Effective: July 02, 2020

Privacy Policy for envoyexcellency.com

This Privacy Policy (“Policy”) describes the information which Envoy Excellency (“We” or “Us” or “Sites”) collects from you when you download, access, or use its Website (The Sites this policy is applicable for has been listed below in Annexure 1 ).

This Policy shall not apply if you access or use Website.

This Privacy Policy should be read in conjunction with the Terms of Use applicable to the EE services you are using.

Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications like social media login the information we collect is through those third-party sites linked with our applications is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in observance that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Use.

User Consent

By using the Site, you agree to our terms of collection, storage and use of your personal information which you provide to us in accordance with this policy. In some cases, particularly if you reside in a country governed by a data protection regulation, we may ask you to provide explicit consent to access our services before proceeding for further operations. In case of any roaming user profile or if you are a traveller visiting various countries around the world and avail EE services, then we will consider the country of registration as your primary country and the consents obtained at the time of registration will be valid for your processing of personal information.

Accessing Website and EE Services through VPN

You should not access or use the Website or EE Services by means of any mechanism or technology which conceals your actual geo-location or provides incorrect details of your location (for example, use a virtual private network (VPN) to access EE Services).

We will not be responsible or liable for any collection, storage or processing of your personal information or data if you use any mechanism or technology to access or use Website or EE Services which conceals your actual geo-location.

Collection and Use of Personal Information

‘Personal Information’ or ‘PII’ is defined as any information that identifies (whether directly or indirectly) to a particular individual or natural person, such as the individual’s name, postal address, email address, mobile number and any other identifier indicating to that particular person. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

Information collected when you use our Mobile Application

When you download our mobile application we may collect, including but not limited to, the below information from you-

  • Location/IP address for geo-locating accurate up to 300 meters
  • Device ID
  • SMS for OTP
  • Gallery permissions for storing images
  • Android Advertiser ID/ iDFA ID

Information you provide to us voluntarily

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect and store such information.

We may collect additional information at other times, including but not limited to, when you provide feedback to EE or you change your content or email preferences, comment on stories or communicate with us.

  1. Information automatically collected while browsing/navigating through the Website

Cookies

The Website uses cookies and other similar technologies which are necessary to its functioning and to provide EE Services. Some of these cookies are essential for us to provide you with the EE services. For more information about essential cookies we use, please refer to our Cookie Policy.

We do not collect your personal data through these cookies.

Do Not Track

The Website and EE Services currently do not process or respond to “Do Not Track” requests/signals which some internet browsers have the ability to send out.

  1. Inferred information through usage and log data

We may track certain information about you based upon your behavior on using EE services. We use this information for conducting internal research on our users’ demographics, devices, interests, and behavior to better understand, protect and serve our users.

We may also collect Your Information to track user behavior and preferences for internal analytics and research. We may also use your information:

  • To evaluate your interest for various genres of content, services, offers;
  • To perform analytics and conduct customer research, to determine your interest, for identifying content that generate sales and to analyze traffic patterns.

If you choose to post messages on social media accounts, or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

The above information may also be captured by keeping cookies on our websites by our affiliates for the purposes mentioned above.

  1. Information we collect from third parties

a)Information obtained from other sources
We may receive information about you from other sources, add it to our account information and treat it in accordance with this policy. If you provide information to the platform provider or other partner, whom we provide services, your account information and order information may be passed on to us. You can opt-out or opt-in by giving a consent at to serve you advertisements when you visit our website or applications. We may obtain updated contact information from third parties in order to correct our records and fulfil the Services or to communicate with you.

b)Demographic and other information
We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use various third party analytics service providers, among others, to track the user behavior on our website. They are used to support display advertising towards helping us gain understanding of our users’ Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out or opt-in by giving a consent at to serve you advertisements when you visit our website or applications.

Disclosure to Third parties

  1. a) Service Providers
    The Application may include links to other websites or applications (for e.g., links to payment gateways for payment of subscription fees). Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the application, website you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these sites via a link from the application’s/website homepage, you should contact the application/website owners directly for more information.

    b) Promotional Offers
    We may share or disclose your personal information outside of EE when we have your consent. For example, providing SMS and E-mail related services such as marketing newsletters, promotions and offers.

    c) Advertisers
    We do not provide any personally identifiable information to third party websites / advertisers / ad-servers without your explicit consent.

    d) Legal
    In the event Envoy Excellency is merged with or acquired by another company or in case of re-organization or re-structuring of business, we and our affiliates may share your personal information, wholly or in part, with another business entity.

    e) Business transfers
    We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we may use service providers to help us with customer support.

    .

 

Purposes and Lawfulness of Processing

We will only collect and process personal data about you where we have lawful basis. Lawful basis on which we would process our personal information includes obtaining explicit consent from you for processing your personal information or processing for “legitimate interests” where processing is necessary by us to provide you with services.

We use information to provide, analyze, administer, enhance and personalize our service and marketing efforts, to process your registration, to provide you services, and to communicate with you related to below mentioned points. For example, we use information to:

  • Analyze and understand our audience, improve our service (including our user interface experiences),recommendation algorithms and delivery which may require sharing personal information with our group companies and affiliates or third party service providers
  • To help advertisers understand our audience and confirm the value of advertising on our websites or Applications (however it is usually in the form of aggregated statistics on traffic to various pages within our site) and to provide you relevant ads
  • Communicate with you concerning our service (for example by email), so that we can send you news about EE, details about new features and content available on our Services,promotional announcements, and surveys, and to assist you with operational requests such as password reset requests.
  • Notify you about changes in terms of service or privacy policy
  • Allow you to participate in interactive features offered through our Services
  • Sharing with our customer support team to resolve your queries/concerns related to your rights or services provided to you.

 

Information use by the company

The Information as supplied by the users enables us to improve the Services and provide you the most user-friendly experience. In some cases/provision of certain service(s) or utility (ies), we may require your contact address as well. All required information is service dependent and the Company may use the above said user Information to, maintain, protect, and improve the Services (including advertising on the “Application”) and for developing new services. We may also use your email address or other personally identifiable information to send commercial or marketing messages with your consent [with an option to subscribe / unsubscribe (where feasible)]. We may, however, use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, billing, for notifying you in case of breach incidents, etc.)

Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, twitter etc. Any posted/uploaded/conveyed/communicated by users on the public sections of the “Application” becomes published content and is not considered personally identifiable information subject to this Privacy Policy. In case you choose to decline to submit personally identifiable information on the Application, we may not be able to provide certain services on the Application to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.

When you register with the Application or Services, we contact you from time to time about updating of your personal information to provide the users such features that we believe may benefit / interest you.

Information sharing

The Company shares your information with any third parties without obtaining the prior consent of User in the following limited circumstances:

  • When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.
  • The Company proposes to share such information within its group companies and officers and employees of such group companies for the purpose of processing personal information on its behalf. We also ensure that these recipients of such information agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

How long do we store and use your information

We retain the information which we have collected no longer than is necessary. This is determined on a case by case basis. Normally we will retain the information as long as you maintain an account with us and till the time you continue to access and use EE Services. We will delete your information whenever you request us to do so. However, we may archive and/or retain some information for legal purposes.

Your Controls and Choices

For any of the below request you may send us an e-mail to our support team

  1. Accessing & rectifying your personal information

When you use the Services (website/application or any of its sub sites), we make good faith efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. We ask individual users to identify themselves and the information requested to be accessed or corrected before processing such requests. We may decline to process requests that are unreasonably repetitive or systematic, requiring disproportionate technical effort, jeopardizing the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

You can make access requests by sending an e-mail to our Grievance officer. You will get a link on your registered Email address through which you can access all the data TOI collects and stores about you.

You can ask us to correct inaccurate or incomplete personal information

  1. Concerning your login credentials by editing the same through My Accounts section, through the SSO portal. The same shall be reflected across all properties.
  2. Concerning details that are separately collected and maintained by EE by sending an e-mail to our support team to perform the rectification.
  3. Data Portability

You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format; wherever feasible. Through this, a copy of your information that we have collected and stored will be downloaded on your machine.

  1. Data Retention and Erasure

We retain your personal information as long as necessary for us to provide services to you or you ask us to not retain your data. If you no longer want us to use your information then you can request that we erase your personal information and close your EE account. Please note that if you request for the erasure of your personal information;

  • The personal information (Name, E-mail, Mobile No) will be retained as a part of the SSO Login functionality and will be governed by the SSO Login Policy
  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a EE account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
  • Information you have shared with others (e.g., Comments, Reviews, etc.) may continue to be publicly visible on the EE, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
  • Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. Your request will be processed and you will receive confirmation of the same via email. Please note that this will only perform a deletion of the information that has been collected by EE and will disable your SSO information for EE. You will still exist as a user across all the other EE platforms. In case you also wish to delete your SSO related information, kindly follow the instructions displayed on the screen or please read the SSO privacy policy to understand how to invoke your rights.

    Please note that if you have multiple accounts with us, then you will have to raise separate requests for each of the accounts, along with the associated email IDs or phone numbers.

  1. Withdrawing Consent and Restriction of Processing

For withdrawing your consent at any time during the tenure of your services with us, you may choose to do so by sending us an e-mail to our support team. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you and stop any further processing of your personal information.

  1. Objection to Processing

Where your personal information is processed for direct marketing purposes or any contests or promotions or other services, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to our support team.

Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate.If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact us at the below mentioned e-mail address.

We may take 30 days from the date of receipt of request to complete your requests. However, if the nature of the requests are excessive in nature or would require significant effort then may ask for an extension of 60 days by giving a prior notice to you with the reason for the extension.

We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

  1. Complaints

You can write to us in case of any grievance or compliant at the support e-mail address. If you have any complaints regarding the processing of your personal information you may contact our data protection officer or our grievance officer at the below mentioned e-mail address. You have the right to complain about the data processing activities carried out by EE before the competent data protection authorities.

Children’s Privacy

EE is not intentionally designed for or directed at persons less than 18 years of age. EE does not knowingly permit any person who is under 18 years of age to register with the services or to provide any other personally-identifying information. If EE becomes aware that any personally identifiable information of persons less than 18 years of age has been collected on EE Services without verified parental consent, then EE will take the appropriate steps to delete any such information and notify the parent.

However, we consider it the responsibility of parents to monitor their children’s use of our services. Nevertheless, it is our policy not to collect and process any personal information from children below 18 years of age or offer to send any promotional materials to persons in that category. EE does not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided EE with personal information without their prior consent, please contact our customer support team to ensure that the personal information is removed from the EE services.

Data transfer, storage and processing globally

We operate globally and may transfer your personal information to individual companies of the EE affiliated companies or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

Security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered on the Site is securely stored within the EE controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. If you know or have reason to believe that your EE account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.

Updates & Changes
We may alter our privacy policy from time to time to incorporate necessary changes in technology, applicable law or any other variant. We reserve the right to amend the terms of this Policy from time to time. Any changes we make will be effective immediately on notice, which we may give by posting the new policy on the Site. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Privacy Policy periodically on the Site.

Contact us
Support
If you require any information or clarification regarding the use of your personal information or this privacy policy or grievances with respect to use of your personal information, please email us at info@envoyexcellency.com