A. DEFINITIONS
In this document, terms that commence with a capital letter are defined in this Section and shall have the following meaning:
“Images/Us/We/Our” means Images Multimedia Private Limited, a company incorporated and existing under the Companies Act, 1956, and having its registered office at S-61 A, Okhla Industrial Area, Phase 2, New Delhi – 110020, India
“Personal Data” means any information relating to Users in the European Union, who can be identified, directly or indirectly, in particular reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity of that User in the European Union;
“Personal Information” means any information that related to Users outside European Union, which either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such User outside European Union;
“Sensitive Personal Data/Information” means personal information of Users outside European Union which consists of information relating to;— (i) password; (ii) financial information such as bank account or credit card or debit card or other payment instrument details ; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information; (vii) any detail relating to the above clauses as provided to body corporate outside European Union for providing service; and (viii) any of the information received under above clauses by body corporate outside European Union for processing, stored or processed under lawful contract or otherwise, provided that, any information that 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 shall not be regarded as Sensitive Personal Data/ Information;
“Service(s)” means an online platform provided by Images wherein a) Users can register for events listed on Our Website and/or b) Users advertise their products/services, brands etc. (“Products”)including communicating products through mailers, newsletters etc on Our Website for the purpose of promotion of such Products.
“User(s)” or “You(r)” means any natural or legal person including but not limited to any company, firm, sole proprietorship or other associations of individuals, who visits, search, accesses or registers on our Website and/or our clients, business partners and associates.
B. WHAT PERSONAL INFORMATION AND SENSITIVE PERSONAL DATA/ INFORMATION DO WE COLLECT OF USERS OUTSIDE EUROPEAN UNION AND THEIR RIGHTS?
1.1 When any User outside European Union (“EU”) visits Our Website, We collect session data through our tools, which shall include but not limited to the following:
(i) The type of browser and operating system used;
(ii) The domain name of the site from which such User came;
(iii) The date, time and duration for which such User have visited Our Website;
(iv) Number of Visits;
(v) The web pages or services User accessed at Our Website;
(vi) If You download a form, the form that was downloaded.
None of the above is Personal Information or Sensitive Personal Data/Information.
1.2 When any User outside EU, request for additional information regarding Our Services, We only collect Personal Information viz. name, email and phone number, that is required by Us to provide such User outside EU the details regarding the Services which such User outside EU is interested in and it is specifically for the purpose of giving such User outside EU, the additional information requested and in no way is transferred to anybody else.
1.3 When such User outside EU register on Our Website to seek Our Services, We shall collect following Personal Information and Sensitive Personal Data/Information required to register such User outside EU and for purpose of providing such User outside EU Our Services:
Category of Personal Information or Sensitive Personal Data/Information collected What this means
Identity Data First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, pan card number password or other forms of identification.
Contact Data Your home address, work address, billing address, email address and telephone numbers.
Financial Data Your bank account and payment card details.
Marketing and Communications Data Your preferences in receiving marketing from Us and Our third parties and Your communication preferences. If You correspond with Us by email or messaging through the Services, We may retain the content of such messages and Our responses.
1.4 Review and Erasure of Personal Information or Sensitive Personal Data/Information furnished by Users outside EU.
Users outside EU shall have right to review the Personal Information or Sensitive Personal Data/Information provided by them to Us and request correction and amendment of any such Personal Information or Sensitive Personal Data/Information which is inaccurate or deficient.
1.5 Grievance Officer
If any User outside EU want to rectify any discrepancies in the Personal Information or Sensitive Personal Data/Information furnished by them or have any grievance, they may reach to Our designated ‘Grievance Officer’ whose details are as follows: contact@imagesgroup.in
The Grievance Officer shall redress the grievances of and grievances of such User outside EU; within 30 (Thirty) days from the date of receipt of the grievance by the Grievance Officer.
C. WHAT PERSONAL DATA DO WE COLLECT OF USERS IN EU AND THEIR RIGHTS?
Please note that provisions and rights provided below in this clause “C” are only applicable to Users accessing Our Website and seeking Our Services from within the EU, subject to GDPR regulations
1.1 When any User in EU visits Our Website, We collect session data through our tools, which shall include but not limited to the following:
(vii) The type of browser and operating system You used;
(viii) The domain name of the site from which You came;
(ix) The date, time and duration for which You have visited Our Website;
(x) Number of Visits;
(xi) The web pages or services you accessed at our Website;
(xii) If you download a form, the form that was downloaded.
1.2 When any User in EU request for additional information regarding Our Services, We only collect Personal Data viz. name, email and phone number, that is required by Us to provide such User in EU the details regarding the Services which such Users in EU are interested in and it is specifically for the purpose of giving such Users in EU the additional information requested and in no way is transferred to anybody else.
1.3 When such Users in EU register on Our Website to seek Our Services, We shall collect following Personal Data required to register them and for purpose of providing such Users in EU Our Services:
Category of Personal Data collected What this means
Identity Data First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, pan card number password or other forms of identification.
Contact Data Your home address, work address, billing address, email address and telephone numbers.
Financial Data Your bank account and payment card details.
Marketing and Communications Data Your preferences in receiving marketing from Us and Our third parties and Your communication preferences. If You correspond with Us by email or messaging through the Services, We may retain the content of such messages and Our responses.
1.4 Rights Relating To Personal Data of Users in EU
The Users in EU have the following rights under this Privacy Policy and under General Data Protection Regulation, 2016:
Request to obtain your Personal Data: A right to receive a copy of the Personal Data such Users in EU have provided Us, to check the purposes for which We are Processing it, recipients to whom the Personal Data is or will be disclosed, the envisaged period for which the Personal Data will be stored and if We are lawfully Processing such Personal Data;
Request correction of the Personal Data We hold about You: A right to have any incomplete or inaccurate Personal Data We hold about such Users in EU corrected;
Request erasure of Your Personal Data: A right to ask Us to delete or remove Personal Data where such Personal Data is no longer necessary in relation to purposes for which it was collected or such Users in EU withdraw their consent for use of such Personal Data or such Personal Data is unlawfully processed or such Personal Data has to be erased in compliance with legal obligation;
Object to Processing of Your Personal Data: A right to object to Processing of Personal Data. Such Users in EU shall also have the right to object where We are processing their Personal Data for direct marketing purposes;
Request the restriction of Processing of Your Personal Data: A right to ask Us to suspend the Processing of Personal Data;
Request the transfer of your Personal Data: We will provide to Users in EU, or a third party they have chosen, Personal Data provided in a structured, commonly used, machine-readable format to Us. Note that this right only applies to automated information which such Users in EU initially provided consent for Us to use or where We used the information to perform a contract with such Users in EU;
Withdraw consent: A right to withdraw their consent for use of Personal Data. However if they withdraw their consent, We may not be able to provide them with access to the certain specific functionalities of Our Website or Our Services.
How such Users in EU can exercise their rights?
If at any time any User in EU have questions about our practices or any of its rights described above or any complaints with regard to this Privacy Policy or our practices in relation to your Personal Data, such User in EU may reach our Data Protection Officer (“DPO”) and Our dedicated team that support this office by contacting Us at contact@imagesgroup.in. This inbox is actively monitored and managed so that We can deliver an experience that you can confidently trust.
We try to revert to all legitimate requests within 3 days of a request being made. Occasionally it may take us longer than the time mentioned herein if any request is particularly complex or in the event of a number of requests being made. In this case, We will notify such User in EU and keep them updated.
If any User in EU feels that their complaint has not been adequately resolved, please note that GDPR gives such Users in EU the right to contact their local data protection supervisory authority.
No Special Categories of Personal Data
We do not collect any “Special Categories of Personal Data” about any User in EU (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information). Nor do we collect any Personal Data of Users in EU with regard to criminal conviction and offences.
Our Policy on Children Privacy for Users in EU
Protecting the privacy of young children is important to Us. The Services are not intended for children below 16 and We do not knowingly collect or solicit Personal Data from anyone under the age of 16 or knowingly allow such persons to register with Us. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on our Website. If we become aware that we have collected Personal Data from a child under age 16, We will take steps to remove that Personal Data.
D. HOW WE USE THE PERSONAL INFORMATION, SENSITIVE PERSONAL DATA/INFORMATION AND PERSONAL DATA OF USERS THAT WE COLLECT
We strongly believe in both minimizing the Personal Information, Sensitive Personal Data/ Information and Personal Data we collect and limiting the use and disclosure of Personal Information, Sensitive Personal Data/ Information and Personal Data only to our employees, contractors and agents (a) to deliver and improve our Services; (b) to provide you with information about our Services including information about products of our other clients (c) to provide you with e-newsletters you have requested (d) to manage your account and provide You with customer support; (c) to diagnose or fix technology problems; (d) to verify Your identity and prevent fraud or other unauthorized or illegal activity; (e) where disclosure is necessary to be in compliance with law; (f) where certain Sensitive Personal Data or Information and Personal Data has to be provided to third-party intermediaries that manage credit or debit card processing.
These individuals (as applicable) are bound by the confidentiality obligations and may be subject to disciplinary action, including termination (as applicable), if they fail to meet these obligations.
We take reasonable steps to ensure that Personal Information, Sensitive Personal Data/Information and Personal Data, We process are accurate, complete, and current, but We depend on Users to update or correct their Personal Information, Sensitive Personal Data/Information and Personal Data whenever necessary.
It is always up to the User to disclose their Sensitive Personal Data/Information and Personal Data to Us and User can withdraw their consent for retention and use of their Sensitive Personal Data/Information or Personal Data by Us at any time. Although if a User elects to do so, We reserve the right not to provide you with any Services.
Compliance with legal, regulatory and law enforcement requests
We cooperate with government and law enforcement officials and private parties to enforce and comply with applicable laws. We will disclose any Personal Information, Sensitive Personal Data/Information or Personal Data about the Users to government and law enforcement officials as We, in Our sole discretion believe necessary and appropriate to respond to claims and legal process, to protect the safety of the public or any person, or to prevent to stop any activity We consider is illegal and unethical.
E. FOR HOW LONG WE STORE YOUR THE PERSONAL INFORMATION, SENSITIVE PERSONAL DATA/INFORMATION AND PERSONAL DATA
We will retain Users Personal Information Sensitive Personal Data/Information or Personal Data only for as long as necessary to provide to the Users the Services they have requested unless a longer retention period is required by applicable law (for example for legal and regulatory purposes). This may include keeping such Users Personal Information, Sensitive Personal Data/Information or Personal Data after they have deactivated their account for the period of time needed for Us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
F. HOW WE PROTECT YOUR SENSITIVE PERSONAL DATA/INFORMATION AND PERSONAL DATA
We are committed to protecting the security of Users Personal Information, Sensitive Personal Data/Information or Personal Data and We take all reasonable precautions to protect it from unauthorized access, modification or disclosure. User’s Personal Information, Sensitive Personal Data/Information or Personal Data is stored on secured servers that have SSL certificates issued by leading certificate authorities and all the Personal Information, Sensitive Personal Data/Information or Personal Data that is transferred between Users and Us and the Services provided to Users is encrypted. However, internet is not in itself a secure environment and We cannot give absolute assurance that Users Personal Information, Sensitive Personal Data/ Information or Personal Data will be secure at all times
G. COOKIES
Cookies are small files saved to the User’s computer’s hard drive that track, save and store information about the User’s interactions and usage of the Website. This allows the Website, through its server to provide the Users with a tailored experience within the Website.
Our Website uses “cookies” for better User’s experience while visiting the Website. We may also link information stored on your computer in cookies with certain Personal Information, Sensitive Personal Data/Information or Personal Data about specific individuals stored on our servers. If you set up your Web browser so that cookies are not allowed, you might not be able to use some or all of the features of our Web site(s).
Users are advised that if they wish to deny the use and saving of cookies from this Website on to their computer’s hard drive they should take necessary steps within their web browsers security settings to block all cookies from this Website and its external serving vendors.
H. EXTERNAL & THIRD PARTY LINKS
Although We make best efforts to include all kind of quality, safe and relevant external links/third party website links, Users should always adopt a policy of caution before clicking any external / third party website links mentioned anywhere on Our Website. These external links / third party links/ websites should have their own privacy policies which We urge the User to check. We do not accept any responsibility or liability for their third party websites policies whatsoever as we have no control over them.
We cannot guarantee or verify the contents of any externally linked website despite Our best efforts. Users should therefore note they click on external links at their own risk and Our Website and We cannot be held liable for any damages or implications caused by any User visiting any external links mentioned on the Website.
I. ADVERTISEMENTS AND SPONSORED LINKS
Our Website may contain sponsored links and advertisements. These will typically be served through our advertising partners, who may have detailed privacy policies relating directly to the advertisements they serve.
Clicking on any such advertisements will send you to the advertiser’s website through a referral program which may use cookies and will tracks the number of referrals sent from this Website. This may include the use of cookies which may in turn be saved on your computer’s hard drive. Users should therefore note they click on sponsored external links at their own risk and We cannot be held liable for any damages or implications caused by visiting any external links mentioned.
J. SOCIAL MEDIA PLATFORMS
Communication, engagement and actions taken through external social media platforms that Our Website participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy. Neither We nor Our Website will ever ask for Sensitive Personal Data or Personal Data through social media platforms and We encourage Users wishing to provide their Sensitive Personal Data or Personal Data to contact them through primary communication channels such as by telephone or email.
Our Website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
K. CHANGES TO PRIVACY POLICY
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our Website following the posting of any changes to this Privacy means you consent to such changes.
L. OPT-OUT
Any User can ask Us to stop sending them marketing messages or modify their email preferences at any time through any of the following methods:
By following the opt-out links on any marketing message sent to you; or
By contacting us at any time using the contact details in Contact Us;
Where any User opt out of receiving these marketing messages, this will not apply to Personal Information, Sensitive Personal Data or Personal Data provided to Us as a result of emails relating to existing or pending Services taken or consent to direct marketing communications.
M. CONTACT US
If you have questions or comments about Us or Our Website Privacy Policy, Please contact us via any of the ways described in the Contact Us page.
N. DECLARATION
Users within EU accessing Our Website or seeking Our Services hereby make an express declaration that they have consented for providing their Personal Data to Us.
Users hereby agree and confirm that by providing Us with their Sensitive Personal Data or Personal Data for requesting additional information or for registering on Our Website or for seeking Our Services, such Users shall be deemed to have freely and expressly granted consent to furnish such Sensitive Personal Data or Personal Data to Us of their own free will and they agree that they are not deceived or misled as to the purpose or purposes for which such Sensitive Personal Data or Personal Data will be processed. By providing the Sensitive Personal Data or Personal Data, Users also acknowledge being aware of the purpose for which such Sensitive Personal Data or Personal Data shall be Processed as such.
