c. During your use of the Services, We may collect information to track your behavior and pattern while using Our Services. This is to give You an enhanced and better experience in using the Platform.

 

d. We may collect any information regarding the type of devices used by You to access Our Services through the Platform including but not limited to model, operating system, IP address, browser type, mobile device identifier, geolocation information.

 

e. We use cookies in order to remember your preferences, tracking your interests, facilitating your payment transactions and to provide a customised experience of using the Platform. “Cookies” are small text files that are stored on your computer or other device when You visit certain online pages that record your preferences and actions. Most web browsers automatically accept cookies, but, if You prefer, You can usually modify your browser setting to decline cookies. However, please note that refusing a cookie may limit your access to the Services. Any kinds of cookies may be used in order to provide the access and usage of the Platform in the most efficient manner.

 

f. We may use other tools like Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses first-party cookies to report on user interactions with our web-based services. These cookies store non-personally identifiable information. We may use this information to identify the most popular areas of the Services and how to best present and customize them. We may use the unique identifier of your device for security purposes to track suspicious activity. For instance, if We detect that your account is being accessed from multiple devices, We may contact You to ensure that You have authorized such access. Under no circumstance will your email address, password and any financial data be collected by or shared with Google Analytics. For more information about how Google handles technical information, please visit the site, “How Google uses data when You use our partners’ sites or apps", (located at: www.google.com/policies/privacy/partners). Provided that the privacy policy of google shall be in addition to but not in derogation to any of the clauses of this Privacy Policy.

 

g. By providing your email and phone number to us, You are authorizing us, Our representatives and our partners to communicate with You through various modes like call, email to offer You Our Services opted by You, marketing material about Services, promotional offers offered by Our Platform. Irrespective of the fact that You have registered yourself under Do Not Disturb (“DND”) or Do Not Call (“DNC”) service, You are still authorizing us, Our representatives and Our partners to communicate with You for the abovementioned purposes. There is no DNC check required for a number You leave on Our Platform or with Our agents. If You wish to opt-out receiving such communication from Us You can do so by sending Us an e-mail at vamsieco@sterlinggoc.com.

 

h. If You send Us personal correspondences, such as emails or letters, or if other users or third parties send Us correspondence about your activities or postings on the Platform, We may collect such information into a file specific to You.

 

i. If You telephone Us, We may also record and/or monitor calls for quality checks and staff training. Such recordings may also be used to help Us combat fraud.

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3. Our Policy concerning children

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a. We will not knowingly solicit or collect personal data from children below the age of (18) in India (and children in other countries as per the age of majority prevalent in such country as per the applicable laws of each country) (“Child/Children”). However, We may collect personal data about Children from the parent or guardian directly, and with that person's consent. For the purposes of accessing this Platform, We will assume that any Child is accessing/using the Platform under parental guidance and supervision.

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4. Disclosure and Sharing of Personal Information

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a. We will keep your Personal Information confidential and only share it with others for the purposes explained in this Privacy Policy. We have trusted relationships with carefully selected banking and financial entities (whose service We avail) or other third parties (who perform services on Our behalf), some of which may be located within or outside of India. Examples of service providers we use are payment processors, email service providers and providers of hosting services. All service providers are required to maintain the security of your Personal Information and to use it only as permitted by Us and they must comply with the security practices and procedures as maintained by Us as set out in this Privacy Policy.​

 

b. Disclosure of Information. Under no circumstance will We sell or rent your Personal Information to anyone, for any reason, at any time. We use authorized third party service providers who are bound by the same standards of data security practices and procedures as We are under law and contract. They are subject to the same penalties as We are for the unauthorized disclosure of your Personal Information. However, under Indian law, We remain liable to You, Our customer, for any unauthorised disclosure of your Personal Information. We shall not be responsible for any Personal Information shared to Third Party Sites by your access or usage of such Third Party Sites. Please go through the privacy policies of such Third Party Sites as may be redirected / linked to our Platform.

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c. We may share your Personal Information:

i. to transfer data, personal information etc. with any banking or financial entity or third party firm.

ii. to analyze usage of the Platform or to improve the same.

iii. to send communications related to the Products.

iv. in relation to research, to effectively control against error, fraud or other criminal activity.

v. to enforce Our T & C.

vi. to any person who has told Us and who We reasonably believe to be your parent, carer or helper where You are unable to handle your own affairs because of mental capacity, being a minor or other similar issues.

vii. to any person to whom We sell or transfer (or enter into negotiations to sell or transfer) or with whom We merge Our business or any of Our rights or obligations under any agreement We may have with You. If the merger, transfer or sale consummates, the transferee or purchaser may use your Personal Information in the same way as Us.

viii. to regulators, ombudsmen or other authorities, including tax authorities, including those overseas, where We are requested by them to do so.

ix. to other Government/regulatory authorities, as may be required under applicable laws.

 

d. The Personal Information shared by You may be used to perform background checks on your identity and your fitness to avail the access and usage offered by Us on the Platform.

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5. Security Precautions

 

a. Security measures (physical, electronic and managerial) are in place to protect You against the loss, misuse, and alteration of the Personal Information under Our control. We store Personal Information in encrypted form on computers and control access via secure web pages. We employ firewalls and other security technologies to protect Our servers from external attack. Access to the Platform’s server is restricted to authorized personnel and shared with employees strictly on a ‘need to know basis’. We shall also promptly notify You if any security breach is made known to Us in relation to unauthorized access to your Personal Information.

 

b. Our security systems meet or exceed industry standards and We are constantly monitoring internet developments to ensure Our systems evolve as required. However, while We strive to use commercially acceptable means to protect your Personal Information, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, by using this Platform, You agree that We will have no liability for disclosure of your Personal Information due to errors in transmission, infrastructure failures by Us or any intermediary (including telecom and internet service providers), or unauthorized acts of third parties.

 

 

6. Opting Out

 

a. We will generally retain your Personal Information for as long as needed to fulfill the purpose of the Personal Information as specified herein. If You change your mind, and don’t wish to remain on Our contact list, just let Us know at vamsieco@sterlinggoc.com

 

b. You may at any time opt-out from receiving mails relating to such surveys/competitions emailing Us at vamsieco@sterlinggoc.com. In addition, whenever We send You a non-essential email communication, You can optout of similar future mailings by simply clicking on a link provided in the e-mail message.

 

c. As part of the registration process, We ask You whether We may contact You about Our Products by telephone, post, email and SMS (or other reasonable method). If You ticked “yes” but no longer wish to receive such communications, please contact Us on vamsieco@sterlinggoc.com.

 

d. You have the right to withdraw your consent to Our Use of your Personal Information at any time where We rely on your consent to use or process that information by sending an email to <insert e-mail address>.  In such case, the Platform may not be in a position to provide the Services to You.

 

 

7. Grievance Officer

 

a. In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below in the event You have any questions or complaints regarding Our Privacy Policy or practices:

 

Name of Grievance Officer: Anurag Banerjee

E-mail of Grievance Officer: grievance@sterlinggoc.com

 

We are committed to providing a first response within 36 hours of receiving the complaint, and We aim to resolve all complaints within 30 (thirty) business days. Any delay in the resolution time shall be proactively communicated to You. If You do not hear back from Us within a week’s time, please do write to Us at vamsieco@sterlinggoc.com for escalation of your specific complaint to the relevant grievance redressal officer.

 

 

8. Our Legal Obligations

 

a. This Privacy Policy is published on the Platform in compliance with Regulation 4 of the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

 

b. We are bound by the (Indian) Information Technology Act, 2000, and comply with all its provisions available at https://meity.gov.in/content/information-technology-act-2000. Under Section 43A of the (Indian) Information Technology Act, 2000, The Platform and all its service providers are obliged to maintain reasonable security procedures to safeguard your Personal Information. Should there be any accidental disclosure of your Personal Information, You have the right to claim compensation from Us.

 

c. Under Regulation 5 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, We are obliged to provide every user of the Platform with a readable copy of the Personal Information You have provided us. If You require a copy, do get in touch with Us at vamsieco@sterlinggoc.com.

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9. Your rights

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a. Handling information: If You would like to correct, update or amend the information provided to Us, you may login and update Your Account on the Platform. However, we may not be able to provide whole of our Services in such event.

 

b. Deletion request: Subject to certain conditions, You may avail Your right to be forgotten/ deletion of Your Personal Information. Availing this right may impact Your ability to obtain access and use our Platform and Services.

 

c. Request for more information: You may have the right to request for the following more information:

i. Confirmation whether Vamsi Eco is processing or has processed Your Personal Information and/ or summary thereof encompassing the details of such Personal Information being processed or has been processed;

ii. The nature and categories of Your Information collected by Us;

iii. The purposes/ basis for which Your Personal Information is to be processed;

iv. The period for which Your Personal Information is retained;

v. The right to withdraw consent and procedure for the same;

vi. The procedure to for grievance redressal;

vii. The third parties with whom We have shared Your Personal Information with and categories of such Personal Information shared; and/ or

viii. Consequences for the failure to provide the aforementioned information.

 

d. Mode to exercise your rights: To submit a request to exercise these rights You may contact us by: (i) WhatsApp - 919051387404 and / or (ii) Email: vamsieco@sterlinggoc.com .

Any capitalized terms not defined herein shall have the meanings ascribed to it under the Terms and Conditions.