(Updated on: 6 July, 2023)
We collect certain Information because it is necessary for us to be able to provide and administer the Service and its features. We also collect certain Information to comply with specified statutory requirements. Such data is processed based on your consent. To the extent that processing is carried out on the basis of consent, it is for you to give such a consent and you may at any time, wholly or partly, withdraw your consent. Even if you have consented to our using your information for a specific purpose, you will have the right to change your mind at any time, but this will not affect any processing that has already taken place. Please note that for certain Services it is essential for us to access and use certain Information and if you refuse to provide us the consent, it may result in a suspension of your account.
2. Type of information collected by us
We collect the following information as and when you access and use the Services:
a. Personal information you may provide to us through the Service or otherwise includes:
(1) Contact data, such as your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number.
(2) Demographic data, such as your city, state, country of residence, postal code, and age.
(3) Profile data, such as the username and password that you may set to establish an online account on the Service, photograph or picture, preferences, and any other information that you add to your account profile.
(4) Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
(5) Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
(6) Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
(7) User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, submit to us as part of a contest or live event, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
b. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
(1) Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
(2) Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
(3) Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) -- we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
c. Some of our automatic data collection is facilitated by cookies and similar technologies. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service. Some of the automatic collection described above is facilitated by the following technologies:
(1) Cookies, which are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a session ends, "persistent cookies" that remain longer, "first party" cookies that we place and "third party" cookies that our third-party business partners and service providers place.
(2) Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
(3) Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
3. Purpose of collecting information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
a. Service delivery and operations. We may use your personal information to:
(1) provide, operate and improve Services and our business;
(2) personalizing our Services, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
(3) establish and maintain your user profile on Services;
(4) facilitate your invitations to friends who you want to invite to Services;
(5) enable security features of Services, such as by sending you security codes via email and remembering devices from which you have previously logged in;
(6) communicate with you about Services, including by sending service-related announcements, updates, security alerts, and support and administrative messages; communicate with you about events or contests in which you participate;
(7) understand your needs and interests, and personalize your experience with Services and our communications; and provide support for Services, and respond to your requests, questions and feedback.
b. Product improvement. As part of our efforts to improve Banva's Services, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve Services and promote our business and will not attempt to reidentify any such data.
c. Analytics and improvement of Services. We may use your personal information to analyze your usage of the Service, improve Services, improve the rest of our business, help us understand user activity on our Services, including which pages are most and least visited and how visitors move around our Services, as well as user interactions with our emails, and to develop new products and services.
d. Compliance and protection. We may use your personal information to:
(1) comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
(2) protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
(3) audit our internal processes for compliance with legal and contractual requirements or our internal policies;
(4) enforce the terms and conditions that govern the Service; and
(5) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
d. With your consent, in some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
e. Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
(1) Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
(2) Functionality. To enhance the performance and functionality of our services.
(3) Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
4. Sharing and Disclosure of your information
b. We may share the information to the third-party service providers/ vendors, to provide you with the Services.
c. We may disclose any Information provided by you when using our Services as may be deemed to be necessary or appropriate:
(1) under applicable law, including laws outside your country of residence;
(2) to comply with legal process;
(3) to respond to requests from public and government authorities including those outside your country of residence;
(4) to protect our operations or those of any of our affiliates;
(5) to protect our rights, privacy, safety or property, and/that of our affiliates, you or others;
(6) to allow us to pursue available remedies or limit the damages that we may sustain; or to protect against legal liability;
(7) to protect the personal safety of User;
(8) to prevent or investigate possible wrongdoing in connection with the usage of Services.
d. Merger or Acquisition: We may share Information upon merger or acquisition of Banva with another company.
e. With our service providers: We may share Information with other service providers on a need to know basis, subject to obligations of confidentiality for provision of Services. We hereby clarify that we work with institutions, vendors, partners, advertisers, and other service providers, including (but not limited) to those who provide products or services such as contact Information verification, website hosting, data analysis, providing infrastructure, information technology services, auditing services and other similar services, in different industries and categories of business by virtue of lawful contracts instituted between such third parties and Banva to improve our product and services. Accordingly, we may share your Information with such service providers in order to provide you with Services.
f. Employees /Agents of Banva: We follow a strict confidentiality policy with regard to disclosure of confidential information to our employees or other personnel. There may be situations, where we may disclose the confidential information only to those of our employees and other personnel on a need to know basis. Any breach of confidential information by the employees, personnel within Banva is dealt with stringently by us.
g. Except for the Information disclosed pursuant to this section, Banva may share Information only if you authorize us to do so.
5. Data Protection Rights
a. You have certain rights available to you when it comes to your Personal Information. Subject to any exemptions provided by the applicable laws, you have the following rights:
(1) Rectifying, correcting, updating and removing Your information: You can access your personal information at user profile on Banva website. You can edit or update your Personal Information by writing to us via email. We will provide you with information about whether we hold any of your Personal Information upon request. We will respond to such requests within a reasonable timeframe. Please note, however, that we may need to retain certain information for record keeping purposes, to complete our Services and related obligations to you or to comply with our legal obligations.
(2) Object or restrict processing of Your information: You have the right to: (i) object to our processing of your Personal Information; and/or (ii) request that we restrict the processing of your Personal Information.
(3) Portability: You shall have the right to request us to transfer Your Personal Information to you, in a commonly used structured machine-readable format.
b. In order to exercise these rights, please contact us at email@example.com.
6. Storage and transfer of Information
a. Your Information will primarily be stored in electronic form. However, it is possible certain data can also be stored in physical form. We may enter into agreements with third parties (in or outside of India) to store or process your information or data. These third parties may have their own security standards to safeguard your information or data and we will on a commercially reasonable basis require such third parties to adopt reasonable security standards to safeguard your information / data.
b. You agree, acknowledge and consent that we shall not be transferring any data, except for in the following scenarios:
(1) Where such transfer of data is to provide or improve our appropriate access.
(2) Where such transfer of data is to provide or impprove user-facing features that are visible and prominent while accessing Services.
(3) Where such transfer of data is for security purposes.
(4) Where such transfer of data is necessary to comply with applicable laws.
(5) Where such transfer is part of a merger, acquisition, or sale of assets after obtaining consent from the user.
(1) Authentication: If you’re signed in to the Services, cookies help us show you the right information and personalize your experience.
(3) Preferences, Features and Services: Cookies can tell us what your communications and product preferences are.
c. Controlling cookies: While you may block and/or limit our access to cookies, if you limit the ability of websites to set cookies, if may affect your overall user experience, since it will no longer be personalized to you. It may also stop you from saving customized settings like login information.
8. Data Retention
We will retain your Information for as long as your Account is active or as needed to provide our Services. We shall retain and use the Information collected by us as necessary to comply with our legal obligations, resolve disputes or for other Legitimate Purposes. If you cancel/ deactivate/unsubscribe your account with us, we are not under any obligation to retain your Information. However, may retain the Information pertaining to the User for the maximum period permitted under the law of the land from the date of deactivation of User’s Account.
9. Data Security
a. The security, integrity and confidentiality of your Personal Information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to be provided.
b. We may be required to share the aforesaid Personal Information with government authorities and agencies for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences. You agree and consent for us to disclose your information, if so required under the applicable law.
c. You agree and accept that your Information may be stored in third-party cloud service infrastructure providers. While all reasonable attempts have been taken from our end to ensure the safe and secure storage of your data, we shall not be liable for any data breach on the part of the third-party cloud service infrastructure provider that was beyond our control.
d. All interactions with our Services use the Transport Layer Security/Secure Sockets Layer (TLS/SSL) protocol. All data is encrypted via SSL/TLS when transmitted from our servers to your browser.
10. Do Not Sell
a. We do not sell your Personal Data.
b. We do not use, transfer or sell your Information to third parties like advertising platforms, data brokers, or any information resellers. We do not enable serving ads, including retargeting, personalized or interest-based advertising.
c. We do not do activities determining your creditworthiness or for lending purposes and do not transfer, sell, share your Information with any third party who is engaged in the same.
12. Grievance Officer
In furtherance of applicable laws including but not limited to the Information Technology Act, 2000 (“IT Act”) and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Guidelines”) a grievance officer is appointed to ensure compliance with the IT Act and the Intermediary guidelines. Any discrepancies or grievances with regard to content and or comment or breach of the Terms of Service shall be taken up with the designated grievance officer as mentioned below in writing or through email signed with the electronic signature to:
Name: Rahul Shivaji Pawar
The grievance officer on behalf of Banva shall take best possible efforts to redress the complaint within 30 days of receipt of the complaint.