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Last Updated – 12th June 2021
Your privacy is important to us and we respect the value of privacy of any information or data you provide on the Company Platform. We have developed this privacy policy (“Privacy Policy”) in order for you to understand how we receive, use, store, share, transmit, transfer, delete, or otherwise process(collectively “Process”) the Data. This Privacy Policy describes the measures we take to ensure the protection of your Data. We also tell you how you can reach us to answer any question you may have regarding this Privacy Policy. Please note that the capitalised terms used but not defined herein have the same meaning as ascribed to them under our terms of service available at https://verloop.io/terms-of-service/ (“ToS”).
This Privacy Policy in detail provides the following information in detail:
The Privacy Policy governs the Processing of Data undertaken by all entities which form part of the Verloop Group, for all the Services provided by them in all geographies of their operations. The Privacy Policy only applies to the Data that is being provided to us by you to enable us to provide you Services. Please read this Privacy Policy carefully to understand our policies and practices regarding your Data and how we will treat it. By using or accessing the CompanyPlatform and/or the Services, you agree and consent to the practices described in this Privacy Policy. You also expressly consent to our use and disclosure of Data in any manner as described in this Privacy Policy. If you do not agree with this Privacy Policy or the terms contained herein, you should immediately cease accessing the Company Platform and using our Services.
To provide or while providing Services to you, Verloop Group receives Data from Customer Platform, which as described under the ToS includes both CustomerData and End User Data. We receive this Data from you through the CustomerPlatform for the purpose of providing you with the Services and the ancillary purposes as mentioned below, and we Process the Data as required for us to provide the Services as availed by you. Please note that in relation to Processing of Data (which may include personally identifiable data), you are considered as data controller/principal, i.e., you are collecting the Data from the End Users, and Verloop Group company contracting with you is considered as a data processor, i.e., it is only processing the Data, which it receives from you, as per your instructions. Our use and Processing of the Data on your behalf is governed by the terms as mentioned in the Service Order executed between you and Verloop Group company contracting with you and the terms as stipulated under our ToS.
Verloop Group company may receive and process the following categories of Data received from the End Users:
● Personally, identifiable information, including
(i) name, address, phone number, country, email address, and other basic contact information;
(ii)preferences, content, access device information, and payment information;
(iii) reviews, photographs, videos, and other content; and (iv)communications and other messages, including correspondence between the End User and you.
You or the End User may decline to provide such End User Data, however, our Services are completely dependent on the Data provided by you, including the End User Data shared by the End User with us through the customer Platform. If you or the End User decline to provide the necessary End User Data, required for us to provide you with Services, then, in that case, we may not be able to provide you the Service, for such particular instance where necessary End User Data is not being shared with us. In case the End User Data is being provided partially of what we request or require you (or the End User through you) to provide you with the Services, in such a scenario we may only provide you the Services limited to the EndUser Data being shared with us or we may not be able to provide you the Services.
● Non-personally identifiable information that does not identify the End User, may include session or usage data, log data, aggregation information, user device, and browser information.
Verloop Group company may receive and process the following category of Data from you:
We undertake to use and Process the Data with integrity, accountability, fairness, and transparency. While the Data would be Processed for rendering the Services, the context in which we use and Process the Data may also vary based on your additional instructions or on the communication received from the End User through the Customer Platform.
The main purposes for which we may Process the Data are:
Our legal basis for processing the Data is that (i) the processing is necessary to perform a contract executed between you and the Verloop Group company, including but not limited to providing Services to you, (ii) to comply with various legal obligations and requirements under the applicable laws while providing Services to you, and (iii) you have obtained adequate consents, rights and approvals from the End Users, as per the applicable law for the Data, including but not limited to adequate consents, rights and approvals in relation to End User Data, that is being transferred to us by you through the Customer Platform to be Processed by us or sub-Processed as mentioned under this Privacy Policy.
We transfer the Data to our Sub-Processors as may be necessary to provide any component of the Services that you may have requested.
We may share your information when we believe in good faith that such sharing is reasonably necessary or is required to so, in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. We may also share Data to investigate and address threats or potential threats to investigate and address violations of this Privacy Policy or the ToS, or to investigate and address violations of the rights of third parties and/or to protect the rights, property and safety of Verloop Group companies, our employees, users, or the public. This may involve sharing of the Data with law enforcement, government agencies, courts, and/or other organizations on account of legal request such as summons/subpoena, court order or government demand to comply with the applicable law.
In case you are located outside India, the Verloop Group company contracting with you will work with Verloop India to provide you the Services. In case you are located in India, Verloop India will provide the Services directly. The Verloop Group companies shares the Data with Verloop India in order for Verloop India to Process the Data and enable us to provide you with Services. Verloop Group companies also engage with certain Sub-Processors to provide you with specific functionality within the Services. If we transfer the Data to a foreign country, we will comply with all the applicable laws in respect of such transfer, including making sure that your Data and specifically End User Data is kept secure, and ensure that appropriate safeguards are in place as mandated under the applicable laws.
Verloop Group will retain Data for the period necessary to fulfil purposes outlined in this Privacy Policy including till validity of the contract between you and the Company or as may be required under the applicable law. Notwithstanding anything to the contrary, Verloop Group may collect, aggregate and analyze the Data to improve and enhance the Services and for any such other purposes which may be beneficial for the Services. The Verloop Group shall solely disclose the Data in an aggregated and in personally unidentifiable form, except as otherwise provided under this Privacy Policy, ToS and the Service Order.
Verloop Group would like to make sure you are fully aware of all of your rights. You are entitled to the following:
If you would like to exercise any of these rights, or if you have any questions regarding the content of this Privacy Policy, please contact us @ +91 9620393847.
We have implemented appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to the Data and to maintain Data security. These safeguards take into account the sensitivity of the Data that we receive, process and store and the current state of technology. We follow generally accepted industry standards to protect the Data, including personally identifiable data submitted to us, both during transmission and once we receive it. Therefore, while we strive to use commercially acceptable means to protect your Information, we cannot guarantee its absolute security and thereby usage in a manner that is inconsistent with this Privacy Policy. Further, the Verloop Group company processes the Data only in compliance with the applicable laws including but not limited to the Information Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
We assume no liability or responsibility for disclosure of your Data due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your Data secure. You should not share your Access Credentials with anyone. Further, notwithstanding anything contained in this Privacy Policy or elsewhere, we shall not be held responsible for any loss, damage or misuse of your Data, if such loss, damage or misuse is attributable to any event that is beyond our reasonable control or for a reason as attributable to you.
We may provide links to third-party websites as a part of the Services to you or to the End User, specifically if the same is instructed by you. When you or the End Users click on links of third party websites or platform, you may be redirected to such third party website or platform and leave the Company Platform.
This Privacy Policy does not cover any collection, use, or disclosure of any information/data by third parties through any applications, websites, products, or services that we do not control or own, or any third-party features or services made available through the Company Platform or integrated to the Company. By using the third-party website or platform made available through the Company Platform, you expressly relieve Verloop Group from any and all liability arising from your use of any third-party website or platform.
The inclusion of a link or accessibility of third-party websites or platform through Company Platform does not imply endorsement of such third-party websites or platforms by us. All trademarks, trade names, and logos of third parties featured on the Company Platform belong to their respective owners.
The Data we receive from you may be processed and stored in India and/or at any other location where the servers of our cloud service provider are located, which may provide for different data protection rules than the country in which you reside, or your End User resides. By using the Services and by executing the Service Order with us, you are providing consent to us to receive, transfer, use, storage and disclosure of the Data as described in this Privacy Policy, including to the transfer of your Data outside your country or country of residence of the End User. If you have any questions relating to your Data, please write to us at finance@verloop.io .
Verloop shall comply with applicable local data protection laws and requirements worldwide including but not limited to the Information Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
Where applicable data protection laws require a higher standard of protection for Data than that set out in this Privacy Policy, the requirements of applicable data protection law shall prevail. Where applicable data protection laws establish a lower standard of protection for Data than that set out in this Privacy Policy, the requirements of this Privacy Policy shall prevail.
Where you have reason to believe that the applicable law prevents Verloop Group company from fulfilling its obligations under this Privacy Policy or the ToS or it prevents Verloop Group company from providing its Services, you shall promptly inform Verloop Group at finance@verloop.io.
You shall at all times ensure that the Services being provided by us through the Customer Platform are not being availed by End Users under the age of 18. We do not knowingly collect any End User Data from children under 13 or market to or solicit information from anyone under the age of 18. If we become aware that a person submitting End User Data through Customer Platform is under 18, we will suspend our Services in relation to such End User and delete any related End User Data as soon as possible.
This Privacy Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. If we make changes, we will revise the date at the top of this Privacy Policy. Depending on the specific amendments, we may provide you with additional notice prior to the change becoming effective. Please review this Privacy Policy from time to time to stay updated on any changes. Your continued use of our Services constitutes your agreement to the updated Privacy Policy on a prospective basis.
If you have questions or complaints regarding this Privacy Policy, please contact us by email @ finance@verloop.io.