PRIVACY POLICY
We, Wiinnova
Software Labs Pvt Ltd Ôhttps://www.wiinnova.com/Õ and Mobile Application ÔLamboÕ
(together referred to as the ÒPlatformÓ) which is owned and operated by M/s.
Wiinnova Software Labs Private Limited, (hereinafter referred to as the ÒCompanyÓ) having its registered office at #1516, 5th Floor, HiLite
Business Park, HiLite City, Calicut – 673 014, Kerala, India represented
by its members, where such expression shall, unless
repugnant to the context thereof, be deemed to include its respective legal
heirs, representatives, administrators, permitted successors and assigns. The
creator of this Privacy Policy ensures steady commitment to your privacy with
regard to the protection of your invaluable information. This privacy policy
contains information about a Mobile Application called ÒLamboÓ (referred to as the ÒPlatformÓ). In order to provide you with our
uninterrupted use of services, we may collect and, in some circumstances,
disclose information about you with your permission. To ensure better
protection of your privacy, we provide this notice explaining our information collection
and disclosure policies, and the choices you make about the way your
information is collected and used.
This Privacy Policy shall be in
compliance with the General Data Protection Regulation (GDPR) in effect from
May 25, 2018 and any and all provisions that may read to the contrary shall be
deemed to be void and unenforceable as of that date. If you do not agree with
the terms and conditions of our Privacy Policy, including in relation to the
manner of collection or use of your information, please do not use or access
the Site. If you have any questions or concerns regarding this Privacy Policy,
you should contact our Customer Support Desk at support@wiinnova.com
In this Privacy Policy ÒDataÓ refer to whatever data
you use our services to collect, whether it is portfolio information, trading
formation or data inserted on a site hosted by us itÕs all your data which is
reference to personal information or just information, means information about
you personally that we collect or for which we act as custodian.
ANY CAPITALIZED WORDS USED HENCEFORTH SHALL HAVE THE
MEANING ACCORDED TO THEM UNDER THIS AGREEMENT. FURTHER, ALL HEADING USED HEREIN
ARE ONLY FOR THE PURPOSE OF ARRANGING THE VARIOUS PROVISIONS OF THE AGREEMENT
IN ANY MANNER. NEITHER THE USER NOR THE CREATERS OF THIS PRIVACY POLICY MAY USE
THE HEADING TO INTERPRET THE PROVISIONS CONTAINED WITHIN IT IN ANY MANNER.
1. DEFINITIONS:
a. ÒWeÓ,
ÒOurÓ, and ÒUsÓ shall mean and refer to the creators of this privacy policy.
b. ÒYouÓ,
ÒYourÓ, ÒYourselfÓ, ÒBusiness UserÓ
and ÒUserÓ shall mean and refer to
natural and legal
individuals who use the Platform.
c. ÒPersonal
InformationÓ shall mean and refer to
any personally identifiable
information that we may collect from you. For removal
of any doubts, please refer to Clause 2.
d. ÒThird
PartiesÓ and ÒEnd UserÓ refer to
any website and Mobile Application, company or individual apart from the User
and the creator of this Platform.
2. INFORMATION WE COLLECT
We are committed to respecting your online privacy. We
further recognize your need for appropriate protection and management of any
Personal Information You share with us. At the moment, we do not collect any
personal information from the user.
This privacy policy also applies to data we collect
from users who are not registered on the app, including, but not limited to,
browsing behaviour, pages viewed etc. We also collect, and store personal
information provided by you from time to time on the Site. We only collect and
use such information from you that we consider necessary for achieving a
seamless, efficient and safe experience, customized to your needs including:
a. To enable the provision of services opted for by you;
b. To communicate necessary account and service related
information from time
to time;
c. To comply with applicable laws, rules and regulations;
Where any service requested by you involves a third
party, such information as is reasonably necessary by the Company to carry out
your service request may be shared with such third party.
You may from time to time choose to provide payment
related financial information (credit card, debit card, bank account details,
billing address etc.) on the app. We are committed to keeping all such
sensitive data/information safe at all times and ensure that such
data/information is only transacted over secure Site of approved payment
gateways which are digitally encrypted and provide the highest possible degree
of care available under the technology presently in use. We shall collect and
store all such information in our internal Company servers for a finite period
time, as long as you are a User of the platform and shall immediately delete
all such information upon expiry of your User ship. We shall also delete all
aforementioned communication upon withdrawal of User ship of any single Party
to the communication.
The Company will not use your financial information
for any purpose other than to complete a transaction with you. To the extent
possible, we provide you the option of not divulging any specific information
that you wish for us not to collect, store or use. You may also choose not to
use a particular service or feature on the Site and opt out of any
non-essential communications from the platform.
Further, transacting over the internet has inherent
risks which can only be avoided by you following security practices yourself,
such as not revealing account/login related information to any other person and
informing our customer care team about any suspicious activity or where your
account has/may have been compromised.
At every stage prior to, during or after information
collection, you have the right to access all personally identifiable
information provided, rectify or alter all personally identifiable information
provided, restrict the level of information to be retained as per your sole
discretion and object to the retention, use and potential disclosure of the
personally identifiable information.
3. OUR USE OF YOUR INFORMATION
The information provided by you shall be used to
provide and improve the service for you and all users.
a. Provide Customized tools of Platform development.
b. Provide
gateways to capture data through the Platform.
c. Provide actions for improvement.
d. To operate and improve the site and to create new
services, features and content.
For more details about the nature
of such communications, please refer to our Terms of Service. Further, your
personal data and Sensitive Personal data may be collected and stored by Us for
internal record.
We use Your tracking information such as IP addresses,
and or Device ID to help identify you and to gather broad demographic
information. We will not sell, license or trade Your personal information. We
will not share your personal information with others unless they are acting
under our instructions or we are required to do so by law. Information collected
via Our server logs includes users' IP addresses and the pages visited; this
will be used to manage the web system and troubleshoot problems. We also use
third-party analytics, tracking, optimization and targeting tools to understand
how users engage with our Platform so that we can improve it and cater
personalized content/ads according to their preferences.
4. HOW INFORMATION IS COLLECTED
Before or at the time of collecting personal
information, we will identify the purposes for which information is being
collected. If the same is not identified to you, you have the right to request
the Company to elucidate the purpose of collection of said personal
information, pending fulfilment of which you shall not be mandated to disclose
any information whatsoever.
We will collect and use your personal information
solely with the objective of fulfilling those purposes specified by us, within
the scope of consent of the individual concerned or as required by law. We will
only retain personal information as long as necessary for the fulfilment of
those purposes. We will collect personal information by lawful and fair means
and with the knowledge and consent of the individual concerned.
Personal data should be relevant to the purposes for
which it is to be used, and, to the extent necessary for those purposes, should
be accurate, complete, and up-to-date.
5. COOKIES
We use data collection devices such
as ÒcookiesÓ on certain pages of our
Websites. ÒCookiesÓ are small files sited on your hard drive that assist us in
providing customized services. We also offer certain features that are only available through the use of a ÒcookieÓ. Cookies can also help us provide information,
which is targeted to your interests. Cookies may be used to identify logged in or registered users. Our Website uses session cookies to ensure that you have a
good experience. These cookies contain a unique number, your 'session ID',
which allows our server to recognise your computer and 'remember' what you've
done on the Platform. The benefits of this are:
a.
You only need to log in once
if you're navigating secure areas of the site
b.
Our server can distinguish
between your computer and other users, so you can see the information that you have requested.
You can choose to accept or decline cookies by modifying
your browser settings if you prefer. This may prevent you from taking full
advantage of the Plat Form. We also use various third-party cookies
for usage, behavioral, analytics and preferences data. The following are the
different types of Cookies used on the Platform:
a.
Authentication cookies: To identify the
user and share the content that he or
she requested for.
b.
Functionality cookies: For customized
user experience and resuming past course
progress.
Tracking, optimization
and targeting cookies: To capture usage metric on
device, operating system, browser etc. To capture behavioral metrics for better
content delivery. To cater and suggest most suited products and services.
6. GOOGLE ANALYTICS
We use Google Analytics to help us to understand how
you make use of our content and work out how we can make things better. These
cookies follow your progress through our site, collecting anonymous data on
where you have come from, which pages you visit, and how long you spend on the site.
This data is then stored by Google in order to create reports. These cookies do
not store your personal data.
The information generated by the cookie about your use
of the Website, including your IP address, may be transmitted to and stored by
Google on servers in the United States. Google may use this information for the
purpose of evaluating your use of the website, compiling reports on website
activity for us and providing other services relating to website activity and internet
usage. Google may also transfer this information to third parties where
required to do so by law, or where such third parties process the information
on Google's behalf. Google will not associate your IP address with any other
data held by Google. By using this website, you consent to the processing of
data about you by Google in the manner and for the purposes set out above.
The Google website contains further information about
Analytics and a copy of Google's privacy policy pages.
7. EXTERNAL
LINKS ON THE WEBSITE
The Website may include advertisements, hyperlinks to
other websites, applications, content or resources. We have no control
over any websites or
resources, which are provided by companies or persons other than Us. You acknowledge
and agree that we are not responsible for the availability of any such external
sites or resources, and do not endorse any advertising, services/products or
other materials on or available from such platform or resources. You
acknowledge and agree that We are not liable for any loss or damage which may
be incurred by you as a result of the availability of those external sites or
resources, or as a result of any reliance placed by you on the completeness,
accuracy or existence of any advertising, products or other materials on, or
available from, such websites or resources. These external websites and
resource providers may have their own privacy policies governing the
collection, storage, retention and disclosure of Your Personal Information that
You may be subject to. We recommend that you enter the external Website and
review their privacy policy.
8. YOUR RIGHTS
We are providing service that allows you to store
and manage crypto trade transactions.
Unless subject to an exemption, you have the following
rights with respect to your personal data:
a. The right to request a copy of your personal data
which we hold about you;
b. The right to request for any correction to any
personal data if it is found to be
inaccurate or out of date;
c. The right to withdraw Your consent to the processing
at any time;
d. The right to object to the processing of personal
data;
e. The right to lodge a complaint with a supervisory
authority.
f. The right to obtain information as to whether personal
data are transferred to a
third country or to an international organization.
Where you hold an account with any of our service, you are entitled to a
copy of all personal data which we hold in relation to you. You are also
entitled to request that we restrict how we use your data in your account when
you log in.
9. CONFIDENTIALITY
You further acknowledge that the Platform may contain
information which is designated confidential by us and that you shall not
disclose such information without our prior written consent. Your information
is regarded as confidential and therefore will not be divulged to any third
party, unless if legally required to do so to the appropriate authorities. We
will not sell, share, or rent your personal information to any third party or
use your e-mail address for unsolicited mail. Any emails sent by us will only
be in connection with the provision of agreed services, and you retain sole
discretion to seek for discontinuation of such communications at any point of
time.
10. OTHER INFORMATION COLLECTORS
Except as otherwise expressly included in this Privacy
Policy, this document only addresses the use and disclosure of information we
collect from you. To the extent that you disclose your information to other
parties, whether they are on our Platform or on other sites throughout the
Internet, different rules may apply to their use or disclosure of the
information you disclose to them. To the extent that we use third party
advertisers, they adhere to their own privacy policies. Since we do not control
the privacy policies of the third parties, you are subject to ask questions
before you disclose your personal information to others.
11. OUR DISCLOSURE OF YOUR INFORMATION
Due to the existing regulatory environment, we cannot
ensure that all of your private communications and other personally
identifiable information will never be disclosed in ways not otherwise
described in this Privacy Policy. By way of example (without limiting and
foregoing), we may be forced to disclose information to the government, law enforcement
agencies or third parties. Therefore, although we use industry standard
practices to protect your privacy, we do not promise, and you should not
expect, that your personally identifiable information or private communications
would always remain private. We do, however assure you that any and all
disclosure of your personally identifiable information shall be personally
intimated to you through an email sent to your provided email address.
As a matter of policy, we do not sell or rent any
personally identifiable information about you to any third party. However, the
following describes some of the ways that your personally identifiable
information may be disclosed:
a.
External
Service Providers: There may be a number of services offered by external
service providers that help you use our Platform. If you choose to use these
optional services, and in the course of doing so, disclose information to the
external service providers, and/or grant them permission to collect information
about you, then their use of your information is governed by their privacy
policy.
b.
Law and
Order: We cooperate with law enforcement inquiries, as well as other third
parties to enforce laws, such as: intellectual property rights, fraud and other
rights. We can (and you authorize us to) disclose any information about you to
law enforcement and other government officials as we, in our sole discretion,
believe necessary or appropriate, in connection with an investigation of fraud,
intellectual property infringements, or other activity that is illegal or may
expose us or you to legal liability.
12. ACCESSING,
REVIEWING AND CHANGING YOUR PROFILE
Following registration, you can review and change the
information you submitted at the stage of registration, except Email ID. An
option for facilitating such change shall be present on the Platform and such
change shall be facilitated by the User. If you change any information, we may
or may not keep track of your old information. We will not retain in our files
information you have requested to remove for certain circumstances, such as to
resolve disputes, troubleshoot problems and enforce our terms and conditions.
Such prior information shall be completely removed from our databases,
including stored Ôback upÕ systems. If you believe that any information we are holding on
you is incorrect or incomplete, or to remove your profile so that others cannot
view it, the User needs to remediate, and promptly correct any such incorrect
information.
13. CONTROL OF YOUR
PASSWORD
When you sign up to become a Member, you will optionally
be asked to choose a password. You are entirely responsible for maintaining the
confidentiality of your password. It is important that you protect it against
unauthorized access of your account and information by choosing your password
carefully and keeping your password and computer secure by signing out after
using our services.
You agree not to use the account, username, email
address or password of another Member at any time or to disclose your password
to any third party. You are responsible for all actions taken with your login
information and password, including fees. If you lose control of your password,
you may lose substantial control over your personally identifiable information
and may be subject to legally binding actions taken on your behalf. Therefore,
if your password has been compromised for any reason, you should immediately
change your password. You agree to notify us immediately if you suspect any
consistent unauthorized use of your account or access to your password even
after changing it.
14. SECURITY
We treat data as an asset that must be protected
against loss and unauthorized access. We employ many different security
techniques to protect such data from unauthorized access by members inside and
outside the Company. We follow generally accepted industry standards to protect
the Personal Information submitted to us and information that we have accessed.
However, as effective as encryption technology is, no
security system is impenetrable. Our Company cannot guarantee the security of
our database, nor can we guarantee that information you provide wonÕt be
intercepted while being transmitted to the Company over the Internet.
15. SEVERABILITY
Each paragraph of this privacy policy shall be and
remain separate from and independent of and severable from all and any other
paragraphs herein except where otherwise expressly indicated or indicated by
the context of the agreement. The decision or declaration that one or more of
the paragraphs are null and void shall have no effect on the remaining
paragraphs of this privacy policy.
16.AMENDMENT
Our Privacy Policy may change from time to time. The
most current version of the policy will govern our use of your information and
will always be at the Platform.
17. AUTOMATED DECISION MAKING
As a responsible company, we do not use automatic
decision-making or profiling.
18.CONSENT WITHDRAWAL, DATA DOWNLOAD & DATA REMOVAL
REQUESTS
To withdraw your consent, or to request the download
or delete of your data with us for any or all our products & services at
any time, please email support@wiinnova.com.
19. CONTACT US
If you have any questions or concerns regarding this
privacy policy, you should contact us by sending an e-mail to
info@wiinnova.com.