Privacy policy

1. INTRODUCTION:

1.1. We respect your privacy rights and recognize the importance of secure transactions and information privacy. This Privacy Policy describes how Navsons Global Private Limited and its affiliates (hereinafter referred as “PiNmates”, collect, use, share or otherwise process your personal information through PiNmates website www.pinmates.in, its PiNmates Mobile application, (hereinafter referred to as the “Platform”).

1.2. This Privacy Policy is an electronic agreement formed under the Information Technology Act, 2000 and the rules and regulations made there under (as amended till date) including the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 & the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021. It does not require any physical or digital signatures to make the terms of this policy binding. This privacy policy is a legally binding document. The terms of this privacy policy will be effective upon your use of our Platform /service. Please read this policy carefully, together with our Terms of Services https://www.pinmates.in/privacy.html

1.3. By visiting our Platform, providing your information or availing our product/service, you expressly agree to be bound by the terms of this Privacy Policy and the applicable Terms of service. While accessing or using our platform/services, you have given explicit consent to collect, use, share or otherwise process your information in accordance with this Privacy Policy. If you do not agree, please do not access or use our Platform or service.

1.4. You acknowledge that you are disclosing Personal Information voluntarily. Prior to the completion of any registration process on our platform or prior to availing of any services offered on our platform if you wish not to disclose any Personal Information you may refrain from doing so; however, if you don’t provide information that is requested, it is possible that the registration process would be incomplete and/or you would not be able to avail of our services. If you are our corporate customer, it is possible that we have entered into a contract with you for non-disclosure of confidential information. This Policy shall not affect such a contract in any manner.

2. APPLICATION OF POLICY:

2.1. This policy governs each website, mobile site, application, and/or other service, regardless of how distributed, transmitted, published, or broadcast (“Service”) provided by Navsons Global Private Limited, which is binding on all those who access, visit and/or use PiNmates Services. This policy shall apply equally to all of our vendors, service providers, subcontractors, partners, agents, representatives, employees, and any other third parties. PiNmates undertakes to only collect and use personal data voluntarily provided by you. You are able to browse our platform without disclosing any personal information about them. However, you have to provide limited personal data to us, as may be required, in order to register or to avail certain services from us.

2.2. This policy applies to all contractors, suppliers, customers, users, vendors, sellers, partners, and other third party working on behalf of PiNmates or accessing or using our platforms/service. It also applies to the head office, branches office and other offices of PiNmates and all employees/officials of PiNmates. It applies to all data that PiNmates holds relating to identifiable individuals, even if that information technically falls outside of the Privacy & Data Protection law. The said information includes, Names, address, mobile/telephone numbers, email Id of users and any other information collected or received by users while accessing or using our platforms/service.

2.3. This Privacy Policy is part of PiNmates Terms of Service and covers the treatment of user information, including personally identifying information, obtained by PiNmates, including information obtained when you access the PiNmates platform, use the PiNmates Service or any other software provided by PiNmates. Unless otherwise stated explicitly, this Policy applies to Personal Information as disclosed on any of our Platform. This policy does not apply to the practices of organizations that we do not own or to people that we do not employ or manage.

3. OBJECTIVES OF POLICY:

3.1. PiNmates is required to collect & use certain information about individuals, i.e., customers, suppliers/vendors, business contacts, employees, and the third parties with whom PiNmates has a business relationship or may need to contact. This policy describes, how PiNmates collects, receives, possesses, stores, deals or handle personal information including sensitive personal information about you and ensure that the same are available for review by you. The personal information must be collected, handled and stored to meet the data protection standards as well as legislative requirements. This policy ensures to comply with data protection law and follows the good practice and protects the rights of employees, customers, suppliers/vendors, business contacts, employees, and the third parties and how to stores and processes data and protects from the risks of data breach.

4. COLLECTION OF INFORMATION:

We communicate with you through a variety of means and channels, including our Platform, email, phone or text messaging on your mobile phone, such communications may involve giving to you, as well as receiving information from you. We collect and receive the Personal Information in the following ways:

4.1. From you directly and through the PiNmates Application: We may collect information through the Website and PiNmates Application when you visit. The data we collect depends on the context of your interactions with our website.

4.2. Through business interaction: We may collect information through business interaction with you or your employees.

4.3. From other sources: We may receive information from other sources, such as public databases; joint marketing partners: social media platforms: or other third parties such as:

5. Type of Information Collected by PiNmates:

5.1. USER

5.1.1. Personal Identifying information such as name, address and phone numbers; email Id, Age, personal description, profile photograph etc., & delivery address,

5.1.2. location information.

5.1.3. Device information.

5.1.4. IP address.

5.1.5. Content of reviews and e-mails to us.

5.2. VENDORS/SELLERS

5.2.1. Personal Identifying information such as name, address and phone numbers; email Id, Age, personal description, profile photograph, Marital status etc.

5.2.2. payment information.

5.2.3. location information.

5.2.4. IP address.

5.2.5. content of reviews and e-mails to us.

5.2.6. images, and other content collected or stored in connection with our Services.

5.2.7. information and officially valid documents (KYC) regarding identity and address information, including mobile & landline number, place of business, valid Email id, vendor’s photo, id & address proof (such as Aadhar card, Pan Card, GST Voter Id Card, Passport, Shop and Establishment Certificate, etc…

5.2.8. corporate and financial information, and

5.2.9. device log files and configurations etc.

5.3. AUTOMATIC INFORMATION

5.3.1. IP address of your device connected to our platform.

5.3.2. Login details, e-mail address, and password, device log files etc.

5.3.3. location of device/computer.

5.3.4. content interaction information, network details etc…

5.3.5. device metrics, application usage, connectivity data, and any errors or event failures.

5.3.6. our Services metrics, any technical errors, interactions with our service features and content, settings preferences and backup information, location of device, file name, dates, times etc. while using our service.

5.3.7. content use history.

5.3.8. URLs including date & time; products & contents viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information etc.

5.3.9. Images/videos while visiting our platforms.

5.3.10. device identifiers, cookies, browsing history, usage history, and/or other technical information.

6. PINMATES DOESN’T COLLECT THE INFORMATION:

6.1. PiNmates does not collect sensitive personal data or information. It only collects the sensitive personal data or information which is considered necessary to provide the service or to fulfil the purpose and for a lawful purpose connected with a function or activity of PiNmates. User can continue to browse / search on PiNmates platform without giving any information.

6.2. PiNmates does not collect emails, addresses or other contact information from your mobile address book or contact lists and name and mobile phone numbers. PiNmates does not store historical location information in any form or manner at its end, except for last known location from which PiNmates software was accessed in case of non-availability of current location data.

6.3. While collecting information, PiNmates ensures that you must be informed about (a) the fact that the information is being collected; (b) the purpose for which the information is being collected; (c) the intended recipients of the information; and (d) the name and address of (i) the agency that is collecting the information; and (ii) the agency that will retain the information.

6.4. The data/information shall not be collected unless-(a) you have provided a valid, informed & free consent; (b) processing is necessary for the performance of a contract to which you are party; (c) processing is necessary for compliance with the company legal obligation; (d) processing is necessary in order to protect your interests; or (e) processing is necessary for the performance of a task carried out in the public interest.

7. USAGE OF INFORMATION:

7.1. The data/information collected shall be used for the purpose for which it has been collected. In addition, the PiNmates uses the data for the following purposes:

7.1.1. To provide services.

7.1.2. To fulfill your requests for products and services and communicate with you about those requests.

7.1.3. To administer contests, promotions, and surveys.

7.1.4. To respond to reviews, comments, or other feedback you provide us.

7.1.5. To help us personalize our service offerings, PiNmates Mobile Application, PiNmates Website, and advertising.

7.1.6. To provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the Services.

7.1.7. To recommend features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with PiNmates Services.

7.1.8. To operate, provide, develop, and improve the products and services that we offer our customers.

7.1.9. To provide our services and to support our core business functions. These include order or service fulfilment, internal business processes, marketing, authentication, loss and fraud prevention, public safety and legal functions.

7.1.10. To display interest-based ads for features, products, and services that might be of interest to you.

7.1.11. To prevent and detect fraud and abuse in order to protect the security of our customers, PiNmates, and others.

7.1.12. Communicate with you.

7.1.13. Contacting with you for promoting services.

7.1.14. The User’s Personal Data may be used for legal purposes by PiNmates in legal proceeding at the stages leading to possible legal action arising from improper use of PiNmates services.

7.1.15. For operation and maintenance purposes

7.1.16. It helps us in operating, providing, improving, understanding, customizing, supporting, and marketing our Services.

7.1.17. Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws. For instance, we may collect from seller’s information regarding place of establishment and bank account information for identity verification and other purposes.

7.2. Personal Information will be kept confidential and will be used for our research, marketing, and strategic client analysis objectives and other internal business purposes only. If you are a customer of our services, your Information shall be shared with our subscribers/advertisers, and you have given consent to the same. Further, the subscribers / advertisers who are listed with us, may call you, based on the query or enquiry that you make with us, enquiring about any Product / Service or Product / Service of any subscriber / advertiser. If you are a vendor/seller/business entity availing our services, your information shall be shared with our users, customers, callers, subscribers/advertisers who are seeking our services. You are hereby giving us the consent to share the details.

7.3. We use your personal information to assist vendors, service providers, and business partners in handling and fulfilling orders; enhancing customer experience; resolve disputes; troubleshoot problems; help promote a safe service; collect money; measure consumer interest in our products/services; inform you about offers, products, services, and updates; customize and enhance your experience; detect and protect us against error, fraud and other criminal activity; enforce our terms and conditions; and as otherwise described to you at the time of collection of information.

7.4. With your consent, we will have access to your, location and device information. (i) issue GST invoice for the products and services purchased for your business requirements; (ii) enhance your experience on the Platform and provide you access to the products and services being offered by us, vendors, sellers, service providers, affiliates or lending partners. You understand that your access to these products/services may be affected in the event consent is not provided to us.

7.5. In our efforts to continually improve our product and service offerings, we and our affiliates collect and analyse demographic and profile data about our users’ activity on our Platform. We identify and use your IP address to help diagnose problems with our server, and to administer our Platform. Your IP address is also used to help identify you and to gather broad demographic information.

7.6. We have arrangement with other companies and individuals to perform functions for examples include analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments and providing customer service etc. They have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Policy and as permitted by applicable law. In certain cases, we collect and use your personal information to comply with laws. For instance, we collect from vendors/seller’s information regarding place of establishment and bank account information for identity verification and other purposes.

7.7. If you submit Personally Identifiable Information to us through the PiNmates platform, or PiNmates Service, then we use your personal information to operate, maintain, and provide to you the features and functionality of the PiNmates platform and PiNmates Service. In particular, your mobile phone number is essential to your use of the PiNmates Service and will be retained.

7.8. You have given your consent to use your mobile phone number or other Personally Identifiable Information to send commercial or marketing messages without your consent or except as part of a specific program or feature for which you may have the ability to opt-in or opt-out. We may use cookies and log file information to (a) remember information so that you will not have to re-enter it during your re-visit on our platform; (b) provide custom, personalized content and information; (c) monitoring or pages viewed, etc.; and (d) track your entries, submissions, views etc.

8. PROCESSING OF PERSONAL INFORMATION:

8.1. Personal/Sensitive personal data may be processed if such processing is necessary, for any function of Parliament or any State Legislature and/or for the exercise of any function of the State authorised by law for the provision of any service or benefit to the data principal from the State; or the issuance of any certification, license or permit for any action or activity of the data principal by the State.

8.2. Personal data/Sensitive personal data may be processed if such processing is (a) explicitly mandated under any law made by Parliament or any State Legislature; or (b) for compliance with any order or judgment of any Court or Tribunal in India.

8.3. Personal data/Sensitive personal data may be processed if such processing is necessary— (a) to respond to any medical emergency involving a threat to the life or a severe threat to the health of the data principal or any other individual; (b) to undertake any measure to provide medical treatment or health services to any individual during an epidemic, outbreak of disease or any other threat to public health; or (c) to undertake any measure to ensure safety of, or provide assistance or services to, any individual during any disaster or any breakdown of public order.

8.4. Personal data may be processed if such processing is necessary for— (a) recruitment or termination of employment of a data principal; (b) provision of any service to, or benefit sought by, the data principal; (c) verifying the attendance of the data principal; or (d) any other activity relating to the assessment of the performance of the data principal.

8.5. In addition to the grounds for processing contained aforesaid, personal data may be processed if such processing is necessary for such reasonable purposes as may be specified after taking into consideration— (a) the interest of PiNmates in processing for that purpose; (b) whether PiNmates can reasonably be expected to obtain the consent of the data principal; (c) any public interest in processing for that purpose; (d) the effect of the processing activity on the rights of the data principal; and (e) the reasonable expectations of the data principal having regard to the context of the processing.

8.6. The reasonable purposes mean and includes, prevention and detection of any unlawful activity including fraud; whistle blowing; mergers and acquisitions; network and information security; credit scoring; recovery of debt; processing of publicly available personal data. However, PiNmates ensures the protection of the rights of data principals.

9. PROCESSING OF PERSONAL DATA OF CHILDREN:

9.1. PiNmates doesn’t allow children below the age of 13 years to visit our platform without parental guidance or control. Based on your date of birth disclosed by you, we verify your age. When the children visit our platform or use our service, we believe that they access our platform or service under the parental guidance, control and consent and we can process the information accordingly. PiNmates shall process personal data of children in a manner that protects the rights and best interests of the child.

10. DISCLOSURE OF INFORMATION:

10.1. Other users of PiNmates Service may see your ratings submissions in a way that is consistent with the use of the PiNmates Service.

10.2. We sell and share your Personally Identifiable Information (such as mobile phone number) with other third-party companies for their commercial or marketing. We don’t not sell or share confidential information with third party like your Atm Debit Card/ Credit Card Number, PIN, Aadhar No, etc.

10.3. We may disclose your personal information to third parties, such as vendors, sellers, service providers, business partners and other stakeholders. This disclosure may be required for us to provide you access to our products and services; for fulfilment of your orders; for enhancing your experience; for providing feedback on products; to collect payments from you; to comply with our legal obligations; to conduct market research or surveys; to enforce our Terms of Use; to facilitate our marketing and advertising activities; to analyse data; for customer service assistance; to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our product and services, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data and links (including paid listings and links), processing payments, transmitting content, scoring, assessing and managing credit risk, and providing customer service. These third-party service providers may have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with applicable law.

10.4. We share information with our affiliated companies, business partners, associates etc. with whom we are having an arrangement to provide/receive services. We may use the information we receive from them, and they may use the information we share with them, to help operate, provide, improve, understand, customize, support, and market our Services and their offerings. This includes helping improve infrastructure and delivery systems, understanding how our Services or theirs are used, securing systems, and fighting spam, abuse, or infringement activities and promoting, marketing of business.

10.5. As we continue to develop our business, we might sell or buy other businesses or services. In such cases, all of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or third party while providing the services subject to the pre-existing Privacy policy.

10.6. We may disclose personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to: (a) respond to subpoenas, court orders, or other legal process or to government/ law enforcement agencies requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our users, companies, or others. (e) for purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences.

10.7. We disclose the account and other personal information when we believe such disclosure is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of PiNmates, our users, or others. This includes exchanging information with other companies and organizations for fraud protection.

10.8. PiNmates shall share/disclose the data/information, without obtaining prior consent from You, with Government agencies mandated under the law to obtain information including sensitive personal data or information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences.

11. TRANSFER OF INFORMATION:

11.1. PiNmates shall not transfer sensitive personal data or information including any information, to third parties in India, or outside India, except under the following circumstances:

11.1.1. To fulfill your requests for products and services

11.1.2. To fix errors, and improve the usability and effectiveness of the Services

11.1.3. To fraud prevention, public safety and legal functions

11.1.4. To prevent and detect fraud and abuse in order to protect the security of our customers, PiNmates, and others

11.1.5. It is necessary for the performance of the lawful contract between PiNmates and data principal; or

11.1.6. where data principal has consented to data transfer;

11.2. However, PiNmates ensures the same level of data protection that is adhered to by them as that of the PiNmates.

11.3. When using vendors to collect personal information on the behalf of PiNmates, it shall ensure that the vendors comply with the data protection requirements of PiNmates as defined in this Policy.

12. RETENTION OF YOUR INFORMATION:

12.1. The personal information may only be used for the purposes identified in the Terms of Services (the “TOS”) and only if you have given consent. Personal information shall be retained for as long as necessary for business purposes identified in the TOS at the time of collection or subsequently authorized by you. We retain your personal information in accordance with applicable laws, for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. However, we may retain data related to you if we believe it may be necessary to prevent fraud or future abuse or if required by law or for other legitimate purposes.

12.2. When the use of personal information is no longer necessary for business purposes, a method shall be in place to ensure that the information is destroyed in a manner sufficient to prevent unauthorized access to that information or is de-identified in a manner sufficient to make the data non-personally identifiable. PiNmates shall have a documented process to communicate changes in retention periods of personal information required by the business to you who are authorized to request those changes.

12.3. PiNmates holding sensitive personal data or information shall not retain that information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.

12.4. Personal information shall be erased if their storage violates any of the data protection law or if knowledge of the data is no longer required by PiNmates or for the benefit of the data providers. Additionally, PiNmates has the right to retain the personnel information for legal and regulatory purpose as per applicable laws.

13. REVIEW OF INFORMATION BY YOU:

13.1. PiNmates shall establish & facilitates a mechanism to enable you to review the data/information you had provided, as per your choice, and shall access, edit, rectify, modify, delete any personal information or sensitive personal information found to be inaccurate or deficient. However, PiNmates shall not be responsible for the authenticity of the personal information or sensitive personal information supplied by you.

14. YOUR CONSENT:

14.1. By visiting our Platform or by providing your information, you consent to the collection, use, storage, disclosure and otherwise processing of your information (including sensitive personal information) on our Platform in accordance with this Privacy Policy. If you disclose to us any personal information relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. You, while providing your personal information over our Platform or any of our partner Platform or establishments, consent to us (including our affiliates, lending partners, technology partners, marketing channels, business partners, vendors, service providers and other third parties) to contact you through SMS, instant messaging apps, call and/or e-mail for the purposes specified in this Privacy Policy.

14.2. If you want to manage, change, or edit your information, we allow you to do so through the Settings tools: You can change your settings to manage certain information available to other users.

14.3. You can add or update your Personal Information on regular basis. PiNmates would retain your previous Personal Information in its records.

14.4. You may, of course, decline to submit Personally Identifiable Information through the PiNmates Service, in which case PiNmates may not be able to provide certain services to you. If you do not agree with our Privacy Policy or Terms of Service, please delete your account and uninstall the PiNmates mobile application; your continued usage of the PiNmates Service will signify your assent to and acceptance of our Privacy Policy and Terms of Service. To protect your privacy and security, we take reasonable steps (such as SMS authentication in certain cases) to verify your identity before registering your mobile phone number and granting you access to the PiNmates Service. Please contact PiNmates via email to support@pinmates.in or available web forms with any questions or comments about this Privacy Policy.

15. THIRD-PARTY ADVERTISERS, LINKS TO OTHER SITES:

15.1. PiNmates shall not be responsible for its Partner’s privacy practices or the content of their privacy policies, and we request you to read their privacy policies prior to disclosing any information.

16. CHILDREN INFORMATION

16.1. We do not knowingly solicit or collect personal information from children under the age of 13 and use of our Platform is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are under the age of 18 years then you must use our Platform or services under the supervision of your parent, legal guardian or any responsible adult.

17. OUR COMMITMENT TO INFORMATION SECURITY:

17.1. The security of your Personal Information is important to us. You are responsible for keeping your device and your account safe and secure, and you must notify us promptly of any unauthorized use or security breach of your account or our Services. Your account information is protected by the password you use to access your online account. Please keep this password confidential. PiNmates uses commercially reasonable physical, managerial, and technical, electronic and procedural safeguards to preserve the integrity and security of your personal information. PiNmates shall adopt reasonable security practices and procedures as mandated under applicable laws for the protection of your Information. For this purpose, PiNmates adopts internal reviews of the data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where PiNmates stores your Personal Information. We cannot, however, ensure or warrant the security of any information you transmit to PiNmates and you do so at your own risk and you hereby waive and release PiNmates from any claim of damages under contract.

17.2. PiNmates may share your Information with third parties. However, PiNmates is not responsible for any breach of security or for any actions of any third parties that receive your Personal Information. PiNmates is not liable for any loss or injury caused to you as a result of you providing your Personal Information to third party (including any third-party websites, even if links to such third-party websites are provided on the Website). Notwithstanding anything contained in this Policy or elsewhere, PiNmates shall not be held responsible for any loss, damage or misuse of your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event. A “Force Majeure Event” shall mean any event that is beyond the reasonable control of PiNmates and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided beyond reasonable control of PiNmates), power or electricity failure or unavailability of adequate power or electricity.

17.3. While we will endeavour to take all reasonable and appropriate steps to keep secure any Personal Information which we hold about you and prevent unauthorized access. You acknowledge that the internet or computer networks are not fully secure and that we cannot provide any absolute assurance regarding the security of your Personal Information. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, processing, and disclosure of personal information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

17.4. We maintain reasonable physical, electronic and procedural safeguards to protect your information. Whenever you access your account information, we offer the use of a secure server. Once your information is in our possession, we adhere to our security guidelines to protect it against unauthorized access. However, by using our platform, you accept the inherent security implications of data transmission over the internet which cannot always be guaranteed as completely secure, and therefore, there would always remain certain inherent risks regarding use of the Platform. You are responsible for ensuring the protection of login & password records for their account. You hereby waive and release PiNmates from any claim of damages under contract.

17.5. We work to protect the security of your data/information including sensitive personal data during transmission by using encryption protocols and software. If you choose a payment gateway to complete any transaction on PiNmates Platform then your credit/debit card data/financial details may be stored in Payment Gateway server and not on the Platform.

18. TRANSPARENCY & ACCOUNTABILITY MEASURES:

18.1. PRIVACY BY DESIGN:

18.1.1. PiNmates shall implement policies and measures to ensure that managerial, organisational, business practices and technical systems are designed in a manner to anticipate, identify and avoid harm to you;

18.1.2. PiNmates shall implement policies and measures to ensure that the technology used in the processing of personal data is in accordance with commercially accepted or certified standards;

18.1.3. PiNmates shall implement policies and measures to ensure that the legitimate interest of businesses including any innovation is achieved without compromising privacy interests;

18.1.4. PiNmates shall implement policies and measures to ensure that privacy is protected throughout processing from the point of collection to deletion of personal data and processing of personal data is carried out in a transparent manner and the interest of the data provider is accounted for at every stage of processing of personal Data.

18.2. SECURITY SAFEGUARDS:

18.2.1. Having regard to the nature, scope and purpose of processing personal data undertaken, the risks associated with such processing, and the likelihood and severity of the harm that may result from such processing, PiNmates shall implement appropriate security safeguards including (a) use of methods such as de-identification and encryption; (b) steps necessary to protect the integrity of personal data; and (c) steps necessary to prevent misuse, unauthorised access to, modification, disclosure or destruction of personal data. PiNmates shall undertake a review of its security safeguards periodically as may be specified and may take appropriate measures accordingly.

18.3. PERSONAL DATA BREACH:

18.3.1. PiNmates shall notify the Authority of any personal data breach relating to any personal data processed by PiNmates where such breach is likely to cause harm to any data principal. The said notification includes, (a) nature of personal data which is the subject matter of the breach; (b) number of data principals affected by the breach; (c) possible consequences of the breach; and (d) measures being taken by the data fiduciary to remedy the breach.

19. MONITORING AND ENFORCEMENT:

19.1. DISPUTE RESOLUTION & RECOURSE:

19.1.1. It shall define a process to register all the incidents/complaints and queries related to data breach. PiNmates shall perform a periodic review of all the complaints related to data breach to ensure that all the complaints are resolved in a timely manner and resolutions are documented and communicated to the data principals.

19.1.1.1. An escalation process for unresolved complaints and disputes which shall be designed and documented and the Communication of privacy incident / breach reporting channels and the escalation matrix shall be provided to all data providers.

19.2. DISPUTE RESOLUTION & ESCALATION PROCESS FOR EMPLOYEES:

19.2.1. Employees with enquiries or complaints about the processing of their personal information shall first discuss the matter with their immediate reporting manager. If the employee does not wish to raise an inquiry or complaint with their immediate reporting manager, or if the manager and employee are unable to reach a satisfactory resolution of the issues raised, the employee shall bring the issue to the attention of the Grievance Officer.

19.3. DISPUTE RESOLUTION & ESCALATION PROCESS FOR CUSTOMER / THIRD PARTY:

19.3.1. Customers / Third Party with inquiries or complaints about the processing of their personal information shall bring the matter to the attention of the Grievance Officer in writing. Any disputes concerning the processing of the personal information of non-employees shall be resolved through arbitration.

19.4. TERMS OF USE, POLICY & REVISIONS:

19.4.1. If you choose to use PiNmates Services, your use and any dispute over privacy is to this policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the prevailing law in India. If you have any concern about privacy at PiNmates, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly and our Privacy policy will change also. You should check our websites frequently to see recent changes.

19.4.2. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We assure that will never materially change our policies and practices to make them less protective of your information collected in the past without your consent.

19.5. GRIEVANCE OFFICER:

19.5.1. In accordance with Information Technology Act 2000 and rules & regulations made thereunder, the name and contact details of the Grievance Officer are provided below:
Name: Naveen Panchal
Address: E-44/3, First floor, Okhla Industrial Area Phase-II, New Delhi, India, 110020 (Email: naveen@pinmates.in )

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