INFORMATION COLLECTED

1. The information collected from you by the Company may constitute ‘personal information’ which term has been defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (hereinafter referred to as the “SPI Rules”). The SPI Rules define “Sensitive Personal Data or Information” of a person to mean personal information about that person relating to:

a) Passwords;

b) financial information such as bank accounts, credit and debit card details or other payment instrument details;

c) physical, physiological and mental health condition;

d) sexual orientation;

e) medical records and history;

f) biometric information;

g) information received by body corporate under lawful contract or otherwise; and

h) visitor details as provided at the time of registration or thereafter.

2. In the course of providing services to you through the platform, we may collect the following:

a) Personal identifiable information regarding you such as your name, phone number, profile picture, username, password and the e-mail address when you register on the Platform for its usage.

b) The information provided by you on your social media accounts, which will be linked with the account created by you on our Platform, information disclosed therein, including but not limited to the username as provided by you at the time of sign-up, and publicly available data of those social media accounts such as any posts, comments, likes posted on such accounts, any personal information provided provided by you in your private profile qua such accounts and any such other information that may be required or be related to for better rendering of the Services by CLABSTA so as to give you, the user, a better, seamless and effective as well as efficient experience of the Platform.

c) With your permission, we may automatically collect information about your hardware devices when you access the Platform. It is fairly being informed to you that when you utilize our Platform, we may collect the IP address of the device from which you are accessing the services provided by our Platform along with what type of mobile device/computer/laptop you use and your geographic location. Most devices allow you to prevent location data from being shared to us and you have every right to not share the same with us, we honor whatever decision you make qua the said aspect. We may also collect information about your activity on the Platform, such as information about your account usage, as well as information about how you interact with the Platform (collectively, “User Data”). We may combine this automatically gathered information with other information, including Personal Information we have collected about You.

d) If you allow access to the cookies on your browser, we may receive and store certain kinds of information stored in the form of small text termed as “cookies” whenever you avail the services being provided by our Platform.

e) Any Communication that has happened at any point of time between you and CLABSTA.

3. CLABSTA shall, for the better working of the platform, for more effective and efficient working, for the benefit of users of CLABSTA and for the better working of the company itself so as to provide seamless experience to the users, reserve the right to be free to use, collect and disclose information that is freely available in the public domain without Your consent.

4. The User guarantees that the personal data provided is true and is responsible for communicating to CLABSTA any modification thereof. The User will respond, in any case, for the veracity of the data provided, keeping CLABSTA the right to exclude from the registered services any User who has provided false data, without preconception to the other actions that proceed in Law.

5. In order to provide services through the platform, we may require the user to provide us with certain information that personally identifies himself. Personal Information includes the following categories of information:

a) Contact data including email address, phone number and call recording; and

b) Demographic data (such as time zone, postal address and location details); and

c) If the user communicates with us via any mode of communication so as to register with us to avail the services, any information provided in such communication may be collected by us.

d) For security purposes and to create an impediment against the wrongful gain or wrongful loss to any person or legal entity, financial data of the user including account details, e-wallet details, bank account or information provided under credit or debit card or any such details while the buyer makes a payment using any other payment instrument, provided by the user may provide us so as to avail the services provided by the Platform.

6. When you make your profile on our platform, for providing effective and efficient service to you, you can share with us additional information, such as details regarding your personality, lifestyle, interests and other details about you. By choosing to provide this information, You consent to our act of processing of the said information.

7. All such information is stored or used for providing a better quality of Service to you and to create an impediment against the happening of any unlawful or immoral act, and to take an effective action against any wrong-doer. Moreover, we may use this information to share with you any additional and/ or upcoming information regarding the Services offered by the Platform.

8. Our Platform may contain links directing you to third party websites or applications. The user agrees and understands while being in the domain of other such third party websites or application,the privacy policies, and terms and condition the user agrees to, with the said party are not under our control and the user understands that once he or she leaves our servers, use of any information provided by the user shall be governed by the privacy policy of the operator of the site used by them.

9. Prior to any direct marketing or commercial operation for the benefit of the user including, but not limited to sending the newsletters or commercial offers we will first obtain user’s consent to do so either when you create an account on the platform or later by indicating your consent of allowing to do the same by accessing the account settings and allowing to do the same. Users shall always reserve the right to withdraw his or her consent at any time, directly by clicking on the unsubscribe link available on each email received, by modifying his account settings, or by contacting us at the following email address hello@clabsta.com

10. In accordance with the laws exercising jurisdiction over the working and activities being done on our platform, the user has the right to access, to rectify and to object qua any data concerning them. Users can access and change their profile picture, display name and user’s username and the password of their profile, at the time of creating the profile and thereafter, the said changes can be made by accessing the settings provided on our platform qua the same or by contacting us hello@clabsta.com

11. We may disclose any personal information we may deem necessary, in our sole discretion, in accordance with law and terms and condition set between CLABSTA and you, furthermore, comply with any of the applicable laws, regulations, legal process, or any request furthered by any concerned authority, be it governmental or otherwise, whereby such request made a third private party is backed and required by law, in order to investigate, prevent or take action regarding illegal activities, suspected fraud, so as to prevent happening of any such act which may result into unlawful gain or unlawful loss to any person or legal entity, and any situation involving potential threats to the physical and mental safety of any person or as otherwise required by law. The user shall understand that such transfer or disclosure of any data shall be for lawful purposes only. Further, such transfer or disclosure of your sensitive personal information to any such third party aforementioned shall only be done once it is ensured by us that the third party receiving such information has implemented the same level of security practices as we have, and will secure your data in accordance with law.

12. We take your right to privacy very seriously and other than as specifically stated in this privacy policy, will only disclose your personal information in the event it is required to do so by applicable law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or any request made by a third party, when such request is is made in accordance with law, by which we are required to furnish such information for lawful purposes, or when CLABSTA in its sole discretion, deems it necessary in order to protect its rights or the rights of others,or to prevent harm to persons or property, to fight fraud and credit risk, so as to prevent happening of any such event which may result in wrongful gain or wrongful loss to any person or any third party or to enforce or apply the Terms of Use.

13. Further, we, the team of CLABSTA declare that we adhere to strict norms in disclosing the Personal Information of its user. We understand that privacy is a fundamental right of a person, and it shall be maintained and upheld at a higher standard. Any such disclosure of personal information of the user, will only be disclosed in accordance to law, and while keeping in mind the rights of the user to keep it protected.

Use of Personal Information

1. We and third-party data processors, who will be working under the direct control of us qua the instructions we will provide for better services to the users, vendors and hosting partners who may be acting on Our behalf may collect, store and process your personal data/ information for the following reasons:

a) to make this platform customized in accordance to the specific needs of users, so as to provide them a better service, in accordance with law, and to provide content tailored to individual requirements; to understand your needs and provide you with improved products and Services, newsletters and other communications and to enable others to view submissions made by users and posts and blogs of users;

b) to maintain any registered accounts that you may hold with us and to provide You with updates or notifications of changes to your account;

c) for our internal record keeping requirements including collection of anonymized details about visitors to our website to compile aggregate statistics or produce internal reports, which in turn would be used for a better user experience and needs;

d) with your agreement, to contact you about our or our business partners’ promotions, products and services or other information which we think you may find interesting, and seems useful to you, offers, or for customer satisfaction purposes;

e) for market research, analysis, testing, monitoring, risk management and administrative purposes (including diagnosing technology problems which may be reported to us); and

f) for any purposes related to the above or where we have a legal right or duty to use or disclose your personal data/ information (including for abuse, crime and fraud prevention and related purposes).

g) To better understand how users access and use our Service, both on an aggregated and individualized basis;

h) user posted content may be reused by us to aggregate data about a particular activity or location and include it in consolidated formats.

2. If it is brought to our notice that we have somehow collected or been sent personal data/ information from a person who is under 18 (eighteen) years of age, without the consent of the parent or guardian, we will deactivate the relevant account as soon as is reasonably practicable by us. It is the endeavour of CLABSTA that while carrying out any operation while the platform of CLABSTA is being used, no right of any minor is infringed, his interests are safeguarded, and he/she is protected from any mishappening.

3. Your personal information may be disclosed as part of any merger, sale of company assets or acquisition, as well as in the event of insolvency, bankruptcy or receivership, in which personal information would be transferred as one of the business assets of the Company.

4. Further, in an ongoing effort to better understand and serve the users of our Service, we also often conduct research on its customer demographics, interests and behavior based on the personal information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with Our affiliates, agents, advertisers and business partners. It shall be understood by the user that in the said operation, no such personal information of the user is given which may personally identify any user specifically. We may also disclose aggregated user statistics in order to describe our service to current and prospective business partners and to other third parties for other lawful purposes (including providing advertising use cases to actual or potential advertisers).

USAGE OF COOKIES

Your Internet browser has the in-built facility for storing small text files termed as cookies that hold information which allows a website to recognize your account. Our website takes advantage of this facility to enhance your experience. You have the ability to prevent your computer from accepting cookies but, if you do, certain functionality on the website may be impaired, and there may be a hindrance to the user in experiencing a seamless experience.

SECURITY

1. The security of data provided by the user and Personal Information of the user present with us is important to us. We secure the said data by adhering to the accepted industry norms and standards to protect the user data and personal information submitted to us, both during transmission and once we receive it. All information gathered on Our Platform is securely stored. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. Such information may also be converted to physical form from time to time, if deemed necessary. We take all necessary precautions to protect Your Personal Information both online and off-line, and implement strict and reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Our business.

2. Although we make best possible efforts to store personal information in a secure operating environment that is not open to the public, users must understand that there is a chance of something happening whereby some personal information of the user may get disclosed, although every safety measure for prevention of the happening of the same is placed, therefore, we do not guarantee that there will be no unintended disclosures of personal Information. If and when we become aware that Personal Information of the user has been disclosed in a manner not in accordance with this privacy policy, we will use reasonable efforts to notify such user of the nature and extent of such disclosure as soon as reasonably possible and as permitted by law, and take required action in the event of happening of the same.

3. For security from your part, so as to prevent the happening of any such aforementioned even, you should:

if using a computer in a public place or location, whereby the device does not belong to you and even otherwise, always log out and close the website browser as soon as you complete your online session;

- keep Your account details and passwords private;

- keep a complex password, and avoid using the same password for multiple online accounts.

4. Depending on the processing of personal information, the data may be subject to a different storage period.

5. We do not sell users personal information to any advertisers or any third party. We use users' personal data only to display relevant advertisements for efficient and effective service, based on his preferences, for which his personal data has been retrieved and put to use. We make reports related to the advertisement campaigns, in particular statistics, without any reference or information related to the personal information of visitors or users of the Platform.