“Personal Information”, as defined under Information Technology Act, 2000, Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, shall mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely available with a body corporate, is capable of identifying such person.
“Sensitive Personal Information” shall mean as defined under the Information Technology Act (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011
“Services” shall mean and include all our services and products made available to you by us through the Website.
HIGHWAVES TECHNOLOGIES PRIVATE LIMITED, a company registered under the Companies Act 2013 and having its registered office at #28, 16th Main Road, 38th Cross, Jayanagar 4th T Block, Bangalore – 560041 (“we” / “us” / “our”) owns and operates the domain name www.trilto.com (“Website”) and mobile application (“Trilto Chikoo”).
We believe that the users / subscribers (“you” / “your”) who avail the benefits and services through the Website / Mobile application has the right to know and understand our ethical standards in gathering, the purpose of gathering, using, handling, securing and safeguarding any Personal Information (as defined herein below) that you share with us. It also explains your options for accessing and managing all such Personal Information.
- Procure and/or intend to procure and/or inquire about any of our services (“Services”).
- Procure or subscribe to Services made available by us through any of our platforms / interface including without limitation Website, mobile site, Mobile application, software (collectively referred hereinafter as “Platforms”) and through our offline channels such as but not limited to call centres, offices, etc (collectively referred hereinafter as “Offline Channels”).
- Visits the Website
MINOR’S PERSONAL INFORMATION
We do not knowingly collect data of users younger than 18 years of age.
WHAT WE COLLECT AND HOW WE COLLECT ?
We collect the following-
- Personal Information
At the time of visiting the Website or any Platform and / or at the time of registering with us and while enjoying the Service, you share the following data / information with us – (a) your name, age, gender, date of birth, nationality, email address, phone number, information relating to address, billing information, etc; (b) social media account ID and other data publicly available or data made available by linking your social media, geographic location or phone number; (c) transactional information, such as but not limited to availing offers, use of our special services; (d) information you provide us when you contact us for help; (e) language preference, information you enter into Website while availing / using the Service, such as while asking doubts, participating in discussions and taking tests.
- Sensitive Personal Information
Depending on the type of Services that you may avail we may collect some Sensitive Personal Information such as password, transactional information, such as but not limited to your subscription payment details if any, any purchases such as offers etc, your choice of .
- Other Information
In addition to the above information / data, we may collect certain information automatically, such as but not limited to – (i) the type of mobile device you use, unique device ID of your mobile devices, log information of your mobile device or computer, operating system of your mobile or computer, the Internet browsers used by you to access the Websites and information about the way you use our Services through any Platform; (ii) browser and device data; (ii) app usage data (iii) data collected through Cookies, pixel tags and other technologies (iv) Demographic data and other data provided by you (v) Aggregated data. However, in case any Other Data identify you as an individual or relate to any particular individual, then we will treat such Other Data as Personal Information.
- Log information:
When you access our website, our servers automatically record information that your browser sends whenever you visit the Website. These server logs may include information such as but not limited to your web request, Internet Protocol address, browser type, browser language, the date and time of your requests raised, transcripts of any chat conversations and one or more cookies that may uniquely identify your browser. Please refer to “Cookies” to more about how we collect information using cookies.
5. User communications:
When you send email or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
- We collect certain data from Cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. A Cookie may also allow us to collect information about your path through our Website and to determine whether you have visited us before. However, unless you register with us, it will only collect Other Data. Cookies cannot be used to read data off of your hard drive and cannot retrieve information from any other Cookies created by other Web sites. These Information to help us understand how visitors use our site and help us to improve our site for various purpose including security purposes, to facilitate navigation, to display data and information more effectively, to collect statistical data, to personalize your experience while using any of the Platform(s) and to recognize your computer to assist your use of the Platform. We also gather statistical data about use of the Platform to continually improve design and functionality understand how they are used and assist us with resolving questions.
3. You may refuse to accept a Cookie from us by following the procedures specific to your Web browser. Although if you do so, you may find your browser to react strangely while visiting our Website and other websites as well. Since Cookies don’t provide us with any information from which we can identify you, we suggest you allow us to place one on your computer. If you are visiting a site where you will be accessing your confidential account information, you will be required to accept Cookies as it is essential for site administration and security.
4.You can choose whether to accept Cookies by changing the settings on your browser or by managing your tracking preferences. However, if you do not accept Cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs.
USAGE OF PERSONAL INFORMATION
We’ll use your information for various purposes to render Services to you as purchased, availed or subscribed by you and hence usage of some Information will depend on the type of Services for which you have engaged us. Under some circumstances we might require you to share the Information directly with us. In case you fail to provide such Information to us or prohibit us from collecting such information, then we might not be able to render you with your requested product or Services, for which we shall not be responsible / liable. We use all such Information for our genuine business purpose to render appropriate services, which includes without limitation the following-
1. We collect Personal Information from you to identify you, to provide you with information required to service you, to send you any communications related to the Services availed, subscribed or purchased by you. This shall include sending you email, sms, text messages etc to notify you of changes in our Services or features. We will also use your Information to update you with the latest news, events, offers, sales, brochures, marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys.
2. When you provide an email address at the time of purchasing / subscribing any Service, we use that email address to send you a copy of your invoice(s) and / or other notifications, documents related to your purchase / subscription. However, in case you are purchasing or subscribing any Service on behalf of any third person using your email address, then the invoice(s) and / or other notifications, documents related to the purchase or the subscription made for such third person will also be sent to you on the email address shared by you with us.
3. Information collected by us enables us to give you convenient access to our service offerings and products, and may help us tailor your requirement.
4. We collect Personal Information from you to combine them with individual data and behavior patterns so that we can provide you with targeted / personalized content. We will further use the information shared by you to ensure continuous better experiences.
5. We collect Personal Information from you to Develop new products, services, features, and functionality.
6. We collect Personal Information from you to for compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
PAYMENTS, DEBIT / CREDIT CARD AND OTHER BANKING DETAILS
When you purchase our Services, we track the web pages, and information that has been accessed by you, and store it on our servers. This enables us to track Services purchased by you and those that you need to see. However, in case of payments via credit or debit card or through Net Banking, you will be redirected to the webpage or application (as may be applicable) of concerned payment gateway providers such as but not limited to Razorpay etc or to the payment gateway of the banks (“Payment Gateway”), where you may save and store with the Payment Gateway your payment details such as but not limited to card holder’s name, card numbers, card expiry date and / or preferred Net Banking. Under no circumstances do we have access to any such data which is saved and stored by you with the Payment Gateway. Hence we do not store any data related to debit /credit cards and net banking details however, we have access to and may retain, subscriber information through the Payment Gateway. All payment transactions under the Website are processed through secured Payment Gateway.
Other than the abovementioned sharing of data related to credit card information, we only share Personal Information with other companies or individuals outside of HWT in the following limited circumstances:
- We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to :
- Satisfy any applicable law, regulation, legal process or enforceable governmental request, orders or instructions.
- Detect, prevent, or otherwise address fraud, security or technical issues, or
- Protect against imminent harm to the rights, property or safety of HWT, its users or the public as required or permitted by law.
- We may share with third parties certain pieces of aggregated, non-Personal Information, such as the number of users subscribed to a particular product, or the number of users registered on our website. Such information does not identify you individually.
- We may provide information to service providers to help us bring you the services we offer. Specifically, we may use third parties to facilitate our business, such as to host the service at a co-location facility for servers. Where we utilize third parties for the processing of any Personal Information, we implement reasonable contractual and technical protections limiting the use of that information to our specified purposes.
HOW LONG DO WE RETAIN USER DATA?
Currently, we plan to retain user data while an account is active and for at least three years afterward. We may alter this practice according to legal and business requirements. For example, we may lengthen the retention period for some data if needed to comply with law or voluntary codes of conduct. Unless otherwise prohibited, we may shorten the retention period for some types of data if needed to free up storage space.
THIRD PARTY ENTITIES
We are committed in protecting your Personal Information. We store you Personal Information in secured locations and servers. We take appropriate technical and organizational measures to protect against unauthorised or unlawful processing of Personal Information and against accidental loss or destruction of, or damage to, Personal Information, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the Information to be protected, having regard to the state of technological development and the cost of implementing any measures.
The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please bear in mind that the Internet, electronic data transmission or storage of information cannot be guaranteed to be 100% secure.
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with Service you have requested or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If you have consented to receiving marketing communications from us, we may continue to use your Information for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.
HOW CAN YOU PROTECT YOUR INFORMATION
In addition to us protecting your Personal Information, you can also protect your Personal Information if you take reasonable measures to protect the same, such as but not limited to – (i) Choose strong passwords and change them regularly (ii) at all times ensure that your passwords are kept confidential and ensure that you do not share them with anyone else; (iii) do not use your same password for multiple accounts (iv) if you are a registered user then you must ensure that you log out after each session; (v) in case you suspect that your password has been compromised or if someone may have accessed your account, then you must immediately inform us; (vi) keep your devices protected by ensuring that you’re using the latest version of your operating system and have suitable anti-virus software, if applicable; and (vii) stay away from any and all fraudulent emails.
We may alert you by email or phone (through sms/call) to inform you about new service offerings, progress reports, events or other information which we feel might be useful for you.
When you use certain features on our website like the discussion forums and you post or share your Personal Information such as comments, messages, files, photos, will be available to all users, and will be in the public domain. All such sharing of information is done at your own risk. Please keep in mind that if you disclose Personal Information in your profile or when posting on our forums this information may become publicly available.
YOUR CONSENT TO THIS POLICY
You have the right to access your Personal Information held by us and if necessary, have it amended, modified or deleted. However, please be informed that certain Services and features of the Platform requires your Personal Information. Hence, in case you delete your Personal Information then such Services and feature of the Platform may not be able to you. You can also request not to receive marketing communications from us through communications such as but not limited to email and SMS. You may opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails. Please note that we may still need to send you certain communications relating to your account or use of any of the Platforms and these transactional account messages may be unaffected if you choose to opt-out from marketing communications.
Address: #28, 16th Main Road, 38th Cross, Jayanagar 4th T Block, Bangalore – 560041