INTRODUCTION
Complinity Technologies Pvt. Ltd. (the “Company”, “we”, “us”
or “our”) through its website www.complinity.com (“Portal”) provides a
comprehensive cloud-based Governance, Risk and Compliance software that helps organizations
manage theirCompliances, Contracts, Litigations, Audits, Secretarial, Registrations, Insurance,
Risks,Controls and more (“Services”).
We respect your privacy and are committed to protect it through our compliance with this Privacy
Policy (“Policy”). Please read this Policy carefully to understand how we collect
and use personalinformation and under which circumstances we share the personal information
collected from you (hereinafter referred as “User” or “you”) with any
third party.
This Policy describes:
(i) the types of personal information that we may
collect from you when you access or use the Portal including but not limited to any personal
information shared by you for posing queries or for opting for a demo of the services offered by
the Company through the Portal; and
(ii) our practices for collecting, using, maintaining,
protecting and disclosing the personal information.
The Policy applies only to the personal information collected by us during your use of the
Portal, through email and through other electronic communications sent through the Portal.
By accessing or using the Portal and/or registering for an account on the Portal, you agree to
this Policy and you consent to our collection, use, retention and disclosure of your personal
information in accordance with this Policy.
In the event you do not provide the personal information required by us, we may not be able to
provide you complete use/access of the Portal or the Services provided thereto. Please note that
while you will be accessing the Portal and sharing your personal information on behalf of your
employer body corporate, which is the recipient of our Services (“Customer”); the
information pertaining to the Customer which is entered, accessed or stored on the Portal, is
governed by the confidentiality obligations contained in the terms of engagement with the
Customer and therefore does not fall within the ambit of this Policy.
COLLECTION OF PERSONAL INFORMATION
We respect your privacy and are committed to protecting it in all respects from any unlawful
disclosure. In order to facilitate your use of the Portal, we collect several types of personal
information from and about you, including:
(i) Information about the internet connection
you use to access the Portal.
(ii) The personal information that can be used to identify a
specific person including but not limited to your name, email address, mobile number,
designation, department and the name of your employer. We collect personal information about you
to contact you with respect to your use of the Services, your queries or for customer support.
Our Services and customer support are provided through many platforms, including but not limited
to thePortal, email, and telephone.
Information which is freely available and accessible in the public domain or is furnished to any
authority, organization, department or public at large,without any default by us shall not be
considered as personal information.
Personal information is collected by us either directly from you when you or your employer
provide it to usand/orautomatically as you login to your User Account on our Portal (IP
addresses and session variables) as follows:
(i) Personal information that you provide
us:
Upon creation of your user login, your personal information is either added by us, upon
the instructions of the Customer; or is directly added by the representativeof the Customer
designated as “the admin”.
(a) In case you make an enquiry for demo or
information, the personal information collected is as follows: Your name, name of your employer,
your email address and your mobile number
(b) The personal information collected while
registering your User Account is as follows: Your full name, email address, mobile number,
password, department, designation, location and other personal information that youor the admin
may provide with your account.
(ii) Personal information that we collect through Data
Collection Technologies:
We may automatically collect certain personal information about
your use of the Portal:
(a) Your browsing information: We use session variables to oversee
how long you actively use the Portal. In case of continuous inactivity for 30 minutes, your
session is automatically logged out.
(b) Your IP Address: Your Internet Protocol (IP)
address is tracked to ensure that you are accessing the Portal and the Services through IP
Addresses authorized by the Customer.
(iii) Cookies
We do not use any cookies, flash
cookies, pixel tags or mobile ids, to track your usage of the Portal or customize your user
experience at the moment. However, we may use cookies in the future, in which case this Policy
will be adequately amended to cover the use and purpose of the cookies deployed by us. We only
use session variables to ensure that each logged session is automatically logged out in case of
inactivity of more than thirty minutes. The session variables are maintained for a period of 30
minutes or the duration of the browsing session, whichever is shorter.
(iv) Anonymous
Data
We may anonymize personal information collected from you through the Portal or via
other means, including via the use of third-party web analytic tools. As a result, our use and
disclosure of aggregated anonymized personal information is not restricted by this Policy, and
it may be used and disclosed to others without limitation.
STORAGE, PROCESSING AND SHARING OF PERSONAL INFORMATION
We take appropriate security measures to protect against any unauthorized access, alteration,
modification, disclosure or destruction of data. These include internal reviews of our data
collection, storage and processing practices and security measures, including appropriate
encryption to guard against unauthorized access to systems where we store personal data. We have
implemented appropriate electronic, and managerial procedures to safeguard and help prevent
unauthorized access to your personal information and to maintain data security. These safeguards
take into account the sensitivity of the information that we collect, process and store and the
current state of technology. We follow generally accepted industry standards to protect the
personal information submitted to us, both during transmission and once we receive it.
All the personal information gathered from you is securely stored and on our behalf on
third¬-party infrastructure provider Amazon Web Services.The database is stored in an
encrypted form and processed on the servers provided by Amazon Web Services; with the access to
the servers being password-protected and strictly limited. You can find more information about
Amazon Web Services’ security practices at https://aws.amazon.com/security/. However, as
effective as the security measures are, no security system is impenetrable. We cannot guarantee
the security of the database, nor can we guarantee that the personal information supplied to us
by you will not be intercepted while being transmitted to us over the Internet. Internet is an
ever evolving medium.
We assume no liability or responsibility for disclosure of your personal information due to
errors in transmission, unauthorized third-party access, or other causes beyond our control. You
play an important role in keeping your personal information secure. You should not share your
login credentials, or other security information for your User Account with anyone.
We do not share your personal information with any third party and are not bound to discloseyour
information to any third party unless required by law.
USE OF PERSONAL INFORMATION
We use the personal information we collect from and about you for a variety of purposes,
including:
a) contacting you to understand your requirements for the Services, including
sharing quotations for the Services;
b) organizing physical demonstration of the Services
offered through the Portal;
c) sharing notifications in relation to updates in the
Services, including but not limited to the content provided through the Services;
d)
tracking software usage;
e) processing and responding to your queries, complaints, bugs
reported by you through the helpdesk;
f) sharing reminders pertaining to the compliances
under the Services;
g) providing you customer support;
h) carrying out our obligations
and enforcing our rights arising from any contracts entered into between you and us, including
for billing and collection;
i) assisting you in password retrieval and policy
changes;
j) preserving history as governed by existing law or policy;
k) sending
information, including confirmations, invoices, technical notices, updates, security alerts and
support and administrative messages;
l) meeting any applicable law, regulation and legal
process;
m) responding to law enforcement authority or other governmental official
request;
n) enforcing applicable Terms and Conditions, including investigation of potential
violations;
o) detecting, preventing or otherwise addressing fraud, security or technical
issues;
p) protecting against harm to our rights, property or safety, or harm to our users
or the public, as required or permitted by law;
q) disclosing for the purpose of our audits
or investigating a complaint or security threat; or
r) any other purpose, for which we have
obtained your consent.
SHARING OF PERSONAL INFORMATION
Legal Purposes: We may share your personal information when we believe in good
faith that such sharing is reasonably necessary in order to investigate, prevent, or take action
regarding possible illegal activities or to comply with legal process. We may also share your
personal information to investigate and address threats or potential threats to the physical
safety of any person, to investigate and address violations of this Privacy Policy or the Terms
and Conditions, or to investigate and address violations of the rights of third parties and/or
to protect the rights, property and safety of the Company, its employees, users, or the public.
This may involve the sharing of your personal information with law enforcement agencies,
government agencies, courts, and/or other organizations in response to legal requests, such as
summons, court orders or government demands to comply with the law.
Contractual Rights: We may be required to disclose your personal information to
enforce or apply our Terms and Conditions and other agreements.
Consent: We may share your personal information in any other manneras may have
been consented to by you.
Customer Testimonials / Comments / Reviews: From time to time, we post customer
testimonials on the Portal, which may contain personal information such as your name and
designation. We always obtain the customers’ consent prior to posting their names along
with their testimonials
CORRECTING THE INFORMATION
We will take reasonable steps to accurately record the personal information that you provide to
us and any subsequent updates. In case you wish to review, update, and correct the personal
information that we maintain about you, or you wish to delete the personal information about you
that is inaccurate, incomplete, you may do so by contacting the Privacy Officer (described in
the Section below).
Subject to the applicable law, your right to review, update, correct, and delete your personal
information may be limited:
(i) Where the rights or safety of another person or persons
would be encroached upon, or
(ii) If the information requested relates to any pending or
threatened legal proceedings between you and the Company.
Your right to review, update, correct, and delete your information is subject to our records
retention policies and applicable law, including any statutory retention requirements.
TERMINATION OF ACCOUNT
In case of termination of your User Account, pursuant to the instruction of the Customer, or upon
the termination or expiry of the engagement between us and the Customer, we will either delete
your personal information or de-identify it so that it is anonymous and not attributable to you.
We may retain information about you for the purposes authorized under the applicable law.For
example, we may retain information to prevent, investigate, or identify possible wrongdoing in
connection with the Portal or to comply with legal obligations.
TO CONTACT OUR PRIVACY OFFICER
If you have an enquiry or a complaint about the way we handle your Personal Information, or seek
to exercise your privacy rights in relation to the personal information we hold about you, you
may contact our Privacy Officer as follows:
By Email: neera.singh@complinity.com
By
Mail: Unit No. 544, Tower B-2,
Spaze i-Tech Park,
Sohna Road Sector 49,
Gurugram
– 122018,
Haryana
While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a
formal privacy complaint, we request that you make your complaint in writing to our Privacy
Officer, by mail or email as above.
AMENDMENTS
We reserve the right to amend this Privacy Policy from time to time to reflect changes in the
law, our data collection and use practices, the features of our Services, or advancements in
technology. Use of information we collect is subject to this Privacy Policy in effect at the
time such information is used. If we make any material changes to this Privacy Policy, we will
notify the changes to you through the Portal. Please review the changes carefully. Your
continued use of the Services following the posting of changes to this Privacy Policy will
constitute your consent and acceptance of those changes.
