Privacy Policy

This Privacy Policy (“Policy”) governs the manner in which Divy Skil Private Limited (the “Company” or “We”) collects, gains access to, uses, maintains, stores, transfers/shares, and discloses information, including personal or sensitive personal data or information of the users (each, a “User” or “You/you” or “Your/your” or “Customer”) of various services rendered by the Company (“Services”) either through the portal/website of the Company or through mobile applications (collectively referred to as “Platform”). Please note that the scope of this Policy is limited to the aforesaid information collected or received by the Company through your use of the Services. By using the Services, you are expressing your agreement to this Policy and the processing of your information, including your Personal Information and non-personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Services and do not provide the permissions when specifically asked by the Company.

All the terms and conditions/policies in respect of the Services provided by the Company (as set out in the Terms and Conditions or any other policies of the Company) are incorporated in this Policy by reference. The Policy seeks to comply with the provisions of the Information Technology Act, 2000 (“Act”) and the Information Technology (Reasonable security practices, procedures and sensitive personal data or information) Rules, 2011 (“Rules”).

What We Collect

We may collect and/or gain access to and/or record certain information, including personal information from or of Users in a variety of ways, including, but not limited to, when Users access and use the Services and in connection with other activities, services, features, or resources we make available on the Services. This information may relate to and include, but is not limited to, your name, date of birth, gender, father’s name, mother’s name, marital status, email address, address (including PIN code, city, state, residence type), phone number (including alternative mobile number, reference mobile number, reference person name), your unique device ID (persistent/non-persistent), photograph/selfie, your KYC details/documents, business details/documents (including business address), PAN Number, GST details (including extracting of GST from PAN or from GST Number), hardware type, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address (if you have connected to Facebook or Google+), and your location (based on your Internet Protocol (“IP”) address) (including demographics (LAT LONG) on various stages), applications installed by Users through our mobile application, applications uninstalled by Users, all other applications installed by Users on their devices, foreground running apps/process (RUN event; We update the server about the app downloaded/installed by our mobile application), SMS data and read SMS, network information, User behaviour analysis, demographic information (such as preferences and interests, etc), Credit/Debit Card information of Users for Internet banking (We do not store credit/debit card information on our servers), credit or affluence-related information or assessment and/or documents, user-selected offers, bank statements (upload or net banking), personal bank account numbers and bank account data/details including e-NACH, NEFT, IMPS, UPI ID details, salary and income details. Users can always refuse to supply Personal Information; however, it may prevent them from engaging in certain Services-related activities.

What We Do with the Personal Information We Gather

We may use your Personal Information to:
– Administer the Services.
– Provide User direct links to the Services.
– Process transactions.
– Process installation.
– Send Users our newsletter.
– Develop, deliver, and improve our products, services, content, and advertising.
– Send important notices, such as communications about purchases/downloads and changes to our Policy.
– Conduct auditing, data analysis, and research to improve the Services.
– Troubleshoot and help us understand usage trends.
– Send notifications and alerts to Users.
– Market and promote the Services.
– Send transactional information and other necessary information by SMS and other electronic modes.

Security

We are committed to ensuring that the User’s Personal Information is secure. We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of the User’s Personal Information, username, password, transaction information, and data stored in our Services/eco-system.

When a User uses Services and products offered by us through the Services, the Personal Information shared by the User is visible to the other users and can be read, collected, or used by them. The User is responsible for the Personal Information they choose to submit in these instances. For example, if the User lists their name and email address in a blog/forum posting, that information is public. Users are requested to take care when using these features.

Retention of Personal Information

We will retain User’s Personal Information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

Sharing Personal Information

We may use third-party service providers to help us operate our business and Services or administer activities on our behalf, such as sending out newsletters or surveys. We may share the User’s Personal Information with these third parties for those limited purposes.

Third-Party Websites

Users may find advertising or other content on the Services that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and services and are not responsible for the practices employed by those websites and services linked to or from our Services. In addition, these sites and services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites and services which have a link to the Services, are subject to that website and service’s terms and policies.

How We Use Cookies

A cookie is a small file that asks permission to be placed on the User’s desktop/laptop/mobile device’s memory drive. Once the User agrees, the file is added and the cookie helps analyze web traffic. Cookies allow services to respond to the User as an individual. The services can tailor its operations to the User’s needs, likes, and dislikes by gathering and remembering information about the User’s preferences.

Cookies help us better understand User’s behavior and tell us which part of the services Users have visited and facilitates and measure the effectiveness of products and services offered by us. We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Information by applicable law, we also treat these identifiers as Personal Information.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our services in order to tailor them to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide Users with a better experience of Divy Skil Private Limited services, by enabling us to monitor which pages Users find useful and which Users do not. A cookie in no way gives us access to the User’s desktop/laptop/mobile device or any information about the User, other than the data a User chooses to share with us.

A User can choose to accept or decline cookies. Most web browsers automatically accept cookies, but a User can usually modify their browser setting to decline cookies if the User prefers. This may prevent the User from taking full advantage of the services.

Advertising

Advertisements appearing on the Divy Skil Private Limited services may be delivered to the User by advertising partners, who may set cookies. These cookies allow the ad server to recognize the User’s computer each time they send the User an online advertisement to compile non-personal information about the User or others who use the User’s computer. This information allows advertisement networks to, among other things, deliver targeted advertisements that they believe will be of most interest to the User. This Policy does not cover the use of cookies by any advertisers.

Divy Skil Private Limited Shall Access, Preserve, and Share Your Information

(i) With regulators, law enforcement, or others in response to a legal request (e.g., a search warrant, court order, or subpoena) if we have a good-faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions anywhere in India or abroad when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with Indian recognized standards.

(ii) When we have a good-faith belief that it is necessary to: detect, prevent, and address fraud, unauthorized use of the products, violation of our Terms or Policies, or other harmful or illegal activity; to protect ourselves (including our rights, property, or products and services), the User, or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we exchange information with third-party partners about the reliability of your account to prevent fraud, abuse, and other harmful activity on and off our products and services.

Information that we receive about you (including financial transaction data) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our Terms or Policies, or otherwise to prevent harm.

Observation of Reasonable Security Practices

Divy Skil Private Limited shall take all reasonable precautions to maintain the confidentiality of Personal Information/data pertaining to its Users and business associates by imparting proper training to its employees and by providing restricted access to persons who may require access to such data strictly on a need-to-know basis.

Links to Other Websites

The website contains links to other websites. Please note that when Users click on one of these links, they enter into another website for which Divy Skil Private Limited takes no responsibility. Divy Skil Private Limited encourages Users to read the privacy statements/terms and conditions of all such websites as their policies/terms and conditions may be materially different from this Privacy Policy. Users are solely responsible for maintaining the secrecy of their passwords and other membership account information.

New Owner

If the ownership or control of Divy Skil Private Limited or all or part of our products and services or their assets changes, we may transfer the User’s information to the new owner.

Updates to this Privacy Policy

Divy Skil Private Limited may change the data privacy practices and update this privacy statement as and when the need arises, and the same shall be made available on the website. Users and business associates are requested to keep check on the same.