Updated in January 2022
Objective and Scope
Greynium Information Technologies Private Limited. (“We”, “us”, “our”, “Greynium”) values the trust placed in us by the data subject (“you”, “your”, “user”, “subscriber”) and therefore, we assure that we follow the highest standards of privacy guidelines to protect the information shared by you with us.
All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Service.
1. User Consent
By using Greynium (for example, when you register for an account, enter a contest or promotion, communicate with us, on our sites or applications), you agree to provide consent to our collection, use and sharing of your personal information as described in this policy. In some cases, particularly if you reside in a country governed by a data protection regulation, we may ask you to provide explicit consent to access our services before proceeding for further operations.
If you are a traveller visiting various countries around the world and avail the Platform’s services, then we will determine your location using your IP address to determine the relevant Greynium’s services that should be offered to you. In the event IP detection fails, we will consider the last cached location as your current location to provide you with Greynium services and the consents obtained at the time of registration in that location will be valid for processing of your personal information. We use third-party service providers to help us determine your location to provide you with appropriate content and services on our Platform.
2. Collection and Use of Personal Information
‘Personally Identifiable Information’ or ‘PII’ is defined as any information that identifies (whether directly or indirectly) to a particular individual or natural person, such as the individual’s name, postal address, email address, mobile number and any other specific identifier indicating that particular person. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.
A. Information you provide to us
Information Collected at the Time of Registration
When you register using your social media accounts or any third-party applications, we retrieve the following information from your account(s) to continue to interact with you and to continue providing you the Services. Information that we collect include –
- User Name
- E-mail id
- Mobile number
- Public profile information – (Facebook & Twitter) Information collected under my profile section when a user has completed the registration:
- Date of Birth
- Profile picture upload
We may collect sensitive personal information when you provide feedback, report spam, participate in polls, surveys, contests etc. for the activity it is being collected. This information will only be captured if you have provided us with explicit consent.
Information you provide to us voluntarily
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect and store such information.
We may collect additional information at other times, including but not limited to, when you provide feedback(s), modify your content or email preferences, respond to surveys, provide comments, or communicate with us. This information may include your name, e-mail id, mobile number, location, etc.
B. Information automatically collected while browsing /navigating through the website
Log File Information
We automatically collect limited information about your computer’s connection to the Internet, mobile number, including your IP address, whenever you visit our website(s), application or services. Your IP address is a number that lets computers attach to the Internet and recognize where you send data – For e.g. pages you viewed. We automatically receive and log information from your browser, including your IP address, your computer’s name, your operating system, browser type and version, CPU speed, and connection speed. We may also collect log information from your device, including your location, IP address, your device’s name, device’s serial number or unique identification number (e.g. UDID on your iOS device), your device operating system, browser type and version, application version, operator name, screen size, CPU speed, and connection speed etc.
C. Inferred Information through usage and log data
We may track certain information about you based upon your behaviour on the Platform. We use this information for conducting internal research on our users’ demographics, devices, interests, and behaviour to better understand, protect and serve our users.
We may also collect Your Information to track user behaviour and preferences for internal analytics and research. We may also use your information:
i. To evaluate your interest in various genres of content, services, offers;
ii.To perform analytics and conduct customer research, to determine your interest, for identifying content that generates sales and to analyze traffic patterns. If you choose to post messages on social media accounts, message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
The above information may also be captured by keeping cookies on our websites by our affiliates for the purposes mentioned above.
D. Information we collect from third parties
a) Information obtained from other Sources
We may receive information about you from other online sources. We may add it to our account information system and treat it in accordance with this policy. If you provide information to the platform provider or other partner to whom we provide services, your account information including PII may be passed on to us. We may obtain updated contact information(s) from third parties in order to correct our records and fulfill the Services or to communicate with you or share the information with any third party.
b) Information obtained from third party websites(if applicable)
If you link, connect or login to your Greynium’s platform account with third-party services they may send us information such as your registered e-mail id and public profile information from the service as stated below;
- Facebook – Email ID and public profile information which includes name, profile picture, age, gender etc.
- Twitter – Email ID, see who you follow, read tweets from the timeline, post tweets for you, access direct messages and update your profile
c) Demographic and other information
We may reference other sources of demographic and other information to provide you with more targeted communications and promotions. We use various third-party analytics service providers, among others, to track user behavior on our website. They are used to support display advertising towards helping us gain an understanding of our users’ Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out or opt-in by giving consent to serve you advertisements when you visit our website or applications.
d) Subscription or Paid service information (If applicable)
When you choose any subscription or paid service, we or our payment gateway provider may collect your personal information such as address or billing information, including your credit/debit card number and expiration date in the tokenized form in accordance with the applicable laws. The subscriptions or paid Services may be on auto renewal mode unless cancelled. If at any point you do not wish to auto-renew your subscription, you may cancel your subscription before the end of the subscription term or contact us on our support email.
*In case of sharing or referring the subscription to another user then the personal information of the referrer will only be used for the purpose for which it has been shared by the user. Other than the purpose, We won’t provide or process the referrals’ personal information for analytics, direct marketing etc. without prior consent provided by the referral to receive such services from us.
e) Transactional and Billing Information
Based on your purchase of a subscription or paid service, our payment gateway partner may collect information, including but not limited to, your credit/debit card details or other bank account details along with your billing address. This information is stored by the payment gateway partner. For instance, the Services will be using third-party payment gateway partners to process and facilitate the payment of your subscription fee to the Services for providing you access to the subscription; such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to providing them with information about you or entering into any transactions with them. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them.
We may receive financial or transactional information (for e.g., transaction ID, order ID etc.) from third-party vendors in case of payments, for reconciliation and validation of transactions and also for the purpose of resolutions of complaints (in case of failed transactions and refunds).
3. What purposes your data are used for
The data is used for providing personalized news feeds on the Platform based on the content preference and reading habits of the user. Personal and other information you may provide when registering, subscribing and/or responding to surveys may be used for the following purposes:
- to provide better usability, troubleshooting and site maintenance
- to understand which parts of the website are visited and how frequently
- to create your user ID
- to identify you once you register on our website
- to contact you and respond to your questions or requests
- to provide access to desirable content based on your preferences
- for marketing communications – we may use your information and share with our business partners for marketing purposes, as permitted by law
4. Data Retention and Erasure
Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.
If you no longer want us to use your information then you can request that we erase your personal information. Please note that if you request for the erasure of your personal information, your request will be processed and you will receive confirmation of the same via email. Please note that this will only perform a deletion of the information that has been collected by Greynium.
You can request for deletion of your information by writing to our designated Grievance Officer via email signed with the electronic signature to email@example.com
5. What we don’t do with your personal data
a. Greynium does not sell, trade, or rent Your personal information collected by Greynium to third parties except as provided in this Policy. Greynium may share generic aggregated demographic information not linked to any personal information, regarding visitors and users with Greynium’s business partners, contractors, affiliates (including Greynium Innovation) and advertisers.
b. Greynium may be required by law or litigation to disclose personal information about the Users. Greynium may also disclose information about the Users if Greynium determines that for national security, law enforcement, or other issues of public importance that disclosure of the information is necessary.
6. How we process these data
The collected data are processed in several ways. We use your personally identifiable information (name, email address, etc.) to identify you in order to contact you, send a newsletter, and provide products & support. The non-personal data may be used to improve the service. We share your Personal Information within
- Greynium’s Business Verticals (Departments)
- Business partners;
- Service vendors;
- Authorized third-party agents.
7. Control of Your Information
All users may elect to stop receiving marketing material from us or on behalf of external third-party business partners by following instructions at the end of any such email received. You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you.
8. To Target Content and Advertising
We may use your user information for advertising purposes in order to promote our Site or our other products or services, and the products and services of third parties. To develop and provide content and advertising to you that is targeted to your interests, we use the analytics collected by the systems described above to determine which areas of our Site you prefer based upon the frequency of your visits and engagement with those areas.
9. As Necessary to Provide Services to You
We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of email or newsletter mailings, processing transactions, or performing statistical analysis of our services. We will only provide those companies with the user information they need to deliver the service. In all cases, these companies are subject to agreements that require them to maintain the confidentiality of your user information and they are prohibited from using that information for any other purpose.
10. Third party links on our website
We may talk about third-party products and services on our website. Third-party sites have their own privacy policies. So, therefore, we have no responsibility or liability for the content and activities of these linked sites.
11. What data breach procedures we have in place
If in any case a breach of data such as loss, alteration, unauthorized disclosure or access, personal data transmission, storage or otherwise happens, we will notify you reasonably as soon as possible. Greynium adopts reasonable and appropriate security practices and procedures and technical controls in order to safeguard your Personal Information.
We may use information collected from ourCookies to identify user behavior and to serve content and offers based on your profile, and in order to enhance the convenience of the users of our Site.
Information on the Types of Cookies that are used on our Site
We have provided details of the types of cookies that are used on our Site as well as other relevant and useful information on the Cookies. You can also find more information on the Cookies when you click the pop-up window “[name of the pop-up banner]”.
- Technical Cookies: These cookies are necessary to enable you to move around our Site and use its features.
- Analytical Cookies: These cookies are used by us or third-party service providers to analyze how our Sites are used and how they are performing.
- Functionality Cookies: These cookies allow our Site to remember the choices you make when you visit our Site in order to provide enhanced, more personalized features to you.
- Advertising and Retargeting Cookies: These Cookies save information from your browsing history in order to record your interests and your browsing path on our Site. We may use advertising and targeting cookies for retargeting, which enables our advertising partners to target advertising to you on other websites, based on your visit to our Site. Without these Cookies, online advertisements you encounter will be less relevant to you and your interests.
You can write to us in case of any grievance or complaint at the support email address. If you have any complaints regarding the processing of your personal information you may contact our data protection officer at the below-mentioned email address.
15. Security and Compliance with Laws
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall on the cloud; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. If you know or have reason to believe that your Greynium account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting us on the below-mentioned information.
16. By downloading, install and Contacting Us
Mr. Ajay Mohan,