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SUMMARY OF KEY POINTS
- A. We use Personal Information to allow you to participate in the features on the Site(s)/ App(s), to process your registration, and to provide you with other requested content related to our content and other offerings.
- D. If you are under 18 years old, you must obtain the permission of your parent or guardian before participating in a contest or engaging in other activities. The only exceptions are if you simply sign up for a newsletter.
- F. This Site(s)/ App(s) may be hosted on web servers in jurisdictions outside India. Your use of the Site(s)/ App(s) constitutes your consent to the transfer of Personal Information to any other jurisdiction that may not provide the same level of data protection as your home country.
(i) We may collect Personal Information/Information, including your name, email or street address, date of birth, telephone number, your preferences and interests, or other information you provide to us or grant us access to when you register for newsletters, communicate with us, or take part in interactive games, features or competitions. The Site(s)/ App(s) may also ask you to provide other information about yourself, such as demographic, geographic information (gender, zip code, age, etc.) or certain information about your preferences and interests. If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as personal information. Please note that information submitted to the Site(s)/ App(s) via a “contact us” or other similar function may not receive a response. We will not use the information provided to contact you for marketing purposes unrelated to your request unless you agree otherwise.
(ii) Whenever you visit or interact with the Site(s)/ App(s) or ALTBalaji content, ALTBalaji, any third-party advertisers, content providers and/or service providers, may use a variety of technologies that automatically or passively collect information etc. about how the Site(s)/ App(s) are accessed and used (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time, and the preceding page & video views etc. Usage Information is generally non-identifying, but if ALTBalaji associates it with you as a specific and identifiable person, ALTBalaji treats it as Personal Information. ALTBalaji also automatically collects your IP address or other unique identifier (“Device Identifier”) from the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Site(s)/ App(s). A Device Identifier is a number that is automatically assigned to your Device when you access a Site(s)/ App(s) or its servers, and our computers identify your Device by its Device Identifier. Some mobile service providers or our third-party service provider may also provide us with information regarding the physical location of the Device used to access the Site(s)/ App(s).
(iii) The technologies used on the Site(s)/ App(s) to collect Usage Information, including Device Identifiers, have been detailed herein below.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
(ii) Web beacons (also known as clear gifs) are used in combination with cookies to help Site(s)/ App(s) operators understand how you interact with their Site(s)/ App(s). A web beacon is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a Site(s)/ App(s) or in an email. The use of a clear gif allows the Site(s)/ App(s) to measure your actions in opening the page that contains the clear gif.
(iii) Embedded scripts are programming codes that are designed to collect information about your interactions with the Site(s)/ App(s), such as the links you click on. The code is temporarily downloaded onto your Device from our server or a third-party service provider, is active only while you are connected to the Site(s)/ App(s),and is deactivated or deleted thereafter.
- a. Provide general internal and customer analytics.
- b. Study traffic patterns in order to improve Site(s)/ App(s) performance, to customize the user experience, and to better match the users’ interests and preferences. For example, ALTBalaji keeps track of the domains from which people visit, and also measures/tracks visitor activity on ALTBalaji Site(s)/ App(s). However, these tracking records are performed and maintained in ways that keep the data non-identifiable.
- c. Keep track of preferences you specify while you are using ALTBalaji products or services.
- d. Support security measures, such as requiring re-login into an ALTBalaji product or service, after a certain amount of time has elapsed.
- e. If you login to our products through the Site(s)/ App(s), cookies can also be used to save the username so that we can process the saved login information and quickly log you into the product.
- f. Assist in identifying possible fraudulent activities.
- g. Tell if an email has been opened and acted upon.
3. LOG FILE INFORMATION
Our servers automatically collect limited information about your Devices’ connection to the internet, including your IP address, Device and/or MAC ID, etc., when you visit our Site(s)/ App(s). Your IP address is a number that lets computers attached to the internet know where to send your data — such as the web pages you view. Your IP address, Device and/or MAC ID, etc., does not identify you personally but may be combined with your Personal Information which then may identify you personally.
4. MINOR’S PERSONAL INFORMATION
5. HOW WE USE YOUR INFORMATION
We will use Personal Information collected through the Site(s)/ App(s) to: (1) allow you to participate in the features we offer on the Site(s)/ App(s); (2) provide you with information that you request or agree to receive; (3) improve the Site(s)/ App(s) and for internal business purposes; (4) contact you with regards to your use of the Site(s)/ App(s), and any changes to our policies; (5) tailor content, advertisements and offers we serve you; and (6) fulfil other purposes disclosed at the time you provide your Personal Information or otherwise with your consent.
6. HOW WE SHARE YOUR PERSONAL INFORMATION
- 6.1 WHEN YOU AGREE TO HAVE YOUR PERSONAL INFORMATION SHARED
- 6.2 FOR SWEEPSTAKES, CONTESTS AND PROMOTIONS.
The Site(s)/ App(s) may offer sweepstakes, contests, and other promotions (each, a “Promotion”) that may require registration. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties in connection with the administration of such Promotion, such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. By entering a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements from you, including, except where prohibited by law, allowing the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
- 6.3 ON SITE(S)/APP(S)THIRD PARTIES PROVIDING SERVICES ON OUR BEHALF
We may engage any third parties to perform functions on our behalf, such as hosting or operating our Site(s)/ App(s), sending e-mail communications, and data analysis. We may share Personal Information with third parties in order for them to provide content or otherwise perform services for us, and we will require such parties to maintain appropriate security to protect such data from unauthorized access or processing. It being clarified that in no event shall ALTBalaji, or any of its directors, employees, or any representatives, be held liable for use of such Personal Information by itself and the aforementioned third parties.
- 6.4 FOR AFFILIATE SHARING AND BUSINESS TRANSFERS
We may share your Personal Information with other entities (group entities and/ or affiliates) for internal reasons, primarily for business and operational purposes. ALTBalaji or any of its assets, including the Site(s)/ App(s), may be sold, or other transactions may occur in which your Personal Information is one of the business assets of the transaction. In such case, your Personal Information may be transferred. Hence, ALTBalaji reserves the right to disclose and transfer user information, including Personal Information in connection with a corporate merger, consolidation, restructuring, the sale of certain of ALTBalaji’s assets, or other corporate change including, without limitation, during the course of any due diligence process
- 6.5 POTENTIAL INVESTORS
Certain investors may be interested in investing funds in ALTBalaji. For the purposes of securing such investment, ALTBalaji may be required to disclose data pertaining to your Personal Information or to your Usage Information. We will require such parties to maintain appropriate security to protect such data from unauthorized access or processing. It being clarified that in no event shall ALTBalaji be held liable for use of such Personal Information/ Information by itself and the aforementioned third parties.
7. LEGAL PROTECTIONS AND OTHER DISCLOSURES
8. LINKS TO OTHER SITE(S)/ APP(S) AND SERVICES, AND ALTBALAJI CONTENT FOUND ON OTHER SITE(S)/ APP(S)
9. PERSONAL INFORMATION YOU DISCLOSE PUBLICLY ON OUR SITE(S)/ APP(S)
Our Site(s)/ App(s) may offer message boards, chat rooms, alternative reality games, multi-player games and other public areas (collectively, “Community Forums”) where you can engage in social networking, interact with others, as well as have the opportunity to submit photographs, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Submissions”). To participate in certain Community Forums, you may be asked to select a username, screen name or member name and password. Furthermore, any such User Submissions that you publish on our Site(s)/ App(s) or submit for publication on our Site(s)/ App(s) may be available, via the internet, around the world, and we cannot prevent the use or misuse of such information by others.
10. NOTE THAT ANYTHING YOU POST TO A COMMUNITY FORUM IS PUBLIC
Also, functionality on the Site(s)/ App(s) may permit interactions between the Site(s)/ App(s) and a third-party Site(s)/ App(s) or service, such as enabling you to “like” a product on our Site(s)/ App(s) or “share” content to other Site(s)/ App(s) or services. If you choose to “like” or “share” content on the Site(s)/ App(s) or to otherwise post information from or via the Site(s)/ App(s) to a third-party’s Site(s)/ App(s), service, feature or application, etc. that information will become public and the third-party may have access to information about you and your use of our Site(s)/ App(s).
11. INFORMATION WE RECEIVE FROM THIRD PARTIES
12. WE MAY USE AD SERVING AND TRAFFIC MEASUREMENT SERVICES; HOW TO “OPT OUT” OF RECEIVING ADVERTISING RELEVANT TO YOU
ALTBalaji licenses technology to serve advertisements on its own Site(s)/ App(s) and within its videos and other content as that content is served across the internet. In addition, ALTBalaji may use third-party network advertisers to serve advertisements and third-party analytics service providers to evaluate and provide us with information about the use of the Site(s)/ App(s) and viewing of our content. We do not share Personal Information with these third parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including Usage Information. With regard to advertisements, we and our network advertisers may target advertisements for products and services in which you might be interested based on your visits to both the Site(s)/ App(s) and other Site(s)/ App(s). Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, or to conduct research regarding the usefulness of certain advertisements to you. We may share Usage Information about visitors to the Site(s)/ App(s) with third-party advertising companies for the same purposes. We may use a variety of companies to serve advertisements.
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no electronic data transmissions or storage of information can be guaranteed to be 100% secure. You acknowledge that we cannot ensure or warrant the security of any information you transmit to us, and you use the Site(s)/ App(s) and provide us with your information at your own risk.
14. PERSONAL INFORMATION SITE(S)/ APP(S) AMENDING OR REMOVING YOUR PERSONAL INFORMATION, CONTROLLING MARKETING COMMUNICATIONS, AND PRIVACY QUESTIONS
You have the right to access your Personal Information held by us and, if necessary, have it amended or deleted. You can also request not to receive email, SMS, and MMS marketing communications from us. You may opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails. If you sign up to receive SMS or MMS messages, you may unsubscribe from any SMS or MMS messages received by replying “STOP.” Please note that we may still need to send you certain communications relating to your account or use of the Site(s)/ App(s) and these transactional account messages may be unaffected if you choose to opt-out from marketing communications.
For more details or any privacy questions please contact us by email at firstname.lastname@example.org (name and contact no of the Grievance office not mentioned. Who ) or write to us at:
ALT Digital Media Entertainment Limited
C-13, Balaji House, Dalia Industrial Estate,
Opp. Laxmi Industries, New Link Road,
Andheri (W), Mumbai 400053
We request you to please provide the following information in your complaint:-
- a. Identification of the information provided by you
- b. Clear statement as to whether the information is Personal Information or sensitive Personal Information
- c. Your address, telephone number or email address.
- d. A statement that you have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be.
- e. A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to you.
16. COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
We cooperate with mandated government and law enforcement agencies or to any third parties by an order under law for the time being in force to enforce and comply with the law. We will also disclose any information including Personal Information or Information about you to government and law enforcement agencies or private parties without your permission as we, in our sole discretion, believe necessary or appropriate to respond to valid claims and legal process, to protect the property and rights of Site(s)/ App(s) or a third-party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. Site(s)/ App(s) may also provide your Personal Information including Sensitive Personal Information or Information to various authorities upon any demand or request from them.
We may use your Personal Information or Information for the aforementioned purposes of the services/Site(s)/ App(s). You have full control regarding which emails you want to receive. If you decide at any time that you no longer wish to receive such communications from us, please follow the instructions to unsubscribe, as provided in any of the communications. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information or national identification numbers in a non-secure or unsolicited email or telephone communication.
19. GRIEVANCE OFFICER
20. APPLICABLE LAWS AND JURISDICTION
1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
2. PURPOSE OF COLLECTING YOUR INFORMATION
- (i) respond diligently to queries or requests submitted by You;
- (ii) process financial transactions or applications submitted by You;
- (iii) administer or otherwise carry out our obligations in relation to any agreement you have with us;
- (iv) resolve problems/complaints with any goods or services supplied to You;
- (v) create products or services that may meet your needs and requirements.
b. We process Information to pursue our legitimate interest to run, maintain and develop our services inorder to meet needs/requirements of our end users/viewers/subscribers. At times while consuming the services, You may be requested to grant Your consent for the processing/usage of Your Information. In this event, You may withdraw Your consent at any time post which we shall refrain from using Your Information in any manner whatsoever.
c. To optimise our Services, We may wish to use Your Information for marketing our services whereby we send you emails, messages relating to our services and/or our Site(s)/App(s). As We respect your privacy, We will only use Your Information for the purpose of marketing our services when you are aware about the same and if required We will request your consent prior to using Your Information for such marketing purposes.
Additionally, if at any time You wish us to stop using Your Information for any or all of the above purposes, you can reach out to the Data Protection Officer at email@example.com. We will stop the use of Your Information for such purposes as soon as it is reasonably possible to do so.
e. Please be assured that we will not use Your Information for any of the purposes if You have indicated that you do not wish us to use Your Information in any certain manner/way when submitting the Information or at any later stage.
3. HOW DO WE USE YOUR INFORMATION?
ALTBalaji and/or its partners/third party firms and/or third party service providers may use Your Information (i) to study how You use the Site(s)/ App(s) so we can make improvements and provide you with better customer experiences (ii) to record information about the pages You visit in the of the Site(s)/App(s), the duration of time You spend on the pages of the Site(s)/ App(s), how You arrived at the Site(s)/ App(s) and the content you clicked on when You visit the Sites(s)/App(s), (iii) to provide targeted content recommendations to You based on Your interests; (iii) for the purpose of A/B testing, (iv) marketing communications (iv) to comply with legal obligations as per jurisdiction and (v) to conduct various internal audits and analytics to understand customer behavior and their interaction with features of the platform. We also use your account information to deliver content based on subscription pack, country, location and age.
4. WHO DO WE SHARE YOUR INFORMATION WITH?
We use third party service providers for rendering support services, such as Email/ SMS service providers for marketing, for conducting analytics purposes and for software development purposes. We use these third-party services solely to obtain, process or store Your Information for the purposes described in this policy. We may further share your Information to track your usage of the services provided by us on Site(s)/App(s), however the same is not shared with any third party(ies) who are unauthorized to receive such Information.
5. WHERE DO WE PROCESS/STORE YOUR INFORMATION?
6. TRANSFER OF INFORMATION TO COUNTRIES OUTSIDE EUROPEAN ECONOMIC AREA
The collected Information may be transferred to selected third parties that own/operate our servers and/or third party support, engineering teams that manage the Site(s)/App(s), which may be located outside of the European Economic Area (“EEA”) as part of the services offered to You through our site. By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA. These third parties will not use Your Information for any other purposes than what we have agreed with them, unless the same is required by law or any court order or any statutory requirement or regulatory policy. We respect Your need to protect the Information and therefore, we will on best effort basis take all requisite steps/precautions to ensure that your Information continue to be protected if we transfer your information outside of the EEA. In addition, if you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
7. HOW LONG DO WE RETAIN YOUR INFORMATION?
a. You Information is retained for up to 10 (ten) years from the date when the Information is collected/received by us.
You may instruct us to delete your Information collected by us by writing an email to us at firstname.lastname@example.org. If you instruct us to delete your Information, your Information shall be deleted within 30 (thirty) working days from the date of receiving Your Information deletion request email.
c. For Registered users of Site(s)/App(s, we will retain your Account ID and Email ID
d. For subscribed user below is the list of Information that shall be retained by us.
- i. Account ID/Customer ID which is created when You registers on the Site(s)/App(s)
- ii. Order ID which is generated when You initiate a financial transaction on the Site(s)/App(s)
- iii. Location – which means the location from where the financial transaction was made
- iv. Package selected – the subscription package price selected by user (which may be $4.99, $7.99 or $12.99)
- v. Duration of subscription package ( which may be quarterly, half-yearly or yearly)
- vi. Payment gateway through which transaction has been done
- vii. You Email ID
- viii. Date of the financial transaction
- ix. Type of transaction (Success/ Failure)
- x. Invoice issued to You by ALTBalaji
8. WHAT RIGHTS DO YOU HAVE OVER YOUR INFORMATION?
As a resident of EEA and a user of ALTBalaji, you have access to the following rights in compliance with GDPR:
- a. Right to be Informed: You have the right to be informed about anything that happens with your Information, what it is used for, you have the right to access it and to modify it and even to remove your consent to share Your Information with us. At the same time, you have the right to access your Information at your disposal.
- b. Right to Restrict Processing: Under the GDPR, You have the right to restrict processing of Information in various circumstances. For example, You can restrict processing when You feel Your Information is not accurate. In this case You will be able to restrict the processing until the accuracy of Your Information has been verified. Another case when processing can be restricted is when You object to the processing of Your Information.
- c. Right to Erasure: You have the right to request the deletion or removal of Your Information from our end. This right is not absolute, which means that there are circumstances when Your Information will not be erased at Your request. For sake of clarity, if Your Information is used to comply with a legal obligation, for scientific research or for the exercise or defense of legal claims, then the right to removal can be denied to You.
- d. Data Portability: You also have the right to data portability. Unless other contractual issues pre-exist (of which you should be informed of before you allow your data to be processed) then you can move any data from the Information from one service provider to another in an easy and secure manner.
- e. Rights related to Automated Decision Making And Profiling: The GDPR defines profiling as any form of automated processing intended to evaluate Your personal aspects, such as Your performance at work, Your health, personal preferences, economic situation, location and more.
- f. Right to Rectification: You have the right to request rectification of inaccurate Information concerning You. You also have the right to have incomplete Information completed, including by means of providing a supplementary statement.
- g. Right to Object: You shall have the right to object, on grounds relating to your particular situation, at any time, to process the Information concerning You. We shall no longer process Your Information in the event of receipt of the objection, unless We can demonstrate having compelling legitimate grounds for processing of the Information which may at times override Your interests and rights of the Information.
If You wish to exercise either or all rights mentioned above, write to us at email@example.com.
If you have any concerns or complaints regarding the use of the Site(s)/Apps(s), please contact us at firstname.lastname@example.org.
Alternatively, you can reach out to the Data Protection Officer at email@example.com.
The following is a comprehensive list of what /Information we collect, how we use it:
|Information||Purpose of processing|
|Registration Data and Log-in Data. Your name, email, mobile phone number, password, date of birth, gender, and IP address.
Legal Basis (EU): Contract
|User Profile Search Data. Record of search inquiries.
Legal Basis (EU): Contract
|To provide quick access to previous searches.|
|Additional Account Security. Kids mode PIN (an optional security features for you), Managed Devices, Email address, Facebook Connect Token.
Legal Basis (EU): Contract
|To verify your identity account security.|
|Log File Information See definition above.
Legal Basis (EU): Legitimate Interests
|To better understand how you access and use ALTBalaji;
To administer ALTBalaji;
For internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management.
|Android Device Permissions. Your on-device contact list, SMS, Location, Telephone
Legal Basis (EU): Contract
|To process payment for subscription via various payment gateways, wallets, mobile carrier billing, etc;|
|Transaction/ Financial information
Legal Basis (EU): We process this data in accordance with our obligations under applicable law.
|As per Indian law and jurisdiction, ALTBalaji is required to store information regarding any payment transaction attempted on the platform.
Account ID (Customer ID)- created when a user registers on the app
Order ID (generated when a user initiates a transaction)
Location (Location from which the transaction was done)
Duration of Package (Quarterly, Half-yearly, Yearly)
Payment gateway through which transaction has been done
Email Id of the user
Date of transaction
Type of transaction (Success/ Failure)
Invoice issued to subscriber
|Customer Support Information. Any information that you provide to our customer support team.
Legal Basis (EU): Contract
|Device Data. Media stored on your device.
Legal Basis (EU): Contract
|Surveys. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third- party service provider to conduct these surveys and this will be notified to you prior to you completing the survey.
Legal Basis (EU): Consent
|Contest Information. Any information that you provide to us in submitting an entry to a contest offered on ALTBalaji.
Legal Basis (EU): Contract
|Anonymized and Aggregated Data. We anonymize and aggregate certain Information to improve our services||
|Cookies. We further explain such collection in “Cookies and other Tracking Technologies” section.
Legal Basis (EU):** Contract
|Payments Information. Please note that where a payment is processed by a third- party payment service provider, we do not collect or store any Personal Information, though we may receive summary information about transactions.||