PRIVACY & NON-DISCLOSURE POLICY
Infologitech Systems Private Limited and SpotWays
These Terms of service are effective July-1, 2016
Global Privacy & Non-disclosure compliance
Infologitech Systems Pvt Ltd. complies with the requirements of the EU-U.S. Privacy Shield Framework. Infologitech Systems Pvt Ltd. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield. [https://www.privacyshield.gov/]
Infologitech Systems Pvt Ltd. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Infologitech Systems Pvt Ltd. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Infologitech Systems Pvt Ltd. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Infologitech Systems Pvt Ltd. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to- Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Infologitech Systems Pvt Ltd. complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Infologitech Systems Pvt Ltd. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, please visit https://safeharbor.export.gov/swisslist.aspx.
Registration with SpotWays may include collection of the following information from you within the Websites:
We may collect the following personal information from you when you use our Service(s):
We may use the information collected from within the Websites or when you use the Service(s) to:
When you provide us with personal information about your contacts and/or your customers, we will only use this information for the specific reason for which it is provided.
Except as outlined in this Policy, your information will never be sold to or shared with other companies or organizations for commercial purposes or otherwise. We may transfer information to our Group Companies and sub-contractors that help us provide our Service(s). Transfers to subsequent third parties are covered by the service agreements with our sub-contractors. Such sub-contractors may include third-party payment processors who process your credit card and other payment information but are otherwise not permitted to store, retain or use such information. Information that is already in the public domain would not be part of this privacy commitment by SpotWays.
If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at firstname.lastname@example.org
SpotWays keeps information on behalf of our customers, and has no direct relationship with the individuals with whom our customers may interact using the Service(s). If you are a customer of one of our customers (“End-Customer”) and would no longer like to be contacted by that customer, please contact the customer that you interact with directly. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the SpotWays’s customer (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
Other information such as End-Customer device models, usage patterns are also captured by the SpotWays Service(s). This information is not used by SpotWays except in allowing you to view and use this information for trouble shooting. Content and messages in voice, text or other format created by you or your End-Customers to send or share with other users or End-Customers shall be hosted on SpotWays servers.
We retain Data we process for as long as an Account is active or as needed to provide the Service(s). If you wish to terminate your Account or request that we no longer use Your Data, please contact us at email@example.com. We will retain Your Data as necessary to comply with our legal obligations, maintain accurate financial and other records, resolve disputes, and enforce our agreements. We delete all Your Data on the expiry of 30 days after the termination of your Account, except as otherwise prohibited by applicable law.
We are the data processors and not the data controllers of the information on our platform for purposes of the EU Directive on Data Protection (Directive) and the Swiss Federal Act on Data Protection. Our EEA or Switzerland based customers, who control their customer data and send it to SpotWays (Infologitech Systems Pvt Ltd) for processing, are the “controllers” of that data and are responsible for compliance with the Directive. In particular, SpotWays’s customers are responsible for complying with the Directive and relevant data protection legislation in the relevant EEA member state before sending personal information to SpotWays for processing. We work with our customers to help them provide notice to their customers concerning the purpose for which personal information is collected.
We do not own, control or direct the use of the information stored or processed on our platform, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the SpotWays Service(s) (including to respond to support requests), as otherwise authorized by our customers or as required by law.
It shall be our customers’ responsibility to inform the End-Customers about and obtain necessary consent for any personal information that is collected through our customer’s use of the Service(s). As the processors of personal information on behalf of our customers, we follow their instructions with respect to the information they control to the extent consistent with the functionality of our Service(s). In doing so, we implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, personal information as more fully described under the section below entitled, “Protection of Information”.
When you download, install and use our Mobile Applications, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”).
We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Application on your mobile or handheld device. This Mobile Application may record information such as how often you use the Mobile Application, the events that occur within the Mobile Application, aggregated usage, performance data, and where the Mobile Application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the Mobile Application.
SpotWays has its own proprietary as well as open source software for analytics. All metrics information collected from your usage can be used to evaluate how users use SpotWays, and to compile statistical reports on activity for us. We further use the same statistical analytics tool to track. We will use this information in order to maintain, enhance, or add to the functionality of the Service(s) and to personalize the experience for you. Anonymized and aggregated information and analysis may be made public where desired by SpotWays. All our third party partners, wherever associated, will not share your information or associate your information with any other data held by them.
We use Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our Websites or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
You can set your browser to either reject all cookies, to allow only “trusted” websites to set them, or to accept only those cookies from those websites you are currently on.
For more information on controlling cookie settings in your browser, please refer to the following links:
More information on "Incognito" mode and cookie setting in Google Chrome
More information on "InPrivate" and cookie setting in Internet Explorer
More information on "Private Browsing" and cookie setting in FireFox
More information on "Private Browsing" and cookies setting in Safari
Please note that if you wish to turn off the cookies in your web browser, you might not be able to take advantage of many features of our Service(s).
To learn how to delete or disable cookies in general, visit www.allaboutcookies.org/manage-cookies.
Infologitech and SpotWays customers have the responsibility to inform the individuals with whom they interact with via the help of the Service(s) about the cookies used by SpotWays and by themselves and should obtain individuals’ consent, if necessary.
We and our third party advertising partners use technologies such as web beacons in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other information we collect about you.
Do Not Track. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.
We partner with a third party to either display advertising on our Websites or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this Website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Our Websites contain links to other websites that are not owned or controlled by SpotWays or Infologitech Systems. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Websites and to read the privacy policies of each and every website that collects personal information.
Our Websites offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know that we are unable to do so and why.
You can log in to our Websites using sign-in services such as Google, Facebook Connect. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address. Services like Google, Facebook Connect give you the option to post information about your activities on our Websites to your profile page and to share information with others within your network.
We may use your email address to send our newsletters and/or marketing communications. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the emails you receive.
We will send you announcements related to the Service(s) on occasions when it is necessary to do so. For instance, if our Service(s) is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of communications which are not promotional in nature. If you do not wish to receive them, you may deactivate your Account.
The Websites and Service(s) have industry standard security measures in place to protect against the loss, misuse, and alteration of the information under our control. When you provide us with sensitive information (such as credit card information or login credentials), our partners will encrypt that information via Secure Socket Layer (SSL).
While there is no such thing as “perfect security” on the Internet, we take all reasonable steps to ensure the safety of your personal information. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Websites or via the Service(s) and any transmission is at your own risk. Once we receive your information, we will use strict procedures and security features to try to prevent unauthorised access.
Additionally, you retain all rights of ownership to your personal data we collect. Except as set forth herein under sections elaborating on use of your personal information above and legal disclosure below we will not sell or share your personal data with any third parties or use your personal data to compete with you. Your privacy and the privacy of your customers are of utmost importance to us. If you have questions about our security you can contact us at email@example.com.
We post customer testimonials/comments/reviews on our Websites which may contain personal information. Prior to posting the testimonial, we obtain the customer's consent to post their name along with their testimonial. If you want your testimonial removed, please contact us at firstname.lastname@example.org.
Upon request Infologitech Systems will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at email@example.com.
We allow users of the Service(s) or Website to access, update or modify their information by clicking on the My Account link in the SpotWays navigation menu or by contacting us at firstname.lastname@example.org. We seek to respond to requests for access or modification as soon as possible and within reasonable timeframe.
SpotWays or Infologitech Systems does not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or Service(s). We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through our Service(s) or Websites without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Websites or Service(s), please contact us and we will endeavor to delete that information and terminate the child's account from our databases.
Amendments to this Policy will be posted to this URL and will be effective when posted. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. Provided we will not be notifying you if we amend the Policy to make addition, deletions or modifications to the list of cookies from time to time to keep the list of cookies current and accurate. You should frequently visit this Policy to check for amendments. Your continued use of this Websites or the Service(s) following the posting of any amendment, modification, or change to this Policy shall constitute your acceptance of the amendments to this Policy. You can choose to discontinue use of the Websites or Service(s), if you do not accept the terms of this Policy, or any modified version of this Policy.
We reserve the right to disclose your data as required by applicable law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us. Your data will also be shared between our Group Companies for the activities permitted under this Policy.
In the event SpotWays or Infologitech Systems goes through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account and personal data will likely be among the assets transferred. You will be notified via email@example.com and via a prominent notice on our Websites of any such change in ownership or control. We may also disclose your personal information to any other third party with your prior consent.
Our address for a notice to Us in writing by Courier or US Mail is: SpotWays, Infologitech systems Pvt Ltd, 92, Telecom Nagar, Gachibowli, Hyderabad, India 500032 with a CC to firstname.lastname@example.org by electronic mail. All notices shall be deemed to have been given immediately upon delivery by electronic mail, or if otherwise delivered upon receipt or, if earlier, two (2) business days after being deposited in the mail or with a Courier as permitted above.
Mutual NDA: Infologitech Systems Pvt. Ltd. Page /