarding unlawful activity, suspected fraud, circumstances posing a danger to any person's safety, breaches of the provisions of this Privacy Policy, or as otherwise required by law;

  • To respond to any inquiries You may have and to communicate information to You, such as notifications of any promotions or alerts, changes/updates to the Site, or the introduction of any future fees or charges that We may collect from You in connection with the purchase of products or provision of Our Services; or

  • To contact You from time to time by SMS, email, and phone calls to solicit Your useful comments on Our goods and services as they presently exist and/or any future products and services that may be provided.

 
We may use “cookies” information and “automatically collected” information We collect on the Platform to do the following:
 

  • Personalize the Services that We provide by remembering Your information so that You do not have to enter it again during Your visit or the next time You use the Service;

  • Monitor and assess the success of the Service and third-party marketing initiatives;

  • Keep track of aggregate site use metrics like total number of visitors and pages viewed; and

  • Maintain a record of your entries, contributions, and status in any promotions or other activity on the Service.

 
We may access or keep Your information if it is required to identify, prevent, or resolve fraud and other criminal behaviour, or to protect the Platform's or others' safety, property, or rights .
 
We may use information regarding Your location or the location of Your device through which You access the Service for a number of purposes, including without limitation to confirm You are located in a jurisdiction in which the Service is offered and to identify an appropriate delivery partner for conducting the Service effectively.
 
We may collect, analyse, utilise, publish and produce de-identified information, which may include Your personal or sensitive personal information, for any business or other purpose permissible under applicable law, including research and marketing. (collectively referred to as "Purposes").

Your Consent

By accessing our Platform or supplying your information, you agree to the collection, use, storage, disclosure, and other processing of your information (including sensitive personal information) on the Platform in accordance with the terms of this Privacy Policy. If you give personal information about other persons to us, you indicate that you have the permission to do so and that you agree to let us use the information in accordance with our Privacy Policy.
 
You consent to us (including our affiliates and other third parties) contacting you through SMS, instant messaging apps, phone call, and/or e-mail for the reasons indicated in this Privacy Policy by giving your personal information on the Platform or any connected platforms or institutions.

What Are Our Data Security Practices?

We implement appropriate technical and organisational security measures to ensure that your personal data is protected to a level commensurate with the risk, taking into account state-of-the-art technologies, implementation costs, the nature, scope, context, and purposes of processing, as well as the likelihood and degree of risk. Personal data is generally transferred encrypted between your end device and us. The lock icon in your browser's address line indicates an encrypted connection. Third-party access cannot be ruled out if you connect with us by email.

How Secure Is the Information that You provide?

In connection with the collection, storage, and disclosure of personal information, we maintain adequate technological, physical, and procedural measures (including SPDI).  Due to our security processes, We may occasionally seek verification of identification before disclosing personal information to You.
 
We limit access to personal information to Our employees and agents who need to know that information to process it for Us and who are subject to strict contractual confidentiality obligations and may be disciplined or have their relationship with Us terminated if they fail to meet these obligations.
 
No employee or administrator will have access to Your password or Your account information on the Site or the App. It is critical that You safeguard Your account from unauthorized access to Your password and mobile phone, as specified in the Site/'User App's Account, Password, and Security' section. You must remember to log out of the Site or the App once you have done using it. We accept no responsibility for any unauthorised use of Your account or password.
 
If You suspect any unauthorised use of Your account, You must tell Us immediately by sending an email to the contact information listed in the contact section. You agree to compensate Us for any losses incurred as a result of such unauthorised use of Your account or password.
 
We will not be able to obtain Your prior consent before disclosing Your information in certain circumstances, including but not limited to information demanded by government agencies or otherwise mandated by law to obtain SPDI, or during investigations of cyber incidents, prosecution of offences, or any other requirement deemed necessary by the Company..
Furthermore, We shall not be liable for any breach of security or for any third-party actions or events beyond Our reasonable control, including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage devices, computer crashes, breach of security and encryption, poor quality of internet service or telephone service provided by the User etc.

Access and Facilities Provided to You

The Platform provides You with access to a wide range of information regarding Your account and Your activities with the Platform solely for the purpose of seeing and, in certain situations, amending or deleting information supplied on the App or the Site. You have the ability to opt-out of optional services as well, and if you want to opt-in to such services when you join up, you can do so.
 
If You are a minor
The Platform is accessible exclusively to those who are legally capable of entering into a legally binding contract under the Indian Contract Act, 1872. If You are under the age of 18, please read our terms and conditions on how you may use our Services. If You are a parent or guardian and discover that Your child under the age of 18 has created an account on the Service or has accessed it in any other way without your permission, You may contact Us at support@lavampl.com and request that We delete that minor’s personally identifiable information from Our systems.
 
International Transfer of Data
Personal information about You that we have on file may be transmitted to countries outside of India for any of the purposes outlined in this Privacy Policy. You understand and accept that these countries may have different (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds, and that such information may become subject to such countries' laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies, and private persons, as a result of an applicable governmental or regulatory inquiry, court order, or other similar process. Furthermore, a number of nations have agreements with other countries that allow for the exchange of information for law enforcement, taxation, and other purposes.
 
If we transfer your personal data to third parties for the purposes stated in this Privacy Policy, we will use our best efforts to put appropriate controls and safeguards in place to ensure that your personal data is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a fair, transparent, and lawful manner, and is stored for no longer than is absolutely necessary.

Links to Third Parties

The Platform may include hyperlinks to a variety of different websites, as well as ads and connections to third-party apps, content, or resources ("Third Party Links"). We have no control over Third Party Links that may appear on the Site or the App and are offered by individuals or businesses other than Us. You recognise and accept that We are not responsible for any other sites, apps, corporations, or individuals collecting or disclosing Your information. The placement of any Third Party Links on Our Platform should not be regarded as an endorsement, recommendation, or solicitation of such Third Party Links or any other content on or accessible via such Third Party Links.
 
Additionally, You acknowledge and agree that We are not liable for any loss or damage incurred by You as a result of the collection and/or disclosure of Your information via Third Party Links, or as a result of any reliance placed by You on the completeness, accuracy, or existence of any advertising, products, services, or other materials on, or accessible via, such Third Party Links. This includes any transactions and information exchanged between You and any such third-party sites, apps, or resources, which are purely bi-partite in nature. We will not be accountable for any issues that may arise between You and the aforementioned third parties as a result of or in connection with such transactions.
 
These third-party websites, external apps, or resources that are available through the Third Party Links may have their own privacy rules regulating the collection, storage, retention, and dissemination of Your information. We recommend that You exercise reasonable diligence, as You would in traditional offline channels, and use your judgement and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the privacy policies of any third party website or application.
 
Information that We retain
Additionally, We have safeguards in place to ensure that Your SPDI is deleted and/or anonymized as soon as it is reasonable to anticipate that:
i. The reasons for collecting Your SPDI have been met; and
 
ii. Retention is no longer required by law or for any other reason.
 
We reserve the right, however, to preserve and maintain Your personal information for Our business reasons, regardless of whether such information has been erased. Your data may be anonymized and aggregated after a period of time and then retained by Us for as long as required to allow the purchase of items and provision of Services, or for analytics purposes.
If You wish to revoke Your consent to the processing of Your personal information and SPDI, cancel Your account, or request that We stop using Your personal information and SPDI to deliver Our products or provide You with services, please contact Us using the contact information provided in the contact section. Please keep in mind, however, that withdrawing permission or cancelling your account may result in Our inability to supply goods or offer services to You, or in the termination of any existing relationship We may have with You.
 
Please note that uninstalling the App WILL NOT result in deletion of Your personal information or SPDI.

Changes to Your Information

By logging into Your account, You may check, correct, update, and modify the information You've given. You are not, however, entitled to erase any portion of your personal information or other information created on the Platform. You may request that We erase the information. You may amend Your information at any time by writing to Us at the contact information shown below.
 
If You choose to update or modify Your personal information or SPDI in a way that is not verifiable by Us or results in such information being incorrect, We will be unable to provide You with access to Our Site, App, or the Services, as described in the terms of this Privacy Policy, and such modification may be interpreted as the User requesting to discontinue access to Our Site, App, or the Services.
 
We have the right to verify and validate Your identity and personal information to guarantee that goods and services are delivered accurately. We may deny or restrict access to, or correction, update, or deletion of, Your personal information or SPDI if doing so would violate the rights of another person and/or is not otherwise authorised by applicable law.

Notices

If You have any concerns or complaints regarding the Site or the App, please contact Us with a detailed explanation and We will attempt to address the matter for You.
 
If You have any concerns or questions in relation to this Privacy Policy, You may address them to Our grievance officer at:
 
Name: Sharad Seksaria
 
Address: 15, Khetan Bhavan, 198, J, Tata Road, Churchgate, Mumbai - 400020
 
Phone: 9920805460
 
E-mail: support@lavampl.com
 
We shall endeavour to resolve Your grievances within 1 (one) month from the date of receipt of such grievances.
 
Miscellaneous
You agree and undertake to compensate Us in the event of any third-party claim or dispute arising out of Your disclosure of information to third parties, whether via Our Platform or elsewhere, and Your use and access to third-party websites, apps, and resources. We disclaim any duty for third-party activities involving Your personal information or SPDI that You may have supplied to such third parties.
 
Unless otherwise specifically stated or implied by the context of this Privacy Policy, each clause of this Privacy Policy will be and remain distinct from, independent of, and severable from, all other provisions hereof. The determination or declaration of nullity or voidance of one or more sections shall have no impact on the other provisions of this Privacy Policy.
We cannot guarantee that Your personal information and SPDI will never be disclosed in methods not explicitly stated in this Privacy Policy. As a result, although We are dedicated to safeguarding Your privacy, We cannot guarantee that Your information or private conversations will always stay private, and You should not anticipate that they will. As a User of the Site or the App, You acknowledge and accept that You are solely responsible and liable for Your use of the Site or the App, the internet in general, and the information You post or access, as well as for Your behaviour on and off the Site or the App.

About Us

We are a tech-driven company dedicated to creating innovative mobile and web applications. Our team of experts combines cutting-edge technology with strategic thinking to deliver solutions that drive business growth. 

GLOWBOX MEDIA

Glowbox Media LLP

100 Cecil Street, #15-02
The Globe,
Singapore-069532

info@lavampl.com

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