This Privacy Notice (the “Notice”) sets out how we, Eugenie Technologies Private Limited , Level 7, Commerz II, International Business Park, Oberoi Garden City, Western Express Highway, Goregaon (E), Mumbai 400 063, India and our affiliates, our subsidiaries & associated offices (collectively “Eugenie”, “we”, “us”, “our”) process the personal data of individuals (each a “User”, “you”, “your”) who contact us or who use our websites, services, programs, content and related features (collectively, the “Services”).
If you have any questions about this Notice, please contact us by support@eugenie.ai
This notice, together with our Website Terms of Use and any other documents referred to in these documents, set out our views and practices regarding your personal data and how we will treat it. Please read these documents carefully. By visiting our website or using our Services, you acknowledge the processing described in this Notice, our Website Terms and related documents.
We will let you know, by posting on our website or otherwise, if we make any changes to this Notice from time to time. Your continued use of the Services after notifying such changes will amount to your acknowledgement of the amended Notice. This version of our privacy notice was published in February 2020.
As described below, your personal data may be collected by Eugenie and all companies wholly or partially owned by it), disclosed to third parties, and used by third parties and Eugenie.
What is personal data?
“Personal data” means any information relating to an identified or identifiable natural person, known as ‘data subject’, who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies, call recording and similar information. It may also include “special categories of personal data” such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health or data concerning a natural person’s sexual orientation.
What personal data do we process?
We may process the following personal data:
a. Information provided by you. You may give us information about you by filling in forms such as the contact form on our website or the Content Download Form, making applications in respect of job postings, corresponding with us by e-mail, phone or otherwise. This information may be your name, mailing address (Iing zip code) email address, employer, job title and department, telephone number and facsimile numbers, the content of any email you send to us and other personal identifying information.
b. Information about others.You may also provide to us personal data relating to third parties, such as people who you work with, reporters and other individuals who comment on markets and news, business actors relevant to your industry and other individuals.
c. Information about your device.With regard to each of your visits to our website we may collect technical information about your device. This information is compiled and analyzed on both a personal and an aggregated basis. This information may Ie the Web site’s Uniform Resource Locator (“URL”) that you just came from, Ih URL you go to next, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the World Wide Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.
d. Information from third party sources.This may include information received from our service providers and other third parties providing us with your information which is publically available or collected by them.
Generally, you are under no obligation to provide this information, but without it, we may be unable to provide you with some of our Services. Some personal data will be mandatory in order for us to comply with mandatory client due diligence processes before we are able to provide the Services.We do NOT collect sensitive personal data of website users such as financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history and biometric information.Information about third parties should only be provided if you have demonstrable permission to do so or if the information is available in the public domain.
We will rely on the information provided by you as accurate, complete and up to date and you agree to ensure that this will be the case.
You must be at least 18 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use or disclose Personal data about visitors that are under 18 years of age.
How do we use your personal data?
We will only process personal data, in accordance with applicable law, for the following purposes:
a. Responding to your queries, requests and other communications
b. Providing the Services including our website and related features as well as providing other information services.
c. Resolve disputes, troubleshoot problems and enforce our agreements with you, including our Site Terms of Use, Sales Terms and Conditions, and this Private Policy
d. Enabling suppliers and service providers to carry out certain functions on our behalf in order to provide the Services such as sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, etc. These third party service providers have access to personal data needed to perform their functions, but may not use it for other purposes. We do not sell, rent, share, or otherwise disclose personally data from customers for commercial purposes.
e. Register to subscribe to newsletters
f. Participate in discussion forums
g. Diagnose problems with our servers, software, to administer our site, to gather demographic information and to track visitors to our website
h. Sending you personalized marketing communications based on your interests opted upon filling forms on our website
i. Serving personalized advertising to your devices, based on your interests in accordance with our Cookie Statement. You have the right to disable cookies as set out in Cookie statement. Click here to access our Cookie Statement.
j. Complying with applicable law, including in response to a lawful request from a court or regulatory body.
The legal basis for our processing of personal data for the purposes described above will typically include:
- processing necessary for our or a third party’s legitimate interests, such as processing for the purposes set out in paragraphs (a), (b), (c), (d), (e), (f), (g) and (h) which is carried out on the basis of our legitimate interests to ensure that Services are properly provided,
- your consent, such as processing for the purposes set out in paragraphs (i);
- processing necessary for compliance with a legal obligation to which we are subject, such as processing for the purposes set out in paragraph (j); and
- any other applicable legal grounds.
Disclosure of personal data
There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. These scenarios include disclosure to:
- our affiliates and subsidiaries;
- our service providers who capture and store data collected through the forms that are filled by visitors to our website;
- subject to appropriate legal basis such as consent, our advertising and marketing teams who enable us, for example, to deliver personalized ads to your devices or who may contact you by email, telephone, SMS or by other means;
- our service partners to operate our website and better serve the visitors to our website:
- payer, such as your employer, who pays for our products and services;
- public authorities where we are required by law to do so; and
- other third parties where you have provided your consent.
The service providers are contractually bound not to share Personal data collected from visitors to our website with anyone else.
Security Practices
At our site you can be assured that your Personal data is secure and consistent with current industry standards. The importance of security for all Personal data associated with our user is of utmost concern to us. We do not do any transmission of the Personal data collected through our website. Our service partners, who assist us in capturing and storing Personal data, are contractually bound not to share that information with any other party. Our company has a requisite information security policy in place with appropriate managerial, technical, operational and physical security control measures to protect the personal and non-personal information that is collected from website users.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal data, you acknowledge that:
a. there are security and privacy limitations of the Internet which are beyond our control;
b. the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and
c. any such information and data may be viewed or tampered with in transit by a third party.
Retention of personal data
We retain personal data for as long as is necessary for the purposes listed above or longer as may be required by the law or as per the client requirement. Please contact us for further details of applicable retention periods.
Data subject rights
Data subjects may have numerous rights in relation to their personal data.
- Right to make a subject access request (SAR): Data subjects may request in writing copies of their personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other individuals. Each request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and any payment permitted by law, where applicable.
- Right to rectification: Data subjects may request that we rectify any inaccurate or incomplete personal data.
- Right to withdraw consent: Data subjects may at any time withdraw their consent to the processing of their personal data carried out by us on the basis of their previous consent. Such withdrawal will not affect the lawfulness of processing based on such previous consent.
- Right to object to processing including automated processing and profiling: We do not make automated decisions about data subjects. However, we may rely on information provided by third parties such as credit reference agencies which may score data subjects on the basis of automated decisions. Profiling may be carried out for business administration purposes, such as monitoring trends in User visits of our website and in order to deliver relevant ads to Users’ devices. We will comply with valid objection requests unless we have a compelling overriding legitimate ground for the continuation of our processing or we have another lawful reason to refuse such request. We will comply with each valid opt-out request in relation to marketing communications.
- Right to erasure: Data subjects may request that we erase their personal data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the personal data, such as, our business record retention obligations that we have to comply with.
- Restriction: Data subjects may request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.
- Right to data portability: In certain circumstances, data subjects may request the controller to provide a copy of their personal data in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We do not consider that this right applies to our Services. However, to the extent it does, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s personal data which may still be retained for legitimate and lawful purposes.
- Right to lodge a complaint with the supervisory authority: We suggest that data subjects contact us about any questions or complaints in relation to how we process their personal data. However, each data subject has the right to contact the relevant supervisory authority directly.
The California Consumer Privacy Act
Under the California Consumer Privacy Act (‘CCPA’), California residents have certain rights regarding the personal information that businesses have about them. This includes the rights to request access or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.
How We Collect Your Personal Information
We collect identifiers and commercial information directly from you.
We collect Internet or other electronic network activity from your usage of the Eugenie website and its services.
With Whom We Share and Sell Your Personal Information
Eugenie shares personal information as necessary for certain “business purposes,” as defined by the CCPA (Cal. Civ. Code 1798.140(d)). This includes sharing identifiers, commercial information and internet or other electronic network activity with providers of service to customer relationship management, consulting, email, product feedback and helpdesk services.
While Eugenie does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). This includes sharing identifiers, commercial information and internet or other electronic network activity with advertising networks, website analytics companies.
Data subject rights
- Right to Opt-out of Sale –
While Eugenie does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We support the CCPA and wish to provide you with control over how your personal information is collected and shared.
You have the right to direct Eugenie to not sell your personal information. You may reach out to support@eugenie.ai to exercise your right.
With respect to cookies, you can always customize your settings at any time.
Please note that we may still use aggregated and de-identified personal information that does not identify you or any individual; we may also retain information as needed in order to comply with legal obligations, enforce agreements, and resolve disputes.
- Right to Request Disclosure –
You have the right to request disclosure about what categories of personal information Eugenie has sold or disclosed for a business purpose about you and the categories of third parties to whom the personal information was sold or disclosed. Additionally, you have the right to request disclosure of specific pieces of information. Below is a full list of the information that you can include in your request.
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- The categories of personal information that Eugenie has collected about you
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- The categories of sources from which Eugenie collected the personal information
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- The business or commercial purpose for collecting or selling the personal information
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- The categories of third parties with whom Eugenie shares personal information
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- The specific pieces of personal information Eugenie has collected about you
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- The categories of personal information that Eugenie disclosed about you for a business purpose
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- The categories of personal information that Eugenie has sold about you, as well as the categories of third parties to whom Eugenie sold the information.
If you would like to exercise your right to request disclosure, please write to support@eugenie.ai. Our privacy team will examine your request and respond to you as quickly as possible.
- Right to Request Deletion –
You have the right to request that Eugenie delete any personal information about your that Eugenie has collected from you. Please note that there are exceptions where Eugenie does not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.
If you would like to exercise your right to request disclosure, please write to support@eugenie.ai. Our privacy team will examine your request and respond to you as quickly as possible.
- Right to Non-Discrimination –
Eugenie will not discriminate against you (e.g., through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.
California and Delaware “Do Not Track” Disclosures
California and Delaware law require Eugenie to indicate whether it honors “Do Not Track” settings in your browser concerning targeted advertising. Eugenieadheres to the standards set out in this Privacy Notice and does not monitor or respond to Do Not Track browser requests.
Children
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Information, please contact us at support@eugenie.ai.
Changes to the Privacy Notice
We’re constantly trying to improve our Websites and Services, so we may need to change this Privacy Notice from time to time as well. We will alert you to material changes by, for example, placing a notice on our Websites and/or by sending you an email (if you have registered your e-mail details with us) when we are required to do so by applicable law. You can see when this Privacy Notice was last updated by checking the date at the top of this page. You are responsible for periodically reviewing this Privacy Notice.
Acceptance of Terms
When you access this site, you acknowledge that you have read and agree to abide by the terms described below. If you do not agree to the terms discussed here, you should exit this site now.
Copyright Notice
Everything on this site is copyrighted. The copyrights are owned by Eugenie (“Eugenie”, implies Eugenie Technologies Private Limited and all companies wholly or partially owned by it) or the original creator of the material. However, you are free to view, copy, print, and distribute Eugenie material from this site, as long as:
- The material is used for information only
- The material is used for non-commercial purposes only.
- Copies of any material include Eugenie copyright notice
Third Party Copyrights and Copyright Agent
The Eugenie is committed to respecting others’ intellectual property rights, and we ask our users to do the same. The Eugenie may, in its sole discretion, terminate the accounts or access rights of users who violate others’ intellectual property rights.
If you believe that your work has been copied in a way that constitutes copyright infringement on our Web site, please deliver the following information to the Eugenie:
- An electronic or physical signature of the person authorized to act on behalf of the copyright owner;
- A description of the copyrighted work that you claim has been infringed;
- A description of where the material that you claim is infringing is located on our Web site;
- Your address, telephone number, and email address so that we may contact you;
- A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and
- A statement by you, made under penalty of perjury, that the information in your notice to us is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf.
Please send this information to – Eugenie Technologies Private Limited, Level 7, Commerz II, International Business Park, Oberoi Garden City, Western Express Highway, Goregaon (E), Mumbai 400 063
Trademarks
The Eugenie Logo is a trademark of Eugenie Technologies Private Limited. You may not use these without the written permission of Eugenie.
No Warranty
While Eugenie attempts to provide accurate information on this Web site, it assumes no responsibility for accuracy. The Eugenie may change the information on the site at any time without notice.
Material on this site is provided “as is” and does not constitute a warranty of any kind, either expressed or implied. Eugenie disclaims all warranties, expressed or implied. This includes but is not limited to implied warranties of merchantability, fitness for a particular purpose, and non-infringement. It also includes any expressed or implied warranties arising from any course of dealing, usage, or trade practice.
Limitation of liability
Eugenie is not liable for any direct, indirect, special, incidental, or consequential damages arising out of the use-or the inability to use-the material on this site. This includes but is not limited to the loss of data or loss of profit, even if Eugenie was advised of the possibility of such damages.
Links
While this Web site may contain links to third-party sites, Eugenie is not responsible for the content of any linked sites.
Your Posted Information
You are prohibited from posting or transmitting any unlawful, threatening, obscene, libelous, or otherwise offensive material.
Your Submission
Any material, information, or idea submitted or posted on this Web site will be considered non-confidential and non-proprietary. Eugenie may share or otherwise use your submission for any purpose whatsoever. If any of the information submitted constitutes personal data, you agree that Eugenie may transmit such personal data across international boundaries for any Eugenie business purpose. Personal data will be treated as set forth in our Privacy Statement.
Jurisdiction and Choice of Law All claims or issues regarding this Web site, shall be governed according to the laws of the State of Maharashtra, India. Any legal action concerning these Terms or this Web site must be brought within one (1) year after the claim or cause of action arises and must be brought in the State of Maharashtra.
