1. INTRODUCTION

Addtitans Digital Private Limited is a company incorporated under the laws of India, having its registered office at Unit 204, U.S.Complex 120, Mathura Road, Jasola,New Delhi 110076 [hereinafter referred to as “We” or “Us” or “Company” or “ADDTITANS DIGITAL PVT LTD”].


According to all the applicable laws, we have curated in this Privacy Policy [Hereinafter referred to as “Privacy Policy” or “Policy” or “Privacy Statement”] showed in the interest of order demonstrated in our or the company’s privacy policy and commitments made towards the data of individual we collect, store and process for our services to be provided or offered, includes individual visiting our websites  [www.addtitans.com].


This Privacy Policy primarily helps you to understand:

  • The nature of the information collected from you

  • The sources of your information from where it is collected

  • The manner in which we collect your information

  • The purpose that why we collect your information

  • The manner in which we store, use, and process your information is stored

  • The rights you have regarding such information collected by us under applicable laws

  • The process to contact us regarding the collection or use of your information if there arises an issue.

2. SCOPE OF PRIVACY POLICY

As it is mentioned above, we collaterally intend to inform you about how and why we collect, define and use your data or personal information whenever you use our website and/or rely on the services we provide to the user. Additionally, any such personal information or data shared with us by third parties is covered under the treatment of our Privacy Policy.

3. GOVERNING LAWS

We are an organization based and existing in India and are thus bound by the laws of the Union of India. This Privacy Policy has been prepared according to the applicable Indian laws, including the Indian Information Technology Act, of 2000.

This Policy, however, contains some specific provisions following the “Regulation on the protection of natural persons concerning the processing of personal data and the free movement of such data and repealing Directive 95/46/EC” [Hereinafter referred to as “GDPR”]. These Specific Provisions are only applicable to EU Residents. EU Residents, in the context of this Policy, are those individuals who are entitled to the protection of their rights under the GDPR.

Thus, depending on the place where you reside, some specific provisions and rights of a data subject, as it’s mentioned in this Privacy Policy, may change or not apply to you.


4. APPLICABILITY TOWARD THE USER

This Privacy Policy applies to all visitors to our website, either individuals to whom we provide our services or the other individuals who provide their personal information to ADDTITANS, including individuals whose data is provided to us by third parties. All such users, visitors, and other individuals are hereinafter referred to as “Data Subjects''.


5. OBJECTIVES OF OUR PRIVACY POLICY

This above-mentioned Privacy Policy is intended to inform the Data Subject such as on how we collect, define, and utilize personal data or information that a Data Subject directly or indirectly provides to ADDTITANS while using our website for such services, social media platforms, or when relying on our services.

This Privacy Policy also covers our treatment of any personal data or information that third parties share with “US” or ADDTITANS.

  • This Privacy Policy will primarily help a Data Subject to understand the:
    The nature of the information that we collect about a Data Subject directly or through any such third parties;
    The sources from where the information of Data Subject is collected;

  • The manner in which we collect the Data Subject’s information;

  • The purpose behind collecting the information on a Data Subject;

  • The manner in which the information of a Data Subject is stored, utilized, and processed by ADDTITANS;

  • The rights a Data Subject has under applicable laws regarding such information collected by ADDTITANS;

  • The process to contacting ADDTITANSS for any such issues regarding the collection or use of a Data Subject’s information.

6. CATEGORY OF INFORMATION COLLECTED AND UTILIZED

A Data Subject’s Information collected by ADDTITANS primarily consists of personal information and/or sensitive personal information [Collectively referred to as “Information” or “Data Subject Information”].

  • PERSONAL INFORMATION
    When a Data Subject makes a visit to the ADDTITANS’s website or enters his/her information on any internet form that is owned by ADDTITANS, we may directly collect or ask the Data Subject to provide the following Personal Information, intentionally:

  1. First Name and Last Name/surname

  2. Personal Email ID

  3. Company or its name

  4. Skype ID

  5. IP Address

  6. Mobile Number/ Contact number

  7. Other information that is required to offer you the best possible services from our side

  8. Behavioral or demographic attributes, when tied to personal identifiers


  • Additionally, third parties to whom ADDTITANS provides its services may provide us with certain personal data of Data Subjects such as:

  1. IP Address

  2. Device Identity

  3. ISP

  4. User Agent

  • Personal information here means any information about a Data Subject from which that individual/ person can be identified. It excludes data where the identity has been removed [anonymous data] such as cookies, web beacons, and other

  • Browsing information.
    Browsing Information is the information collected through cookies and web beacons to track what sort of features or web pages you have viewed/searched on our website, which also includes other information about your browser and browsing behavior. In order to improve, amend, or effectively redesign our website’s performance, we use your browsing information, and phrases to suggest content and/or a product to be curated for our users, which can add value to our audience to help learn new stuff every time they visit our website. We also make sure by gaining access to your information that which type of web search entices you to see promotions of or to gauge the advertising campaigns our company holds. 

Cookies and web beacons are the technology to generate a collection of browsing information, you can rectify this by simply blocking cookies to control your data collection related to your interest-based advertising. You can conventionally do so through your browser at either end. For such sort of instructions, check the section of your browser which says technical information. Preventing the browser on your phone from accepting cookies, creates a hindrance from collecting your data browsing information for delivering you the fastest internet-based ads experience.

However, it may also disable or interfere with other features on our website. For example, cookies allow us to remember your preferences when you log out of your account and then log in again. Cookies also allow us to recognize you as an account holder when you return to our website. Most browsers accept cookies automatically.
Additionally, while you visit our website, we automatically receive and record certain information about your session. Like many other websites, our website uses log files to do so. These files merely log visitors to the website which is a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol [IP] addresses, browser type, Internet Service Provider [ISP], date/time stamp, referring/exit pages, and possibly the number of clicks made by you. This information is used to analyze trends, administer the website, track your movement around the website, and gather demographic information. These log files and the information contained in them, such as IP addresses, and other such information, cannot be used by us to identify or ascertain your identity.

  • SENSITIVE PERSONAL INFORMATION & DATA
    Certain categories of personal information, such as financial records, health or biometric information, sexual orientation, etc. are considered to be Sensitive Personal Information. Data Subject may choose to share his or her Sensitive Personal Information with ADDTITANS directly in certain circumstances.
    ADDTITANS collects and processes Sensitive Personal Information only when it is essential to offer its services to the Data Subject.
    By providing his or her Sensitive Personal Information, the Data Subject agrees that we may collect, use and share this information with third parties for the purpose of processing the Data Subject’s service request[s].
    It is hereby clarified that Sensitive Personal Information shall constitute Sensitive Personal Data or Information under the Indian Information Technology Act, 2000.



7. HOW WE COLLECT DATA & ITS SUBJECT INFORMATION


How We collect information about Data Subjects in these ways followed;

  • Whenever we are notified about a Data Subject using our services [whether these services are provided directly by ADDTITANS or by other companies in contrast or acting on our behalf – such as an ad agency].

  • When we receive Data Subject Information from third parties;

  • when Data Subject makes a visit to our website;

  • when Data Subject interacts with our staff;

  • when Data Subject interacts with ADDTITANS via email or any sort of social media platforms;

  • When Data Subject provides their information through an online form we at ADDTITANS own.

8. WHY DO WE COLLECT DATA SUBJECT INFORMATION

We use Data Subject Information in order to conduct our business and to provide the data subject and our other leading partners with the best possible services and user experience. We will only use Data Subject Information based on the Privacy Policy we stand to, our contract with the Data Subject, and when the law allows ADDTITANS to do so.

Additionally, we may also disclose Information about the Data Subject:

ADDTITANS will collect relevant, necessary, and adequate, Data Subject Information which will further process such information by a fair and lawful means for the purpose it’s collected for. Most commonly, ADDTITANS will use Data Subject Information in these circumstances:

  • Where we need to perform the contract we have entered into with the Data Subject;

  • Where we need to comply with a legal obligation;

  • Where it is necessary for our legitimate interests [or those of a third party] and the Data Subject’s interests to be mentioned that these fundamental rights do not override those interests;

  • To enable the Data Subjects for use with/against our services;

  • To send the Data Subject with non-marketing commercial communications;

  • To send the Data Subject email notifications that have specifically been requested by the Data Subject itself;

  • To provide services to third parties where Data Subject has provided their consent to provide/collect their information;

  • To send Data Subject marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to the Data Subject, where Data Subject has specifically agreed to this, and we do this by email or similar technology. However, the Data Subject can inform ADDTITANS to stop such marketing communications at any time they are required to do so.

  • To provide third parties with statistical information about the users utilizing our services, but those third parties will not be able anymore to identify any such individual user from the same information;

  • To deal with inquiries or complaints made by or about the Data Subject related to the services we’ve provided to them;

  • To improve and customize our services according to the Data Subject’s preferences they opt for;

  • To keep our website and other systems/services secure and to prevent any fraud-related issues;

  • Where the Data Subject has given ADDTITANS explicit consent to do so.

In addition to this, we may also disclose Data Subject Information, in the following likely to be rare situations:

  • Where we do need to protect the interests of the Data Subject/ or the interests of someone else

  • Where it is needed in the public interest or for official purposes or to fulfill a legal obligation. For instance, requests made by law enforcement agencies, courts, states, or tribunals.


9. FAILURE TO PROVIDE THE INFORMATION


If there’s a failure in providing certain necessary information when the subject is requested to do so, then in that case we would not be able to provide the contract we’d entered into the Data Subject or to prevent the compliance of legal obligations we play as mentioned.

It is to be mentioned if the Data Subject fails to provide such sort of information to us, we shall not be obliged or liable in any manner for not providing our services to the user. The Data Subject is hereby accepting and agrees to this policy of information deficiency on its own.

The Data Subject agrees that he/she shall not initiate, or file any complaints, legal proceedings, or claims against ADDTITANS or our employees, directors, associates, clients, etc. in this regard. The Data Subject further agrees to indemnify and hold ADDTITANS and our employees, directors, associates, etc. harmless from any complaints, legal proceedings, or claims filed or initiated by any third party against ADDTITANS, on this ground.


10. CHANGE OF PURPOSES

We will only use Data Subject Information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use Data Subject Information for an unrelated purpose, we will notify the Data Subject and we will explain the legal basis which allows ADDTITANS to do so.

Please note that we may process Data Subject Information without Data Subject’s knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11. CONSENT OF THE USER

Data Subject agrees while signing in to our website that we do not need any additional or further consent from him/her to use Data Subject Information in order to carry out any legal obligations or exercise specific rights in accordance with this Policy.

12. SHARING OF INFORMATION AND DISCLOSURE

We may disclose Data Subject Information to any of our employees, officers, insurers, clients, co-ordinators, professional advisers, administrative or governmental agents, suppliers, or subcontractors insofar as a reasonably necessary move for the purposes set out in this Privacy Policy and for the purpose of providing services to the Data Subject.

In addition to this, we may also disclose Data Subject’s Information:

  • To the extent when we are required to do so by a call of law;

  • In connection with any ongoing or prospective legal proceedings;

  • In order to establish, exercise, or defend our legal rights which includes providing information to others for the purposes of fraud prevention and reducing credibility risks;

  • To the purchaser or prospective purchaser of any business or assets that are contemplating the company’s rights by selling it; and

  • To any such person who we reasonably believe may apply to a court or other competent authority regarding the disclosure of that information where, in our reasonable opinion, such a court or authority would be likely to order the disclosure of that information.

Except as provided in this Policy, we will not provide Data Subject Information to any other third party/parties.

13. DATA SECURITY

We are firmly committed to protecting the information of Data Subject and thus bound to implement appropriate technical and organizational security measures to protect it against any unauthorized or unlawful processing and against any accidental loss, destruction, security/privacy breach, or any kind of damage.

Appropriate physical, electronic, and managerial procedures have been put into place to safeguard and help to prevent unauthorized access, maintain data security, and correctly use the information collected from the Data Subject.

Data Subject Information is solely processed by ADDTITANS in strict notation with the Indian Information Technology Act, 2000, and the rules notified following therein. We implement and maintain ‘Reasonable Security Practices and Procedures as stated in the Indian Information Technology Act, 2000, and the Information Technology [Reasonable Security Practices and Procedures and Sensitive Personal Data or Information] Rules, 2011, while we process, collect, or handle any sort of Sensitive Personal Information collected from the Data Subject.

Please note that in the specifically mentioned case of European Union [EU] residents, all the contemporary information including their Sensitive Personal Information is bound to be secured and protected by us in accordance with GDPR.

15. DATA RETENTION

We will only retain the Data Subject Information for as long as it’s necessary to fulfill the purpose of why we have collected it for, including for the purposes of satisfying any legal, accounting, contrasting, or reporting requirements.

In some circumstances, we may anonymize Data Subject Information so that it can no longer be associated with the Data Subject, in which case we may use such information without a further statement or without prior notice to the Data Subject.

16. WHO HAS THE RIGHT TO HANDLE AND RETAIN DATA SUBJECT INFORMATION

Details about the primary entity which handles and retains all the Data Subject information are provided below for reference:

Addtitans Digital Private Limited

Unit No. 204

US Complex 120,

Mathura Road, New Jasola

New Delhi- 110076

India

DATA CONTROLLER

For the purposes of GDPR, we [Addtitans Digital Private Limited] are a digital marketing agency in as much as third parties are providing us with the information of Data Subject for us to process its purposes.

17. INFORMATION ABOUT CHILDREN

Generally, we do not intend to collect any Sensitive Personal Information or Personal Information about children who are aging or under the age of 13. If we find any breaches or glitches about having us inadvertently collect such information about children under the age of 13 years, we will take reasonable and notable steps to delete any such information as soon as possible, except where we are required to keep it by the applicable laws.


Specifically for EU Residents, it is in the response of the Data Controllers who have provided us with the mentioned Data Subject Information for obtaining parental/guardian consent prior to collecting or using Sensitive Personal Information or the Personal Information of an individual who is below/under the age of 16 years.

18. DELETION OF INFORMATION

Data Subject may at any time ask ADDTITANS to delete Data Subject Information. We will consider and comply where it’s necessary with Data Subject’s request in accordance with applicable laws, which are as explained above. Please note that after deleting the information, we may not be able to provide our services to the Data Subject or an individual user.

We may, however, need to retain certain Data Subject Information for keeping respective records to purpose and/or to complete any transactions that the Data Subject began prior to requesting against deletion of the information. For instance, when a Data Subject participates in a promotion, he/she may not be able to change or delete the Personal Information provided to ADDTITANS until after the completion of such promotions.

There may also be residual information that will remain within our databases and other records, which will not be removed. To add to this, there may also be certain Data Subject Information that we may be unable to delete due to legitimate and legal reasons.

The Data Subject hereby accepts and agrees that we shall not be held liable/obligated in any manner whatsoever if we are unable to perform our services or if there is a deficiency in our services to the user due to Data Subject’s consent withdrawal. 

With these of the given Privacy Policy, the Data Subject agrees that he/she shall not file or initiate any complaints, legal proceedings, or claims against ADDTITANS and our employees, directors, sponsors, coordinators, associates, etc. in this regard. Data Subject further agrees to indemnify and hold ADDTITANS and our employees, directors, associates, etc. harmless from any such complaints, legal proceedings, or claims filed or initiated by any third party against ADDTITANS in this regard.

19. WITHDRAWAL OF USER’S CONSENT

Data Subject may revoke or withdraw Data Subject’s consent at any time, in order to provide Data Subject Information to ADDTITANS by utilizing the applicable contact details [mentioned at the end of this Policy]. However, such actions may render it impossible for ADDTITANS to offer its services to the Data Subject any further.

Data Subject hereby accepts and agrees that we shall not be held liable in any manner whatsoever if we are unable to perform our services or if there is a deficiency in our services to Data Subject due to Data Subject’s withdrawal of consent.

21. THE REVIEW OF INFORMATION

Data Subject can contact ADDTITANS at any time requesting access to Data Subject Information for reviewing or requesting an amendment or to make/term any changes to certain information that Data Subject considers to be incorrect or wrong. ADDTITANS shall process such requests from Data Subjects in accordance with being replicated with applicable laws.

22. CHANGES TO THIS PRIVACY POLICY

  • The Policy is subject to making a modification from time to time, or at the time when needed. If we decide to change our Policy, we will post/notify those changes here/on this page, so that the Data Subject will always know what information we collect, how we might tend to use that information, and whether we comply to disclose it to anyone.

  • We may also notify Data Subject in other ways to be mentioned from time to time about the processing of Data Subject’s Information.

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