We understand the importance of protecting Your privacy. We are committed to safeguarding the privacy of the personal data or information that We collect, possess, use, process, record, store, transfer, disclose, deal, handle and receive, by and on behalf of our users/ subscribers while rendering Services through our Website. Accordingly, set out below is our Privacy Policy (as defined hereinafter), pursuant to Rule 3(1)(a) of the IT Intermediary Rules (as defined hereinafter), setting out how we intend to safeguard such personal data or information received and used by us as aforesaid. This is in compliance with the prevailing Information Technology Act, 2000 (“IT Act”), the Information Technology (Reasonable Security Practices And Procedures And Sensitive Personal Data Or Information) Rules, 2011 (“IT SPDI Rules”) and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“IT Intermediary Rules”) as may be amended from time to time.
This privacy policy, as amended from time to time, (“Privacy Policy” or “Policy”) is effective from 01.01.2023, and applies to Samanta Duggal , its affiliates, employees, staff and team members, Instructor and vendors who collect, possess, use, process, record, store, transfer, disclose, deal, handle and receive, the personal data or information by and on behalf of the users/ subscribers of the Website (“You” or “Your”) while rendering Services to users/ subscribers in India or overseas including but not limited to any consultants, contractors, advisors, accountants, agents, person, representatives of Samanta Duggal etc. who provide services to or on Samanta Duggal’ behalf in connection with the Services rendered through the Website (“Third Person”).
This Policy summarizes what type of Personal Data or Information (as defined hereinafter) We collect about You, purpose of collection, storage and usage of such data or information, to whom such data or information may be disclosed/transferred and how We protect Your privacy.
The term “Personal Data or Information” in this Policy refers to personal information which does and/or is capable of identifying You as an individual. The types of Personal Data or Information that We collect consist of personal information relating to Your:
This Policy does not apply to any information that You may disclose publicly and which is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force and such information shall not be regarded as Personal Data or Information for the purposes of this Policy. Further, Your Personal Data or Information shall not be disclosed to any Third Person unless the said Third Person is required to have the Personal Data or Information of You to provide required Services to You and/or with Your permission and/or to help investigate, prevent or take action regarding unlawful and illegal activities, suspected fraud, potential threat to the safety or security of any person, violations of the terms and conditions of use of the Website or to defend against legal claims and special circumstances such as compliance with the rules of any stock exchange, subpoenas, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure. We share Your information with advertisers on an aggregate basis only.
Further, for any Personal Data or Information disclosed by You to any service provider or trader or any third party that You connect with through the Website, Samanta Duggal shall not be responsible and/or liable to treat the same as the Personal Data or Information to be protected by Samanta Duggal.
You are providing Your consent by providing Your details on the Website (“Consent”) with respect to the purpose of usage of such Personal Data or Information.
If You give Your Consent, it is construed that You have done so freely and voluntarily and that You agree to this Policy. You always have the right to refuse or withdraw Your Consent for the Personal Data or Information sought to be collected or withdraw Your Consent given earlier to us. We will always respect such a refusal or withdrawal, but it might mean that We are unable to perform all the Services, arrangements or contracts with You and will have the option to discontinue the same. We will inform You of these inabilities, if they occur. However, we reserve the right to retain such Personal Data or Information as may be necessary for providing our pending Services to You and in accordance with this Policy and/or if legally required, under the IT Intermediary Rules and other applicable laws.
You are aware of the:
We respect Your privacy; therefore, Samanta Duggal will observe the following guidelines when collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling, and disclosing:
The primary purposes for collection, storage and/or use of Personal Data or Information is for:
In addition to Personal Data or Information, we may use data collection devices such as “cookies” or other technology to obtain certain types of information when Your web browser accesses our website. Cookies are small files containing a string of characters to identify Your browser. Cookies allow the Website to remember important data or information that will make Your visit to the Website more useful. Our website may use cookies and other technology to store pertinent user information during a session to speed navigation and keep track of items and to collect anonymous traffic data that We may use to enhance our website and for marketing and promotional purposes. You can reset Your browser to refuse cookies or warn You when they are being sent. Please note that by turning cookies off, you may not have access to all features available on our website. We also use logging systems on our internal network to register the use of our computer systems. This is done for the purpose of ensuring the performance, integrity and security of these systems. We may also contract with Third Persons to track and analyse anonymous usage and volume statistical information from our visitors and members for research purposes. Such information is shared externally only on an anonymous, aggregated basis. Such Third Persons use persistent cookies to help us to improve the visitor experience, to manage our website content, and to track visitor behaviour. All data or information collected by such Third Persons on our behalf is used solely by or on behalf of Samanta Duggal and is shared externally only on an anonymous, aggregated basis.
We will make best efforts to do so but do not warrant that any of the websites or any affiliate site(s) or network system linked to our website is free of any operational errors nor do We warrant that our website will be free of any virus, computer contaminant, worm, or other harmful components. Our website contains links to other sites which are not owned or operated by Samanta Duggal. Samanta Duggal is not responsible and makes no guarantee for the privacy practices or the content of such websites. These links are provided only as a convenience to You. Neither, Samanta Duggal nor any of its affiliates are responsible for the availability of such Third Persons websites or their contents. Samanta Duggal will not be liable for Your Personal Data or Information transmitted over networks accessed by You on these sites or otherwise connected with Your use of the services. You understand, acknowledge and agree that neither Samanta Duggal nor any of its affiliates are responsible or liable, directly or indirectly, for any damage or loss of any sort caused in connection with Your use of or reliance on any content of any such site or services available through any such site.
You acknowledge that the Services, content, site and/ or any software are provided on an “as is” and “as available” basis, without warranties of any kind, either express or implied, including, without limitation, implied warranties of merchantability, fitness for a particular purpose. Although Samanta Duggal has taken adequate safeguards, and in case of any breach Samanta Duggal may take action to remedy such breach. In addition to taking all the reasonable precautions as required under law, Samanta Duggal expressly disclaims any and all warranties, express or implied, including, without limitation: (i) the Services and/ or software will be free of all viruses and hacking; (ii) the software will work on all mobile phones, will be compatible with all mobile phone networks and/or will be available in all geographical areas; and (iii) Any service will be uninterrupted, timely, secure or error-free for any reasons whatsoever including but not limited to overload/breakdown of receiving network, servers or applications; system failures out of the Samanta Duggal ’ control or due to heavy traffic on network.
Samanta Duggal will transfer, with Your Consent, the Personal Data or Information to any other Third Person in India or overseas, that ensures the same level of data protection that is adhered to by Samanta Duggal as set out herein for fulfilling any contractual obligation.
We will disclose or transfer Your Personal Data or Information in accordance with this Policy and all applicable legal requirements in India.
Your Personal Data or Information will be disclosed or transferred, as may be required from time to time, as follows:
We seek to ensure compliance with the requirements of the IT Act to ensure the protection and preservation of Your privacy, therefore We take reasonable security measures to protect Your Personal Data or Information against unauthorized access, alteration, disclosure or destruction. We have a number of physical, electronic, and procedural safeguards/measures in place to actively protect the confidentiality, security, and integrity of Your Personal Data or Information, including a comprehensively documented information security programme and a strict security policy that contains managerial, technical, operational and physical security control measures for protecting such data or information. We have implemented standard or code of best practices for data or information protection.
We limit access to Your Personal Data or Information to members of our team/employees/ Third Persons who We believe reasonably need to come into contact with that information for the purpose of performing their duties and rendering services to You. We have strict confidentiality obligations that apply to such members/employees/ Third Person’s. Failure to meet these obligations may result in disciplinary and other actions, including dissolution of a contract, termination of employment and criminal prosecution.
We conduct training to authorized users regarding the lawful and intended purposes of processing Your Personal Data or Information, the need to protect and keep information accurate and up-to-date and the need to maintain the confidentiality of the data or information to which such authorized users have access. Authorized users will comply with this Policy, and We will take appropriate disciplinary actions, in accordance with applicable laws in India, if Your Personal Data or Information is accessed, processed, or used in any way that is inconsistent with the requirements of this Policy.
8. RETENTION OF YOUR PERSONAL DATA OR INFORMATION
We are aware of the importance of timely destruction of Personal Data or Information. We ensure that Your Personal Data or Information is not stored/retained for a longer period than necessary for the purpose for which it was collected, used or processed or as provided in our contracts except when there is a legal obligation to do so under any law in India, including but not limited to, the IT Intermediary Rules. It is our practice to destroy Your Personal Data or Information as soon as possible after it is no longer necessary for the purpose for which it was collected, used or processed save and except as stated hereinabove.
You may by a written request review the Personal Data or Information provided by You. We will ensure that any Personal Data or Information about You which is found to be inaccurate or deficient shall be corrected or amended as may be feasible.
You expressly state that Personal Data or Information provided by You to us is correct and complete in all respects and does not contain any false, distorted, manipulated, fraudulent or misleading facts. We expressly disclaim any liability arising out of the said data or information provided by You to us. Further, you expressly agree that We are not responsible for the accuracy and authenticity of such data or information provided by You to us and You agree to indemnify Samanta Duggal for all losses incurred due to any false, distorted, manipulated, defamatory, libellous, vulgar, obscene, fraudulent or misleading facts made by You to Samanta Duggal.
In case of any discrepancies or grievances with regard to the processing of Your Personal Data or Information, please contact the “Grievance Officer”, at. Further on receipt of any concerns or complaints the Grievance Officer will employ all commercially reasonable efforts to address the same at the earliest but in no event the same shall exceed One (1) month of receipt of same.
All Samanta Duggal’ affiliates/group companies will ensure that this Policy is observed. All employees/staff of Samanta Duggal and Third Persons who have access to Personal Data or Information are required to comply with this Policy.
All Third Persons shall only process the Personal Data or Information in accordance with Samanta Duggal’ instructions or make decisions regarding such data or information as part of the delivery of their services. In either instance, Samanta Duggal will select reliable Third Persons who undertake, by contract or other legally binding and permissible means, to put in place appropriate technical and organizational security measures to ensure an adequate level of protection of such data or information. Samanta Duggal will require Third Persons to comply with this Policy or to guarantee the same levels of data protection that is adhered to by Samanta Duggal when handling/processing such data or information. Such selected Third Person’s will have access to such data or information solely for the purposes of performing the services specified in the applicable service contract and are legally and contractually bound to maintain the privacy of such data or information shared with them and will not disclose it further. If Samanta Duggal concludes that a Third Person is not complying with these obligations, it will promptly take appropriate actions to remedy such non-compliance or implement necessary sanctions.
Additionally, our team members/employees/staff are bound by internal confidentiality policies. Any team member/employee/staff found to have violated this Policy or any other policies will be subject to disciplinary action, up to and including termination of employment including penalties under applicable laws in India.
All Third Person’s and our team members/employees/staff do hereby specifically agree that he/she/it shall, at all times, comply with the requirements of the IT Act, IT SPDI Rules, and IT Intermediary Rules while collecting, receiving, possessing, using, processing, recording, storing, transferring, dealing, handling, retaining and disclosing Personal Data or Information. The said Third Person’s and team members/employees/staff do further unequivocally declare that in case he/she/they violates any provisions of the IT Act, IT SPDI Rules, and IT Intermediary Rules, he/she/they shall alone be responsible for all his/her/it acts, deeds and things and that he/she/it alone shall be liable for civil and criminal liability there under or under any applicable Indian law for the time being in force.
The User acknowledges and accepts that We have the right to terminate Your access and usage rights to the Website and Services in the case of Your non-compliance with any provision of this Policy.
Samanta Duggal reserves the right to update, change or modify this Policy, from time to time, without prior notification. The Policy shall come into effect from the date of such update, change or modification.
We will inform You regarding any such changes by updating this Policy and will post all changes to the Policy on relevant internal and external websites. The User acknowledges that such posting shall amount to information to the user as prescribed by the IT Intermediary Rules.
Effective with the implementation of this Policy, all existing intra-group agreements and the applicable privacy guidelines or practices relating to the processing of Personal Data or Information will be superseded by the terms of this Policy and modified accordingly. All parties to any such agreements will be notified of the effective date of implementation of the Policy. If any of the terms or definitions used in this Policy are ambiguous, the definitions established under the IT Act, IT SPDI Rules, and IT Intermediary Rules shall apply.