GDPR POLICY
GDPR POLICY
At, Ibex Engineering Pvt. Ltd., a Company incorporated under the laws of India, having its principal place of business at, # 111/1, Somanahalli Village, Bangalore South Taluk, Bengaluru, Karnataka - 560116, India (hereinafter ‘Company’, ‘We’, ‘Our’, or ‘Us’), your i.e. ‘Users’ (defined below) privacy is of great importance to us. We understand that you entrust us with certain Personal Data (as defined below) to help us provide various Services. In exchange for your trust, you expect and deserve our commitment to treat your information with respect and in accordance with the terms of this Policy (‘Policy’).
In this Policy (‘Policy’), we describe the information that we collect about You our Users who are located in the European Union when you use and access https://www.ibexlifestyle.com (the ‘Website’) and the Services as may be introduced by the Company from time to time, your rights and choices with respect said information and how and why we process, use, store, and disclose that information. The Company is the owner and controller of the Website. To ensure that you can make informed decisions and feel confident about sharing certain Personal Data with us, please read this Policy to understand who we share your Personal Information with and for what purposes and the choices you have concerning how your Personal Information is collected and used by us.
If you have any questions or comments about the Policy, please contact us at _cel@ibexengineering.com. This Policy is incorporated into and is subject to the Company’s Terms of Use with Users, which can be accessed at https://www.ibexlifestyle.com/ (hereinafter ‘Terms’). Your use of the Website and Services offered thereunder and any personal information you provide on therein remains subject to the terms of this Policy and the Terms.
BY ACCESSING OR USING THE WEBSITE, AND/OR SERVICES PROVIDED THEREIN, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THIS POLICY AND OUR TERMS. IF YOU DO NOT AGREE TO THE TERMS OR POLICY DO NOT USE THE SERVICES OR ACCESS THE WEBSITE.
-
YOUR PRIVACY - OUR COMMITMENT
We recognize the importance of your personal privacy. Please read the following Policy to understand how your Personal Information will be treated as you make full use of the Services offered through the Website. Except as disclosed in this Policy or as otherwise authorized by you, we will not share your Personal Information with third parties for their marketing purposes. Your trust and confidence are our highest priority.
-
DEFINITIONS
As used in these Terms, the following terms shall have the meaning set forth below:
-
‘ Personal Data’ means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
-
‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
-
‘Effective Date’ means the Date on which You accept these Terms by using the Website therein entering into an agreement with the Company.
-
‘User’ means any person who browses, uses the Website or Services therein.
-
‘User Content’ may be defined to mean any information pertaining to name, legal status, e-mail address, phone number, payment details, and address of the User, materials that the User may upload, post, or otherwise transmit to this Website including but not limited to User uploaded images, text, data, photos, images, graphics, digital images, or any combination thereof.
-
‘Services’ shall mean the services listed in Clause 2 of the Terms of Use which are offered to Users who simply browse the Website. The Company may remove or add new services from time to time and may also charge a certain amount for offering such Services.
-
All other terms shall have the meaning ascribed to them in the General Data Protection Regulation (GDPR).
-
INFORMATION WE COLLECT
-
Information provided to us:
We receive and store Personal Data (i.e. includes information that whether on its own or in combination with other information may be used to readily identify or contact you).
User data which you provide to us:
We may collect certain information when you are using certain parts of our Website such as your complete name, address, e-mail address, mobile number, payment details when making a payment for purchasing some product/service on the Website etc. and other such Personal Data when you use the Website. Said data may be processed in order to provide our services and to efficiently communicate with you. The legal basis for the collection and processing of said data is to further our legitimate interests of conducting our business through the provision of our products/services efficiently and in a timely manner.
Transaction data/payment method:
We may collect and process information relating to transactions involving the purchase of goods through our Website. The transaction data may include your contact details, information relating to the manner/method of payment, card information (for your security, we do not retain your CVV number, we simply use this to authenticate your card), the payment gateway, and where relevant, the name of your bank, and the transaction details. The data so collected shall be limited to those entered by you. The transaction data may be processed for the purpose of supplying the purchased goods and keeping proper records of those transactions. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
Correspondence and enquiry data:
We may collect and use records and copies of your correspondence (including e-mail addresses), if you contact us. We may collect and process information contained in any enquiry you submit to us regarding goods and/or services offered through the Website. We will also collect information which is made available by the details that you post during your use of the website, and any comments regarding the Software or discussions you post in any blog, chat room, or other correspondence on the Website. You always have the option to not provide information by choosing not to use a particular Service or feature. Importantly, we only collect Personal Data about you that we consider necessary for achieving this purpose and communicating with you about the Services being offered. The legal basis for this processing is your consent and our legitimate interest in using this data to provide you with information that you request from us.
Usage data:
We may process data about your use of our Website and Services. The usage data may include your hardware model, browser type and version, geographical location, IP address, operating system version, unique device identifiers, and mobile network information including phone number, location, URL that you just came from (whether this URL is on our Website or not), which URL you go to next (whether this URL is on our Website or not), your computer browser information, your ISP, and other technical information, referral source, length of visit, page views, and website navigation paths, traffic, logs, other communication data, as well as information about the timing, frequency, and pattern of your Service use. We use this information to analyze the use of the website and services and improve our Website to deliver a better and more personalized service by enabling us to estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our Website according to your individual interests, and recognize you when you return to our Website. This is necessary for the purposes of our legitimate interest to provide you with the website services and to continuously improve these services. The legal basis for this processing is our legitimate interests in monitoring and improving our website and services.
We may process any of your Personal Data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
We may also process any of your Personal Data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests, or the vital interests of another natural person.
Please do not supply any other person's Personal Data to us, unless we prompt you to do so.
By continuing to use our Website and/or Software you are deemed to have read the Policy and understood the purpose for which your Personal Data or such other information is being collected and how the same shall be used and granting your express consent to such purpose and use. If, at a later date, you wish to withdraw this consent, please send us an e-mail at _cel@ibexengineering.com.
Cookies: We use data collection devices such as ‘cookies’ on certain pages of the Website to help analyze our web page flow, measure promotional effectiveness, and promote trust and safety. ‘Cookies’ are small files placed on the hard drive of your computer that assist us in providing the Services. We offer certain features that are only available through the use of a cookie. We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. Most cookies are ‘session cookies’, meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Website and you may be required to reenter your password more frequently during a session. Additionally, you may encounter ‘cookies’ or other similar devices on certain pages of the Website that are placed by third parties. For example, if you view a web page created by a user, there may be a ‘cookie’ placed within that web page. We do not control the use of cookies by third parties.
-
USE OF INFORMATION COLLECTED
Use of Personal Data about You is an integral part of our business. We neither rent nor sell your Personal Information to anyone. We may share your Personal Data only as described in this Policy and related documents.
Personal Data:
We will use and store Personal Data to:
-
deliver Services to you, including registering you for purchasing our products or using our Services, verifying your identity and authority to purchase our products, use our Services, and to otherwise enable you to use our Website and our Services
-
maintain, and improve our Services, including, for example, to facilitate payments, provide Services you request (and send related information), develop new features, provide customer support to You;
-
develop safety features, authenticate users;
-
send updates and administrative messages;
-
market the Service and for the internal operational and administrative purposes of the Service;
-
process billing and payment, including sharing with third party payment gateways in connection with Website, Software and Services;
-
collect information specific to You if you send us personal correspondence, such as e-mails or letters, or if other users or third parties send us correspondence about your activities or postings on the Website or Software
-
improve our marketing and promotional efforts;
-
analyze Website usage;
-
improve the Website and Software content and Service offerings;
-
customize the Website and Software content, layout, and Services;
-
provide You with a smooth, efficient, safe and customized experience while using the Website and/or Software
You agree that we may use your Personal Data in the file we maintain about you, and other information we obtain from your current and past activities to: resolve disputes, troubleshoot problems, help promote safe trading, measure consumer interest in the Services provided by us, inform you about online and offline offers, services, and updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our Terms of Use, and as otherwise described to you at the time of collection.
Legal Basis of the Above: to further our legitimate interests of conducting our business through the provision of our Products/Services efficiently and in a timely manner, to keep you updated with news in relation to our products and services, contract performance.
Aggregate Information: We will also use Personal Data and non-personally identifiable information and other information (including information from online and offline third party sources) to create aggregated data for analytical and other purposes. We use this information to do internal research on your demographics, interests, and behavior to better understand, protect and serve You. This information is compiled and analyzed on an aggregated basis. Unless otherwise stated in this Policy, We only use this data in aggregate form.
Legal Basis: legitimate interests (to allow us to improve our services)
Non-personally Identifiable Information: We may use Non-Personally Identifiable Information in connection with the Services offered through the Website, including: to administer the Services being offered there under, to understand how well the Service is working, to market the Services and other products and services, to develop aggregate, statistical information on usage of the Service and to generally improve the Service. Collecting this information enables us to better diagnose problems with our server and to administer our Website, as well as understand the visitors who come to our Website where they come from, and what content is of interest to them. This information aids us in merchandising and in developing the design and layout of the Website.
Legal Basis: legitimate interests (to allow us to improve our services)
e-mail/SMS Communications: The Platform may use your Personal Data for the aforementioned purposes of the Website. You have full control regarding which of these e-mails and SMS You want to receive. If You decide at any time that You no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. All Users receive administrative e-mails and text messages. From time to time, we may reveal general statistical information about our Website and Software through e-mails and messages.
Legal Basis: legitimate interests (to notify you about changes to our products or service)
-
OUR DISCLOSURE OF YOUR INFORMATION
We may also use your Personal Data to deliver information to you that, in some cases, are targeted to your interests, such as new services, rewards, and promotions. The following are some circumstances under which and people to whom we would share your Information with from time-to-time:
-
Disclosure of Personal Data:
Users: We do not disclose your Personal Data such as e-mail address, contact details, telephone number, and mailing address to any third party for marketing purposes. Except as otherwise provided under this Policy, we will disclose your Personal Data to third parties only in the following limited circumstances:
-
if you use the Service through the Website, we may disclose your Information to trusted partners, our agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this Policy, who work on behalf of or with us under confidentiality agreements. These entities may use your data for performing services, administering promotions, analyzing data and usage of the Service through the Website, processing credit card payments, operating the Service or providing support and maintenance services for the same, or providing customer service.
-
when we have your consent to otherwise share the information.
-
Non-personally Identifiable Information: We may disclose other Non-personally Identifiable Information to third party advertisers and advertising agencies, partners, and other parties in order for us and such third parties to analyze (a) the performance of, to operate and improve the Services offered through the Website, and (b) the behavior of Users and to target offers to other users and depending upon their requirements. We may also disclose, use, or publish this information for promoting the Services offered under the Website. These third parties are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced operation, unless you have explicitly agreed or given your prior permission to them for additional uses.
-
Aggregate Information: Because the aggregate information we collect does not specifically identify you, it may be shared with any number of parties. For example, we may disclose anonymous, aggregated information to third parties such as potential business partners, end users, service providers, advertisers, and funding sources, in order to describe our business and operations.
-
Network Operators: Use of the Service provided through the Website may involve use of the services of third party telecommunications carriers, internet service providers, and service providers (such as the services of the carrier that provides cell phone service to you). Such carriers and service providers are not our contractors, and any information that a carrier collects in connection with your use of the Service provided through the Website is not " Personal Data" and is not subject to this Policy. We are not responsible for the acts or omissions of telecommunications carriers, internet service providers or service providers.
-
Additional Disclosures: Notwithstanding anything to the contrary in this Policy, We reserve the right to use or disclose Personal Data and any other information we collect in connection with the Service offered through the Website (a) to any successor to our business, including as a result of any merger, acquisition, asset sale, or similar transaction, (b) to any corporate affiliate of ours whose privacy practices are substantially similar to ours, (c) to any law enforcement, judicial authority, governmental, or regulatory authority, to the extent required by law or legal process, or (d) if in our reasonable discretion, such use or disclosure is necessary to enforce or protect our legal rights or to protect third parties.
-
Communications with Us or Through the Service: Any communication or material You transmit to us by e-mail or otherwise, including any data other than Personal Data, questions, comments, suggestions, or the like is, and will be treated as non-confidential and non proprietary. Except to the extent expressly covered by this policy, anything you transmit or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast, and posting. Furthermore, you expressly agree that we are free to use any ideas, concepts, knowhow, or techniques contained in any communication you send to us without compensation and for any purpose whatsoever, including but not limited to, developing, manufacturing and marketing products and services using such information.
-
INTERNATIONAL TRANSFERS OF YOUR DATA
The hosting facilities for our website are situated in India. Hence your Personal Data may be transferred to countries outside the European Economic Area (EEA). The European Commission has made an ‘adequacy decision’ with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely, the use of standard data protection clauses adopted or approved by the European Commission.
You hereby acknowledge that the Personal Data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such Personal Data by others.
-
DURATION OF RETAINING YOUR DATA
Personal Data that we process for the purpose mentioned in this Policy shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your Personal Data, including any user data, transaction data, usage data, enquiry, and correspondence data and such other data as is collected and processed, for a period based on business needs and legal requirements. We retain Personal Data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When Personal Data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
Notwithstanding the duration above mentioned, we may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
-
ACCESS TO OR CHANGE IN YOUR PERSONAL DATA
You may review, correct, update, change, or delete your information at any time. To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Data or Information.
Even after you remove information from the Website, copies of that information may remain viewable elsewhere, to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users.
Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.
-
OTHER WEBSITES
Our Website may contain links to other third party websites, including ‘Buy’ links to third party sites where you can purchase products. Please note that when you click on one of these links, you are entering another website over which we have no control and will bear no responsibility. Often these websites require you to enter your Personal Data. We encourage you to read the privacy statements on all such websites as their policies may differ from ours. You agree that we shall not be liable for any breach of your privacy of Personal Data or loss incurred by your use of these websites. We are not responsible for the privacy policies and/or practices on other sites. This Policy only governs information collected by us.
-
AMENDMENTS TO THE POLICY
We may amend this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we decide to change our Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it. Any changes to our Policy will be communicated through our Website(s) at least ten (10) days in advance of implementation. Users are bound by any changes to the Policy when they continue to use the Website(s) and/or Application after such changes have been first posted.
-
CONTACTING US
If you have any questions about this Policy or the privacy practices of this Website or Application you can contact us at _cel@ibexengineering.com. We will make every effort to resolve your concerns.
-
SECURITY OF DATA
We take reasonable security measures and procedures, and as specified by applicable law, to maintain appropriate physical, technical, and administrative security to help prevent loss, misuse, or unauthorized access, disclosure or modification of Personal Data. While we take these reasonable efforts to safeguard your Personal Data, you acknowledge and agree that no system or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login credentials private. We are not responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your Account via unauthorized password activity.
-
YOUR PRIVACY RIGHTS
You have many rights regarding your personal information. These rights include the following:
-
You have the right to access and know what personal information we process and why.
-
You have the right to rectification if you believe we store wrong or incomplete information about you, such as your name, address, etc.
-
You have the right to be forgotten or the right to erasure where You shall have the right to tell us to permanently erase your personal information from our records. You can do this if you believe there’s no longer any need for us to keep it, or, if you previously have given your permission, you can just decide to withdraw it.
-
You have the right to restrict the processing activities in certain situations. This means we will continue to store your information, but we will temporarily stop any other processing.
-
You have the right to data portability.
-
You have the right to object to the processing of your information.
-
You have the right to withdraw consent. The withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal.
-
If you do not wish us to collect cookies, you may set your browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Website may then be inaccessible or not function properly.
-
You have the right to lodge a complaint with the national supervisory authority.
-
DATA PROTECTION OFFICER
Ibex Engineering Pvt. Ltd. is the controller and processor of data as in accordance with the General Data Protection Regulation (GDPR).
In case of any queries regarding the processing of your Personal Data, or if you wish to exercise any of your rights, please contact our Data Protection Officer at:
[Celine Ross]
This Policy was last updated on July 9, 2019.
Copyright © 2019 Ibex Engineering Pvt. Ltd. All Rights Reserved