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Privacy Policy
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Privacy Policy - Subscribers

At Deskfactors, we are committed to ensuring that your Personal Information is kept secure. We understand the importance of your privacy and do our best to prevent any compromise to the same. With this Privacy Policy for Subscribers( ‘Privacy Policy’ or ‘Policy’), we aim to inform you on the manner in which your Personal Information will be either collected, processed, stored or transferred.

Deskfactors Inc. is a company incorporated and registered in the state ofDelaware, USA (the "Company”) with the followingState File Number: 20202357853. For the purpose of this Privacy Policy, "you", “your” or "Subscriber/s" as used herein refers to Company’s customers or Subscribers registering, subscribing to, accessing or using the Platform for the Services and or who acts as an administrator capable of adding other Users to the Platform; the word “user”as used herein refers to anyone, including any individuals and/or entities registering, accessing or using the Platform as a user and/or who is added to the Platform by the Subscriber or an Internal User; and the words “we”, “our” or “us” means the Company rendering certain services on the Platform.

This Privacy Policy for Subscribers applies to all of our products and/or Services, including our software, applications, our cloud-based platform and/or mobile application known as [Bluesecures](“Platform”). We recommend that you also read our Terms of Use for Subscribers (“Terms of Use”)along with any additional terms or policies uploaded onto our Website [www.bluesecures.com] (the “Website”). This Policy, the Terms of Use and any other policies, guidelines made applicable to you, from time to time, along with any agreements you might have entered into with us pertaining to the use of our Services, constitute the entire agreement between us and you with respect to your access to or use of the Platform or Website and the product or Services.

We collect certain information of yours during the registration/ subscription process and access/ use of our Platform by you. We would like to assure you that we are accountable for the protection of your Personal Information/information and take all commercially reasonable steps to stay compliant in this respect, in accordance with applicable laws.

This Policy is to help you understand as to what information of yours is collected by us, what rights you have over your PersonalInformation and how you can at all times exercise the rights over your PersonalInformation. You have the following basic rights: right of access, right of erasure, right of rectification, right to be informed and the right to opt-out. The rights available to you are further enumerated hereunder.

We will also clarify as to what purpose your Personal Information will be collected, used, disclosed and/ or processed; whether the Personal Information will be shared with third parties and the purpose for which it will be shared. The Policy also explains as to where your Personal Information is being stored and how long we intend to keep it.

Please, read this Policy carefully, and if you agree to provide your consent with respect to your Personal Information in terms as given here, please continue and register, subscribe to, access and use our Services. Based on your location and the jurisdiction of law you fall under, you agree that you are of appropriate legal age or older to visit, access and/or use the Services in any manner. By registering, subscribing, accessing and/or using our Services you represent and warrant to the Company that you are of the appropriate legal age or older, and that you have the right, authority and capacity to use the Service and that you agree to the terms of this Policy. If you are not of appropriate legal age to access and/or use the Service, then you must not proceed further with the access and/or use. Deskfactors shall not be held responsible if you do not fulfil these criteria and continue to access and/or use the Service.

I. POLICY UPDATES AND APPLICABILITY

A. This Privacy Policy applies to the current and former visitors to the Platform or Website. By visiting, registering, subscribing to and/or using our Services, (i) you are expressly consenting to our collection, processing, storing, disclosing and handling of your information as set forth in this Privacy Policy, as amended by us from time to time; and (ii) you are accepting the processes and methods utilized as described in this Privacy Policy.

B. Unless otherwise specifically defined in this Privacy Policy, the terms defined in the Terms of Use shall apply to this Privacy Policy. Terms not defined in the Privacy Policy or the Terms of Use shall be deemed defined as per the applicable Agreements in place or as per applicable law, as the case may be.

C. This Privacy Policy applies to our Platform and Website as well as for the use of any of our products, services, content, features, technologies, or functions offered on our Website and all related sites, services and applications (if any) (collectively referred to as “Services”), whether such Services are currently provided or will be provided to our Subscribers/ Users in the future.

D. The Policy shall apply with respect to the collection and processing of any Personal Information (defined below) by us. We are not obligated to render the same level of protection when considering Non-Personal Information, anonymized information or other information provided by you.

E. Changes may be made to this Privacy Policy from time to time without prior notification. To make sure that you are aware of any changes, kindly review the Privacy Policy updates periodically.

F. This Privacy Policy does not apply to any third-party applications, software or services that may be used or integrated along with our Platform or Website, any services not provided by us on the Marketplace or any Non-Deskfactor applications made available to you. Such third-party applications, software or services would be governed by their own policies in this regard. Matters concerning licensing, delivery, payments, customizations, maintenance and support offered, if any, along with other such expressed terms covered in the respective third-party agreements, including but not limited to, any license/ service/ partnerships or alliance agreements (“Agreements”) entered into with us shall be read together and construed, to the fullest extent possible, to be in concert with the Terms of Use, the Privacy Policy and any policies/guidelines applicable at that time.

G. The terms of this Policy do not apply with respect to any Personal Information, including but not limited to, any information, media, files, images, documents, reports, statement, or content you or your User submits, hosts, posts, uploads or displays on or through the Platform (“User Content”) to which the Company will not have any visibility or access to. This Policy shall apply to only the Personal Information shared with us by you while registering/subscribing for and/or accessing and using our Services (“Subscriber Data”). User Content shall be governed by the term of the privacy policy between the Subscribers and their Users. Under this Privacy Policy we play the role of data controller and processor as identified under General Data Protection Regulation (Regulation (EU) 2016/679) (European Union), Protección de Datos de Carácter Personal del 13 de diciembre de 2013 (Dominican Republic), Law on the Protection of Persons Regarding the Processing of their Personal Data No. 8968 of 2011(Costa Rica), Data Protection Act 2011 (Trinidad and Tobago), Data Protection (Privacy of Personal Information) Act 2003 (Bahamas), Data Protection Act 2011 (Saint Lucia), Law No. 1581 of 2012 (Colombia), Personal Data Protection Law N° 29733 (Peru) and Law No. 18.331 on the Protection of Personal Data and the Habeas Data Action 2008 (Uruguay); a data user as identified under the Data Protection Act 2013 (Antigua and Barbuda) and The Personal Data Protection Law 25.326 (Argentina); a business or service provider as identified under California Consumer Privacy Act 2018, subject to meeting certain requirements under CCPA (California); a controller or processor as identified under Lei GeralProtecao de Dados Pessoais 2018 (Brazil), Federal Law for the Protection of Personal Data Held by Private Parties 2010 (Mexico) and Ley De Protección De DatosPersonales 2012 (Nicaragua); an organization of service provider as identified under Personal Information Protection and Electronic Documents Act 2000 (Canada) or an organization or data intermediary as defined under Personal Data Protection Act 2012 (Singapore) (the title of such roles many vary in nomenclature in accordance with the titles given under the applicable data protection laws under which we may be governed by) ; India, Asia Pacific, and other countries as applicable and appropriate, of the Personal Information provided to us by you alone.We will play the role of either a data collector or processor or such other similar/equivalent roles as identified under the applicable laws as stated above. Our role as a collector and/or processor is limited to only Personal Information relating to (i) natural persons; or (ii) a consumer/household as identified under CCPA.

H. The applicability of certain rights available to you involving the understanding of and choice available over the collection, processing, disclosure and/or storage of Personal Information may vary depending on the country from which you avail our Services. The same shall be stated more specifically below in Clause VI.

II. INFORMATION COLLECTED AND/OR PROCESSED

A. Information collected and processed may be classified into Personal Information and Non-Personal Information. Personal Information relates to any personally identifiable information such as your name, email ID, address, contact number, etc. Non-Personal Information can be any information that may not be directly linked and identified as being related to you. Non-Personal Information may be collected when you visit our Website, however, Personal Information is collected only when you provided it to us.

B. We collect and/or process the following types of Personal Information when you register, subscribe to, access or use our Platform, in order to facilitate your use of ourServices and to help improve your experience. We also collect and/or process information about your transactions and your activities:

(i) Full name, designation, gender, nationality, date of birth, country and city;

(ii) E-mail addresses, contact numbers and postal or other such addresses including IP address information, cookies, location information and log data;

(iii) Login details such as screen name and/or user name;

(iv) Information required towards the processing of invoicing such as name, number, company name, company location, unique tax identification codes, business category, business sector, business type, industry and company URL and such other information reasonably needed;

(v) Other information that may be collected and/or processed through the access and use of our Platform and Services, some of which will be optional.

III. CONSENT

A. We believe that every Subscriber of our Service must be in a position to provide informed consent prior to providing any required Personal Information.

B. We understand the importance of data privacy and protection. We normally collect and process Personal Information under a lawful basis for the purpose of fulfilling our contractual obligations with you and for providing our Services in the manner intended. By registering, subscribing to, accessing and using our Platform and Services, it is understood that you have provided us consent which is free, and informed. By providing us such consent you agree to your Personal Information being used for the purposes as set out under Clause IV below.

C. You have the option to change or withdraw consent with respect to the collection, use, disclosure, processing or storage of Personal Information belonging to you, subject to the rights and exceptions that are applicable to you. Please reach to us at the belowmentioned email address for the same.

IV. PURPOSE OF COLLECTION, PROCESSING, USE AND DISCLOSURE OF INFORMATION

A. We collect, process, use, store and disclose your Personal Information for the following purposes:

(i) using our product features such as generating reports, creating profiles, registering for third-party services, participating in online surveys or discussion groups and/or forums and for registering to our newsletters;

(ii) providing you with the required feedback, support and assistance in order to effectively use our Platform and avail ourServices;

(iii) providing the required customizations and improvements in order to better your experience of our Platform or Website;

(iv) researching, designing and launching new features or products on our Platform or Website by understanding the manner in which you use our Services and the preferences shown by such usage;

(v) presenting content and information in our Website and/or Platform in the most effective manner for you and for the device you use;

(vi) providing you with alerts, updates, materials or information about our Services or other types of information such as our latest enhancements, software updates, software upgrades, system enhancements and special offers;

(vii) complying with applicable laws and regulations;

(viii) responding to or taking part in legal proceedings, including seeking professional advice;

(ix) communicating with you and responding to your questions or requests; and

(x) for purposes arising from or incidental to the above.

B. We may use your Personal Information and other information for direct marketing i.e. offering or advertising products or services by sending the relevant information directly to you by email, in-app message, phone messages or calls.

C. You acknowledge that your Personal Information may be disclosed to our partners and third-party service providers in the course of providing Services to you and that your Personal Information will be used by our partners and third-party service providers for the purposes of providing the Services to you. We do not permit our third-party service providers to use the Personal Information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

D. We may also share such Personal Information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any Subscriber or User, violations of our Policy, Terms of Use of any Agreements we may have in place, or as otherwise required by law.

E. Collecting, storing, deleting, processing, using, combining, sharing, transferring and disclosing your Personal Information may take place within Singapore, North America, South America or Europe Union,India, Asia Pacific and other such countries as applicable and appropriate., as the case may be. We strive to ensure compliance with all applicable laws depending on the jurisdiction applicable to you.

V. DATA STORAGE

Your Personal Information is stored securely in our or third-party servers situated in the same or the nearest location within which the collection or processing of your Personal Information takes place usually as is derived from your location.

VI. YOUR RIGHTS

A. Users located within either the European Union, North America, South America, Singapore, India, Asia Pacific and other such countries as applicable and appropriate,have certain statutory rights available to them, based on the country’s jurisdiction under which they fall, in terms of their Personal Information. You may have a right to:

(i) request for access to your Personal Information;

(ii) request for copies of the same, subject to a minimal fee as applicable;

(iii) ensure the Personal Information provided to us is up to date and to request for correction of the Personal Information if found to be inaccurate;

(iv) withdraw consent or opt-out of certain Services;

(v) restrict or object to the processing of your Personal Information;

(vi) disclosure of Personal Information disclosed for valuable consideration;

(vii) not be discriminated against while exercising certain rights;

(viii) transfer or delete or erase your Personal Information under certain conditions;

(ix) lodge a complaint with the relevant data protection authority; and

(x) any other right as available to you under the relevant law.

B. These rights are subject to any applicable fees, limitations and exceptions, as the case may be, in accordance with the laws applicable to you.

C. We request a period of 10 (ten) days to one month, depending on the jurisdiction and the type of request, to respond to any requests made. If you wish to exercise any of your rights, please contact us at the email address provided in Clause XII.

VII. COOKIES AND ONLINE ADVERTISING

Cookies: Deskfactors may use cookies on the Website to analyze trends, administer the Website and track user movements in order to ensure better performance and to gather demographic information about our user base as a whole. Cookies help personalize and maximize your use of our Website, including storing user preferences, improving search results, advertisement selection and tracking user trends. You may choose to delete or block our cookies at the browser level, but if you choose to do so, it will limit your use of certain features or functions pertaining to our Services. We may collect, process and store any Personal Information you provide us when you use Services or Platform, including when you add information on a web form, add or update your account information, or when you correspond with us regarding the Services.

VIII. THIRD-PARTY WEBSITES

Our Platform, Website and our communication with you may from time to time contain links to third-party websites, over which we have no control. If you follow a link to any of these websites, please note that they have their own terms, practices and policies. You agree to read the privacy policies and the terms of use of these websites and understand your rights therein. We accept no responsibility or liability for any practices of any third-party websites.

IX. SECURITY

All information provided by you to us is stored on our or third-party secure servers. We protect your information using physical, technical, and administrative security measures to reduce the risks such as loss, misuse, unauthorized access, disclosure and alteration. We use the relevant industry standard encryptions like HTTPS and practices like protection against cyber-attacks, data encryption practices (such as SSL certificates), firewalls and information access authorization controls. We make best efforts to ensure that the security practices adopted by us are reasonably at par with industry standards. Further:

(i) We restrict access to Personal Information to our contractors hired for investigating any fraud, suspected illegal activities, of breach of this Policy by the you or the user on a strictly need-to-know basis and ensure that such persons/ entities are subject to contractual confidentiality and privacy obligations as applicable to them.;

(ii) We review our collection, storage and processing practices from time to time to guard against unauthorized access, processing or use;

(iii) Please note, however, the Transmission of information or Personal Information via the internet is not completely secure. While we make our best efforts to protect, save and secureany of your information or User Content that you use, generate, upload, display, secure, store, access, transmit (“Transmission”), we cannot guarantee the safety and security over the Transmission of your information or User Content on or via our Platform or Website; and any such Transmissionis at your own risk.

X. RETENTION OF DATA

A. Notwithstanding any other provisions under this Clause X, we will retain your Personal Information for as long as it is necessary to provide you with Services. Further, we may also be obligated to retain certain Personal Information under the applicable laws and/or as part of our contractual obligations with third-parties; and accordingly, such Personal Information shall be retained as prescribed under applicable laws or as part of our contractual obligations.

B. User Content will normally be retained for a 30 (thirty) day period or such other period determined solely at the discretion of Deskfactors with or without any notice thereof, post termination or suspension of Services to allow you to download the User Content. Such User Content will be automatically deleted upon completion of such period, as earlier stated, as the case may be. The right to download is available only upon successful completion of payments due by the Subscribers for utilizing our Services.

C. We may also retain (i) your Personal Information even after you have closed your account on the Platform, if reasonably necessary to comply with our obligations including law enforcement requests, to meet regulatory requirements, resolve disputes, investigate security incidents, prevent fraud and abuse, enforce our Agreements, or to fulfil your request to “unsubscribe” from further messages from us and/or(ii) retain anonymized information after your account has been closed and may continue to use your anonymized information aggregated or in combination with anonymized data of other Subscribers or users.

D. We will respond to information access, copying, blocking, unblocking, correction, deletion, suspension or transfer requests (“Requests”) within a timeframe of 10 (ten) to 30 (thirty) days. If we require additional time to cater to your Requests, we will acknowledge receipt of your request within such timeframe and do our best to promptly supplement our response within the time period (if any) required by applicable law.

XI. CROSS BORDER TRANSFERS

A. We do not share your Personal Information with third-parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, to fulfil our contractual obligations or as required or permitted by law. Where we do transfer your Personal Information to third-parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.

B. We store Personal Information about Subscribers within the Europe Economic Area, the United States, Singapore, Canada, India, Asia Pacific and in other countries and territories in accordance with where you are located. To facilitate our global operations, we may transfer and access such Personal Information from around the world. Therefore, your Personal Information may be processed outside of the country from where your Personal Information was collected and to countries which may not have an adequate level of data protection as per received under the applicable data protection laws. In this event, we will ensure that the recipient of your Personal Information offers an adequate level of protection or we will ask you for your prior consent to such international data transfers.

C. While one cannot guarantee total data protection, we have done our best to implement reasonable safeguards to ensure an adequate level of data protection where your Personal Information is transferred to other countries.

XII. CONTACT US

If you have any questions, comments or requests regarding Personal Information, please contact our data protection officer at blue@bluesecures.com.

XIII. GOVERNING LAW

This Privacy Policy is published and shall be governed by and construed in accordance with the applicable laws of the State of Delaware, as amended from time to time, without reference to conflict of laws principles. The courts in Delaware, USA, shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, this Privacy Policy. Subscriber agrees to submit to the jurisdiction of the courts in Delaware, USA, and agree to waive any and all objections to the exercise of jurisdiction over the parties by such courts and to venue in such courts.

LAST UPDATED: [Feb 01, 2022]
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Privacy Policy - Users

At Deskfactors, we are committed to ensuring that your Personal Information is kept secure. We understand the importance of your privacy and do our best to prevent any compromise to the same. With this Privacy Policy for Users ( ‘Privacy Policy’ or ‘Policy’), we aim to inform you on the manner in which your Personal Information will be either collected, processed, stored or transferred.

Deskfactors Inc. is a company incorporated and registered in the state of Delaware, USA (the "Company”) with the following State File Number: 20202357853. For the purpose of this Privacy Policy, "you", “yours” and "users" as used herein refers to anyone, including any individuals and/or entities registering, accessing or using the Platform as a user and/or who is added to the Platform by the Subscriber or Internal User;the word “Subscriber” as used herein refers to anyone, including any individuals and/or entities subscribing to, registering, accessing or using the Platform as an administrator and who is able to add users to the Platform.; andthe words “we”, “our”or “us” means the Company, rendering certain services on the Platform.

This Privacy Policy for Users applies to all our products and/or services including our software, applications, our cloud-based platform and/or mobile application known as Bluesecures (“Platform”). We recommend that you also read our Terms of Use for Users (“Terms of Use”) along with any additional terms or policies uploaded onto our Website [www.bluesecures.com] (the “Website”). This Policy, the Terms of Use and any other policies, guidelines made applicable to you, from time to time, along with any agreements your Subscriber might have entered into with us pertaining to the use of our Services, constitute the entire agreement between us and you with respect to your access to or use of our Services. For any information with respect to the terms of the agreement your Subscriber has entered into with us, please contact your Subscriber.

Your Subscriber is the data controller with respect to your Personal Information. A data controller determines the purposes for which and the meansby which your Personal Information is processed. Your Subscriber has collected/will be collecting certain information of yours during the registration/ subscription process and access/ use of our Platform by you. The Subscriber will be fully accountable for the protection of your Personal Information and is mandated by law to take all necessary steps to stay compliant in this respect in accordance with the applicable laws. Please, read this Policy thoroughly to learn the details of what information of yours requires protection, what rights you may have on your Personal Information and how to exercise these rights, what Personal Information of yours is being collected by your Subscriber, the meansby which your Personal Information is processed and the purpose for which it’s collected, how your Personal Information will be used/ stored/ protected/ disclosed/ transferred etc., how you can exercise your rights over your Personal Information, whether your Personal Information will be shared with third parties and the purpose for which it will be shared, where your Personal Information is being stored and how long we intend to keep it, and other related information/ details you might find useful.

Any policies in place between you and the Subscriber with regard to any Personal or Non-Personal information shared shall stand separate from this Policy.

Please, read this Policy carefully, and if you agree to provide your consent with respect to your Personal Information in terms as given here, please continue and register, access and use our Services. Based on your location and the jurisdiction of law you fall under, you agree that you are of appropriate legal age or older to visit, access and/or use the Services in any manner. By registering, accessing and/or using our Services you represent and warrant to the Company that you are of the appropriate legal age or older, and that you have the right, authority and capacity to use the Service and that you agree to the terms of this Policy. If you are not of appropriate legal age to access and/or use the Service or to provide consent, then it will be understood that your parent or guardian expressly agrees to consent to our terms on your behalf by allowing you to access and/or use the Service. The Subscriber shall take full responsibility of ensuring such express consent has been obtained from the parent or guardian in order to allow for your access and/or use of the Service and shall not hold Deskfactors responsible for any failure to obtain such express consent.

I. POLICY UPDATES AND APPLICABILITY

A. This Privacy Policy applies to the current and former visitors to the Platform or Website. By visiting, registering and/or using our Services, (i) you are expressly consenting to the Subscriber’s collection, processing, storing, disclosing and handling of your Personal Information as set forth in this Privacy Policy, as amended by us from time to time; (ii) you are expressly consenting to our processing, storing, disclosing and handling of your Personal Information as set forth in this Privacy Policy; and (iii) you are accepting the processes and methods utilized as described in this Privacy Policy.

B. Unless otherwise specifically defined in this Privacy Policy, the terms defined in the Terms of Use shall apply to this Privacy Policy. Terms not defined in this Privacy Policy or the Terms of Use, shall be deemed defined as per the applicable Agreements in place or as per applicable law, as the case may be.

C. This Privacy Policy applies to our Platform and Website as well as for the use of any of our products, services, content, features, technologies, or functions offered on our Website and all related sites, services and applications (if any) (collectively referred to as “Services”), whether such Services are currently provided or will be provided to the users in future.

D. The Policy shall apply with respect to the collection and processing of any Personal Information (defined below) by the Subscriber and the processing of any Personal Information by us. Neither the Subscriber nor we are obligated to render the same level of protection when considering Non-Personal Information, anonymized information or other information provided by you.

E. Changes may be made to this Privacy Policy from time to time without prior notification. To make sure that you are aware of any changes, kindly review the Privacy Policy updates periodically.

F. This Privacy Policy does not apply to any third-party applications, software or services that may be used or integrated along with our Platform or Website, any services not provided by us on the Marketplace or any Non-Deskfactor applications made available to you. Such third-party applications, software or services would be governed by their own policies in this regard. Matters concerning licensing, delivery, payments, customizations, maintenance and support offered, if any, along with other such expressed terms covered in the respective third party agreements, including but not limited to, any license/ service/ partnerships or alliance agreements (“Agreements”) entered into with us by your Subscriber shall be read together and construed, to the fullest extent possible, to be in concert with the Terms of Use, the Privacy Policy and any policies/guidelines applicable at that time.

G. The terms of this Policy shall apply to any Personal Information, including but is not limited to, any information, media, files, images, documents, reports, statement, or content you or your Subscriber submits, hosts, posts, uploads or displays on or through the Platform (“User Content”) to which the Company will not have any visibility or access to. Under this Privacy Policy your Subscriber will play the role of data controller and processor as identified under General Data Protection Regulation (Regulation (EU) 2016/679) (European Union), Protección de Datos de Carácter Personal del 13 de diciembre de 2013 (Dominican Republic), Law on the Protection of Persons Regarding the Processing of their Personal Data No. 8968 of 2011(Costa Rica), Data Protection Act 2011 (Trinidad and Tobago), Data Protection (Privacy of Personal Information) Act 2003 (Bahamas), Data Protection Act 2011 (Saint Lucia), Law No. 1581 of 2012 (Colombia), Personal Data Protection Law N° 29733 (Peru) and Law No. 18.331 on the Protection of Personal Data and the Habeas Data Action 2008 (Uruguay); a data user as identified underthe Data Protection Act 2013 (Antigua and Barbuda) andThe Personal Data ProtectionLaw 25.326 (Argentina); a business or service provider as identified under California Consumer Privacy Act 2018, subject to meeting certain requirements under CCPA (California); a controller or processor as identified under Lei Geral Protecao de Dados Pessoais 2018 (Brazil),Federal Law for the Protection of Personal Data Held by Private Parties 2010 (Mexico) and Ley De Protección De Datos Personales 2012(Nicaragua); an organization of service provider as identified under Personal Information Protection and Electronic Documents Act 2000 (Canada) or an organization or data intermediary as defined underPersonal Data Protection Act 2012 (Singapore)(the title of such roles many vary in nomenclature in accordance with the titles given under the applicable data protection laws under which we may be governed by); India, Asia Pacific, and other countries as applicable and appropriate,of the Personal Information provided to the Subscriber by you alone. We will play the role of either a data processor, service provider, processor or such other similar/equivalent roles as identified under the applicable laws as stated above. The Subscriber’s role as a data collector is limited to only Personal Information relating to (i) natural persons; or (ii) a consumer/ household as identified under CCPA.

H. The applicability of certain rights available to you involving the understanding of and choice available over the collection, processing, disclosure and/or storage of Personal Information may vary depending on the country from which you avail our Services. The same shall be stated more specifically below in Clause VI.

II. INFORMATION COLLECTED AND/OR PROCESSED

A. Information collected and processed may be classified into Personal Information and Non-Personal Information. Personal Information relates to any personally identifiable information such as your name, email ID, address, contact number, etc. Non-Personal Information can be any information that may not be directly linked and identified as being related to you. Non-Personal Information may be collected when you visit our Website, however, Personal Information is collected only when you provided it to the Subscriber while entering such Personal Information under the designated profile assigned to you by the Subscriber and while uploading any User Content.

B. The information collected by us with regards to you shall only befor statistical data analytics purposes and to correctly invoice and bill the Subscriber as well as log data such as IP address, location and cookie information that may be provided to third-party applications or services providers in order to serve our legitimate interests and to accurately provide you with the Services.

C. The Subscriber may collect and/or process the following types of Personal Information when you access or use our Platform, in order to facilitate your use of our Services and to help improve your experience. Our processing of your Personal Information will be in accordance with our contractual obligations to provide the Services to the Subscriber and to you and we will not have any access of visibility to such information. Subscriber may also collect and/or process information about your activities:

(i) Full name, designation, gender, nationality, date of birth, country and city;

(ii) E-mail addresses, contact numbers and postal or other such addresses including IP address information;

(iii) Login details such as screen name and/or user name; and

(iv) Other information that may be collected and/or processed through the access and use of our Services, some of which will be optional.

III. CONSENT

A. We believe that every user of our Service must be in a position to provide an informed consent prior to providing any required Personal Information.

B. We understand the importance of data privacy and protection. We process Personal Information under a lawful basis for the purpose of fulfilling our contractual obligations with the Subscriber and for providing our Services in the manner intended. By registering, accessing and using our Services, it is understood that you have provided us consent which is free, and informed. By providing us such consent you agree to your Personal Information being used for the purposes as set out under Clause IV below.

C. You have the option to change or withdraw consent with respect to the collection, use, disclosure, processing or storage of Personal Information belonging to you, subject to the rights and exceptions that are applicable to you. Please reach out to the Subscriber via email or using the chat feature within the Platform in order to exercise any such option.

IV. PURPOSE OF COLLECTION, PROCESSING, USE, STORAGE AND DISCLOSURE OF INFORMATION

A. The Subscriber collects, processes, uses, stores and or discloses your Personal Information for the purposes:

(i) of using our Platform features such as generating/ sharing content, communicating with other users, creating profiles, registering for third-party services, participating in online surveys or discussion groups and/ or forums and for registering to our newsletters;

(ii) of communicating with you and responding to your questions or requests, providing you with the required feedback, support and assistance in order for you to effectively use our Platform and avail our Services;

(iii) of assessing the required customizations in order to better your experience of our Platform or Website;

(iv) of complying with applicable laws and regulations;

(v) of responding to or taking part in legal proceedings, including seeking professional advice; and

(vi) as arising from or incidental to the above.

B. You acknowledge that your information may be disclosed to our partners and third-party service providers in the course of providing Services to you and that your Personal Information will be used by our partners and third-party service providers solely for the purposes of providing Services to you. We do not permit our partners and third-party service providers to use the information, that we share with them, for their marketing purposes or for any other purpose other than in connection with the services they provide to us.

C. We or the Subscriber may shareyour Personal Information if it is believed that it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any Subscriber or User, violations of our Policy, Terms of Use of any Agreements we may have in place, or as otherwise required by law.

D. Collecting, storing, deleting, processing, using, combining, sharing, transferring and disclosing your Personal Information may take place within Singapore, North America, South America or Europe Union, India, Asia Pacific and other such countries as applicable and appropriate., as the case may be. We strive to ensure compliance with all applicable laws depending on the jurisdiction applicable to you.

V. DATA STORAGE

Your Personal Information is stored securely in our or third-party servers situated in the same or the nearest location within which the collection or processing of your Personal Information takes place usually as is derived from the Subscriber location.

VI. YOUR RIGHTS

A. Users locatedwithin either the European Union, North America, South America, SingaporeIndia, Asia Pacific and other such countries as applicable and appropriate, have certain statutory rights available to them, based on the country’s jurisdiction under which they fall, in terms of their Personal Information. You may have a right to;

(i) request for access to your Personal Information;

(ii) request for copies of the same, subject to a minimal fee as applicable;

(iii) ensure the Personal Information provided is up to date and to request for correction of the Personal Information if found to be inaccurate;

(iv) withdraw consent or opt-out of certain Services;

(v) restrict or object to the processing of your Personal Information;

(vi) disclosure of Personal Information disclosed for valuable consideration;

(vii) not be discriminated against while exercising certain rights;

(viii) transfer or delete or erase your Personal Information under certain conditions;

(ix) lodge a complaint with the relevant data protection authority; and

(x) any other right as available to you under the relevant law.

B. These rights are subject to any applicable fees, limitations and exceptions, as the case may be, in accordance with the laws applicable to you.

C. We request a period of 10 (ten) days to one month, depending on the jurisdiction and the type of request, to respond to any requests made. If you wish to exercise any of your rights, please contact the Subscriber via email or by using the chat feature available on the Platform.

VII. COOKIES AND ONLINE ADVERTISING

Cookies: Deskfactors may use cookies on the Website to analyze trends, administer the Website and track user movements in order to ensure better performance and to gather demographic information about our user base as a whole. Cookies help personalize and maximize your use of our Website, including storing user preferences, improving search results, advertisement selection and tracking user trends. You may choose to delete or block our cookies at the browser level, but if you choose to do so, it will limit your use of certain features or functions pertaining to our Services. The Subscriber may collect, process and store any Personal Information you provide when you use Services, including when you add Personal Information on a web form, add or update your account information, or when you correspond with the Subscriber while using our Services.

VIII. THIRD-PARTY WEBSITES

Our Platform, Website and our communication with you may from time to time contain links to third-party websites, over which we have no control. If you follow a link to any of these websites, please note that they have their own terms, practices and policies. You agree to read the privacy policies and the terms of use of these websites and understand your rights therein and adhere to the same. We accept no responsibility or liability for any practices of any third-party websites.

IX. SECURITY

All information provided by you is stored on our or any third-party secure servers. We protect your information using physical, technical, and administrative security measures to reduce the risks such as loss, misuse, unauthorized access, disclosure and alteration. We use the relevant industry standard encryptions like HTTPS and practices like protection against cyber-attacks, data encryption practices (such as SSL certificates), firewalls and information access authorization controls. We make best efforts to ensure that the security practices adopted by us are reasonably at par with industry standards. Further:

(i) We restrict access to Personal Information to our contractors hired for investigating any fraud, suspected illegal activities, of breach of this Policy by the user on a strictly need-to-know basis and ensure that such persons/ entities are subject to contractual confidentiality and privacy obligations as applicable to them.

(ii) We review our collection, storage and processing practices from time to time to guard against unauthorized access, processing or use.

(iii) Please note, however, the Transmission of information or Personal Information via the internet is not completely secure. While we make our best efforts to protect, save and secure any of the Subscriber information or User content that you use, generate, upload, display, secure, store, access, transmit (“Transmission”), we cannot guarantee the safety and security over the Transmission of such Subscriber information or User Content on or via our Platform or Website; and any such Transmission is at your own risk.

X. RETENTION OF DATA

A. Notwithstanding any other provisions under this Clause X, we will retain your Personal Information for as long as it is necessary to provide you with Services or as directed by the Subscriber. Further, wemay also be obligated to retain certain Personal Information under the applicable laws and/ or as part of our contractual obligations with the Subscriber or any third parties; and accordingly, such Personal Information shall be retained as prescribed under applicable laws or as part of our contractual obligations.

B. The Subscriber decides whether to add, retain, suspend or delete a User. Also, the Subscriber may determine whether to retain or delete the User Contentin partial or full for whatever duration the Subscriber deems appropriate.

C. We may also retain (i) your Personal Information even after you have closed your account on the Platform, if reasonably necessary to comply with our obligations including law enforcement requests, to meet regulatory requirements, resolve disputes, investigate security incidents, prevent fraud and abuse, enforce our Agreements, or to fulfil your request to “unsubscribe” from further messages from us, and/or (ii) retain anonymized information after your account has been closed and may continue to use your anonymized information aggregated or in combination with anonymized information of other users.

D. The Subscriber will respond to your access, blocking, un-blocking, copying, correction, deletion, suspension or transfer requests (“Requests”) within a timeframe of 10 (ten) to 30 (thirty) days. Such requests will be forwarded to us by the Subscriber when the Subscriber is unable to fulfil the request from their end. If we require additional time to cater to such Requests, we will acknowledge receipt of your request within such timeframe and do our best to promptly supplement our response within the time period (if any) required by applicable law.

XI. CROSS BORDER TRANSFERS

A. We do not share your Personal Information with third-parties, unless we are directed to do so by the Subscriber, for our professional or legitimate business needs, to fulfil our contractual obligations with the Subscriber or as required or permitted by law. Where we do transfer your Personal Information to third-parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.

B. The Personal Information collected by the Subscriber may be stored within the Europe Economic Area, the United States, Singapore, Canada, India, Asia Pacificand in other countries and territories in accordance with where you are located. To facilitate our global operations, we may transfer such Personal Information from around the world. Therefore, your Personal Information may be processed outside of the country from where your Personal Information was collected and to countries which may not have adequate level of data protection as perceived under the applicable data protection laws. In this event, the Subscriber will ensure that the recipient of your Personal Information offers an adequate level of protection before directing/allowing us to facilitate such transfer or the Subscriber will ask you for your prior consent to such international data transfers.

C. While one cannot guarantee total data protection, we have done our best to implement reasonable safeguards to ensure an adequate level of data protection where your Personal Information is transferred to other countries.

XII. CONTACT US

If you have any questions, comments or requests regarding the Personal Information that we process, please contact our data protection officer at blue@bluesecures.com. Any questions regarding collection and processing of your Personal Information by the Subscriber may be directed to the Subscriber by using the chat feature found within the Platform or via e-mail.

XIII. GOVERNING LAW

This Privacy Policy is published and shall be governed by and construed in accordance with the applicable laws of the State of Delaware, as amended from time to time, without reference to conflict of laws principles. The courts in Delaware, USA, shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, this Privacy Policy. You agree to submit to the jurisdiction of the courts in Delaware, USA, and agree to waive any and all objections to the exercise of jurisdiction over the parties by such courts and to venue in such courts.

LAST UPDATED: [Feb 01. 2022]
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We protect what matters the most – your data