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Privacy Policy

We, Sawara Solutions Pvt Ltd, a company duly registered under the Companies Act, 1956, bearing CIN-U72900KA2021PTC143734., having registered place of business at #118, Kacharakanahalli, St Thomas Town Near Jyothi School, Hennur Main Road Bengaluru 560084, India., our subsidiaries, affiliates, successors and assigns (collectively, “Promilo”, “we”, “us” or “our”) acknowledge and respect the importance of protecting your privacy. Pursuant to the same, we have adopted the principles set forth in this Privacy Policy (this “Policy”) to govern our use and disclosure of your personal information in the website www.promilo.com and the Android and iOS compatible mobile application, namely “Promilo” [hereinafter collectively referred to as the “Platform”]

The foregoing Policy specifically governs the usage of information collected by us from our users of the Platform and/or any other services provided by us on the Platform, which can be accessed thereof. This Policy should not be read in isolation and is to be read in conjunction and together with the Terms of Use available on the Platform.

Your viewing or browsing of our content or your use of our services offered on our Platform is construed to mean that you explicitly consent to our collection, storage, processing of your Personal Information or Sensitive Personal Information or Information in accordance with this Privacy Policy and you consent to the Terms and Conditions of this Privacy Policy. You hereby agree to be bound by the terms of this Privacy Policy.

1) Collection of Information from Users

We receive process and store information about you, such as:

a) Your e-mail address, name, address, postal code, birth date, preferences, gender details, and telephone number.

b) In this regard, we may also record conversations and archive correspondence between users and the representatives of the Platform (including the additional information, if any) in relation to the services for quality control or training purposes.

c) In connection with any communication or transaction and payment services or any other services that you may avail using the Platform, any information, including but not limited to, bank account numbers, billing and delivery information, credit/debit card numbers and expiration dates and tracking information from cheques or money orders ("Account Information") may be collected by such Payment Aggregator only to the extent permitted/mandated by applicable laws, among other things, to facilitate the sale and purchase as well as the settlement of purchase price of the products or services transacted on or procured through the Platform. Promilo Platform on a standalone basis does not store any payment related information pertaining to Users.

d) Certain other information like your choice to provide further information pertaining to preferences, account settings, reviews, ratings, or any other information provided to us through our service, or elsewhere.

e) Users may also choose to delete or deactivate their accounts on the Platform. We will evaluate such requests on a case-to-case basis and take the requisite action as per applicable law.

f) In this regard, please note that information sought to be deleted may remain with us in archival records for the purpose of compliance of statutory enactments, or for any other lawful purpose. Therefore, users are requested to carefully evaluate what types of information they would like to provide to us at the time of registration.

2) Information Collected Automatically:

The following information is collected about you, your use of our service, the devices used to access our service and it includes the following:

a) Your activity on our Platform, which would include your search history within the Platform, your search inputs within the Platform, services or products viewed over the Platform, profile visits within the Platform;

b) Your interactions with our customer support via various support channels like e- mails, messages, calls;

c) Information collected by other technologies, also including but not limited to advertisement data;

d) Device IDs and other unique identifiers like IP address, browser type, version, network service provider details;

e) Device and software characteristics including types and configurations, connection information, statistics on page views, URLs with time stamp;

f) Service support and payment/ subscription transaction history.

3) Use of Information Collected by Us

How We Share Information
Our Services

Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings.

Profile

Your profile is fully visible to all Promilo Users and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). As detailed in our Help Center, your settings, degree of connection with the viewing User, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

When you share an content or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Users, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can modify visibility in your settings.
Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
When you connect a person or organization, you are visible to them and that “page owner” as a accessor.
We let senders know when you act on their message, subject to your settings where applicable. Subject to your settings, we let a User know when you view their profile.
When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).
Your employer can see how you use Services they provided for your work (e.g. as a recruiter or sales agent) and related information. We will not show them your searches or personal messages.

Communication Archival

Regulated Users may need to store communications outside of our Service.

Some Users (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable archiving of messages by and to those Users outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.

Others’ Services

You may link your account with others’ services so that they can look up your contacts’ profiles, post you show the interest on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.

Subject to your settings, other services may look up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or FB account to share content from our Services into these other services, or your email provider may give you the option to upload your contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.

Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user limited profile data of the person they are meeting or messaging, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

Related Services

We share your data across our different Services and Promilo affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we may personalize your feed or job recommendations based on your learning history.

Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Promilo, our Users, personnel or others. We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. To learn more see our Data Request Guidelines and Transparency Report.

Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

In order to offer you enhanced use of the features of our Platform, We use your information for the following activities :

a) Process your registration, and provide you with your login account details;

b) Process your orders and payments in respect of our services;

c) Provide an efficient medium to facilitate communication and business growth between Users using the Promilo Platform. Users shall be able to strategize, identify their business growth, approach third parties with business proposals and also utilize various parameters available on the Platform to maximize the commerciality of their businesses, based on certain algorithms arrived after utilization of information/ data collected by us to the extent mentioned herein.

d) providing User with customer service and responding to User(s) queries, feedback, claims or disputes;

e) To offer you certain types of services, free trials, and other applicable offers based on your eligibility;

f) To offer you relevant contextual advertisements wherever applicable; g) To connect with you via emails/ phone calls for feedbacks regarding the Platform ; h) To record the phone calls for quality purposes and future references with intent to enhance customer experience on the Platform.

Cross-Border Data Transfers

We store and use your data outside your country.

We process data both inside and outside of the India and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.

Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data. At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent(where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Promilo Services you have requested) and “legitimate interests.”

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Grievance Officer which mentioned below in this document.

Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission. Learn more about this and about our response to “do not track” signals.

Contact Information

You can contact us or use other options to resolve any complaints.

4) Sharing and Disclosure of Information

a) While the Platform is the recipient of your Personal Information or Sensitive Personal Information, we may allow access of this information to various third parties with whom Promilo, has direct legal and confidentiality binding and such data shall stay with them only for limited purpose and period for the processing and storage of information, provision of account to you, provision of customer support, content development and delivery, and other purposes as identified in the Use of Information Collected By Us section to this Policy. To the extent possible and practicable, We shall on a best effort basis enter in to confidentiality arrangements with such third parties.

b) We may also from time to time engage various service providers to perform services on behalf of us enabling us to provide you services better. Such services may include, communications, advertising, infrastructure and IT, payment gateways processing payments, customer support, data analytics, conduct customer surveys, geo tagging/ location based content.

c) Promilo shall on a best effort basis ensure that such service providers adhere to a similar standard of data protection and security that we have agreed to under this Privacy Policy. However, at no point of time shall we be responsible for the privacy practices of such third party entities.

d) Promilo and our service providers may be required to disclose and otherwise use your personal and other information where we or our service providers reasonably believe that there exists the need to disclose to

i. Meet or satisfy any applicable law, regulation, governmental request, or, legal process;

ii. Enforce the agreed Terms of Use;

iii. Address and investigate any illegal activities, which may also include financial frauds, any security or technical issues;

iv. Protect itself against any harm, misuse, of the property or safety of its users and the public, as required or permitted by law.

5) Interaction with third party Platforms

You may be using other third party platforms, to access our services, which may have policies pertaining to privacy which may be different from ours. While you may use mobile devices, gaming systems, smart TVs and other such enabling devices to access our services, it is noteworthy that these have independent privacy policies, Terms of use, which we recommend you read very carefully.

6) Contact list & image uploading

We collect personal data & contact list from you when you provide, share, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data, salary, or address book), respond to a survey, an appointment, meeting, a call back, buy tickets, freebies, survey or submit a resume or fill out a job application on our Services. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, e.g. times, places, attendees and contacts.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

7) Data Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please visit our Safety Center for additional information about safely using our Services, including two-factor authentication.

We understand that we must safeguard your personal information available with us. We use and employ reasonable technical, organizational, logical, physical, administrative measures to protect your personal information against any unauthorized access, modification, or, use.

8) Your Rights and Your Preferences

a) At all times, you have the right to access your personal information, or update, or correct the personal information we hold about you. This can be easily done by you through the “Profile” section; available at the Platform which empowers you with multiple information about your account, which may relate to your contact information, payment information, and several other relevant information about your account. To access this section, and make the relevant changes, you must be logged into your Account

b) Where you have any questions, or wish to make additional requests, you may write to our support team. We strive to respond to any requests made with the specific exercise of data protection rights available under various applicable data protection laws. We retain information as required or permitted by the applicable laws or regulations, including to retain your choices and preferences, for billing purposes, and to meet and fulfill other requirements as specified in this Privacy Policy. Reasonable measures are made to destroy or to remove identifiers in a secure manner when it is no longer required to be retained with us.

c) If you no longer wish to receive certain communications from us via e-mail, messages, you can unsubscribe to the same by clicking on the unsubscribe option in the e-mail communication received from us. Please note that you cannot however, unsubscribe to service related correspondence made by us to you, such as messages regarding your transactions, subscriptions. You can also choose not to receive any push notifications, as may be enabled on your devices; this can be done through your device settings.

9) Children

You must be 18 years of age or older to subscribe to our services. In jurisdictions, where the age of majority is older than 18, in such case, you must satisfy such requirement to become a member.

10) Cookies and Advertising

a) A "cookie" is a small amount of data that is sent to User’s browser and stored on User’s device. If User does not deactivate or erase the cookie, each time User uses the same device to access the Platform, our services will be notified of User visit to the Platform and in turn Promilo may have knowledge of User visit and the pattern of User’s usage.

b) We and our service providers use cookies and other technologies, such as web beacons, as well as several advertising identifiers for several purposes. This is done to understand the users better and offer you with tailored marketing and advertising services. If you do not consent to the use of cookies, use of similar technologies by us, you may at any time adjust your browser settings and delete or disable such cookies. However, this may result in the absence of tailored or user interest based advertisements.

11) Changes in Privacy Policy

We may update this Privacy Policy from time to time. Your continued use of our Platform constitutes your acceptance of our Terms of Use and this Privacy Policy. We encourage and request you to review this section periodically to review any changes made. If you do not wish to accept any changes made to this Privacy Policy, you may cancel your use of our services.

12) Grievance Officer

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Name of the officer appointed as Grievance Officer:

Mr. Michael Jude Saladanha - (Advocate)

Complete Office Address: #118 Kacharakanachali, St Thomas Town, Near Jyothi School, Hennur Main Road, Bengaluru, KA- 560084

Official E-mail Address: grievance@promilo.com

If you have questions or complaints regarding this Policy, please first contact PROMILO online. You can also reach us by physical mail. If contacting us does not resolve your complaint, you have more options. Residents in the Designated Countries and other regions may also have the right to contact our Data Protection Officer here. If this does not resolve your complaint, Residents in the Designated Countries and other regions may have more options under their laws.