Objective and Scope smartcirclegroup (“we”, “us”, “our”, “Smart Circle India”, “Hardik Modi”) values the trust placed in us by data subject (“you”, “your”, “user”, “subscriber”) and therefore, we follow the highest standards of privacy guidelines to protect the information shared by you with us.
Collection and Use of Personal Information - Personal information (PI) - means any information relating to an identified or identifiable living person (‘data subject’ here in referred as you/your’). In particular using a common identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person or any other piece of information as per applicable laws and regulations.
The Company respects the privacy of the users of the Services and is committed to reasonably protect it in all respects. The information about the user as collected by the Company is:
Information you provide to us Information Collected at the Time of Registration /subscription for our Mobile Application smartcirclegroup
When you register/enrol for our Mobile Application smartcirclegroup subscription using your web accounts like Facebook or Google+ we retrieve the following Information from your account(s) to continue to interact with you and to continue providing you the Services. Information that we collect include –
Information Collected when you enrol for website subscription on our platform
When you enrol for any e-newspaper subscription we may collect the following information from you:
Information Collected when you use our Mobile Application
When you download our mobile application we collect the below information, but not limited to
To add certain content, like pictures, you may allow us to access your camera or photo album Information you provide to us voluntarily
We may collect additional information at other times, when you provide feedback(s), modify your content or email preferences, respond to surveys, participate in contests, or communicate with us by posting a comment on our website/ mobile application or asking us a question through or e-mail. This information may include personal information such as, but not limited to, your name, e-mail id, mobile number, comment, postal address etc.
Information Automatically Collected/Tracked while Navigation Cookies
To improve the responsiveness of the "Services" for our users, we may use "cookies", ( a small text file that may be used, for example, to collect your information about Website/ mobile application activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user) or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification ("User ID") to understand the user's individual interests using the identified computer. Our advertisers may also assign their own cookies to your browser(s) (if you click on their ads), a process that we do not control. We receive and store certain types of information whenever you interact with us via website(s), Application(s) or Services through your computer / laptop / notebook / mobile / tablet /pad / handheld device or any other electronic device capable of connecting to internet.
We automatically collect limited information about your computer's connection to the Internet, mobile number, including, but not limited to, your IP address, browser software ,operating system types; clickstream patterns; and dates and times that our site/ application is accessed, whenever you visit(s) our website(s), application or services. Clear GIFs
We may use "clear GIFs" (Web Beacons) when you use our website to track the online usage patterns in an anonymous manner, without personally identifying the user. We may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by them. We also collect information from you passively using Google Analytics and Google search console for collecting information about your usage of our website.
Inferred Information through usage and log data
We may collect and track certain information about you based upon your behaviour on the smartcirclegroup Services We use this information for conducting internal research on our users' demographics, devices, interests, and behaviour to better understand, protect and serve our users.
We may also collect your Information to track user behaviour and preferences for internal analytics and research. We may also use your information:
i. To evaluate your interest for various genres of content, services, offers;
ii. To perform analytics and conduct customer research, to determine your interest, for identifying content that generate sales and to analyse traffic patterns.
If you choose to post messages on social media accounts, message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the smartcirclegroup Services, we may collect and store such information.
Information obtained from other Sources
We may receive information about you from other online sources. We may add it to our account information system and treat it in accordance with this policy. If you provide information to the platform provider or other partner to whom we provide services, your account information including, but not limited to, your name, email ID, may be passed on to us. We may obtain updated contact information(s) from third parties in order to correct our records and fulfil the Services or to communicate with you or share the information with any third party.
If you link or connect to smartcirclegroup Services with a third party service such as Google or Facebook, they may send us information such as your registered e-mail id and public profile information from the service as stated above.
In case you choose to decline to submit personal information on the Application/Websites, we may not be able to provide certain services on the Application/Websites to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.
Processing of personal information
We will only collect and process personal data about you where we have lawful basis. Lawful basis on which we would process our personal information includes obtaining explicit consent from you for processing your personal information or processing for “legitimate interests” where processing is necessary by us to provide you with services (For e.g. processing your information by our group companies/affiliates).
We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services. When showing you tailored ads, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
Send alerts and newsletter(s) to you. If you no longer wish to receive a specific newsletter, follow the "unsubscribe" instructions located near the bottom of each newsletter. (Provided you subscribe to the same)
Send alerts and newsletter(s) to you. If you no longer wish to receive a specific newsletter, follow the "unsubscribe" instructions located near the bottom of each newsletter. (Provided you subscribe to the same. To unsubscribe, please visit your account settings)
Send notification(s) to you on your handheld devices (To turn off the notifications, please visit your account settings)
Communicate with you concerning our service (for example by email, push notifications), so that we can send you news about smartcirclegroup, details about new features and content available on the smartcirclegroup Services, promotional announcements, marketing purposes and surveys, renewal/expiry of services, other services of smartcirclegroup affiliates and to assist you with operational requests such as password reset requests.
Improve our website/ mobile application and its content to provide better features and services
Conducting market research and surveys with the aim of improving our products and services
Preventing, detecting, investigating and prosecuting crimes (including but not limited to fraud and other financial crimes) in any jurisdiction, identity verification, government sanctions screening and due diligence checks
Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings.
Our automated systems analyse your content to provide you customised search results, recommendations and specific promotions and offers
To help advertisers understand our audience and confirm the value of advertising on our websites or Applications, (however it is usually in the form of aggregated statistics on traffic to various pages within our site)
Allow you to participate in interactive features offered through our Services , including contests, news uploads and surveys
Sharing with our customer support team to resolve your queries/concerns related to your rights or services provided to you.
Third party services
Third parties provide certain services available on smartcirclegroup on our behalf. smartcirclegroup may provide information, including Personal Information that ‘smartcirclegroup collects on the Website/ mobile application to third-party service providers to help us deliver programs, products, information, and services. Service providers are also an important means by which smartcirclegroup maintains its Website/ mobile application and mailing lists. smartcirclegroup will take reasonable steps to ensure that these third-party service providers are obligated to protect Personal Information on smartcirclegroup behalf. smartcirclegroup does not intend to transfer Personal Information without your consent to third parties who are not bound to act on smartcirclegroup behalf unless such transfer is required for legal purposes or for providing relevant services. Similarly, it is against ‘smartcirclegroup’s’ policy to sell Personal Information collected online without consent.
We present information to our advertisers to help them understand our audience and confirm the value of advertising on our website/ mobile application. It is usually in the form of aggregated statistics on traffic to various pages within our website/ mobile application. When you register with smartcirclegroup, we contact you from time to time about updation of your content to provide the users such features that we believe may benefit you.
We use third-party advertising companies to serve ads when you visit our website/ mobile application. These companies may use information (such as but not limited to your name, email, photos/media/files on your device, location, audio etc.) about your visits to this and other websites/ applications in order to provide advertisements about goods and services of interest to you. However, we do not store this data in our environment.
Based on Your purchase of a subscription package, our payment gateway partners including payment may collect information with respect to your credit/debit card details or other bank account details along with your billing address. This information is stored by our payment gateway partners. For instance, the smartcirclegroup will be using third party payment gateway partners to process and facilitate the payment of your subscription fee to the smartcirclegroup for providing you access to the subscription. Please note that the smartcirclegroup do not directly collect any financial information such as credit card or debit card or net banking details from you. Such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. These payment gateways may have their own privacy policies in place, which we recommend you review if you visit any such payment gateways. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to providing them with information about you or entering into any transactions with them.
While transacting with these payment gateways, you may provide your financial information including without limitation your bank account details, credit card account details or your details pertaining to any payment settlement or pre-paid instrument service provider. You understand, agree and acknowledge that the smartcirclegroup never receive your financial and payment information from these payment gateways. Your Personal Information, Sensitive Personal Data or Information and financial information will be dealt by these payment gateways in accordance with their respective privacy policies and other terms and conditions and smartcirclegroup shall not be liable, accountable or responsible for Your Personal Information, Sensitive Personal Data and Financial Information which you provide to these payment gateways.
To use the website/ mobile application you agree that you must be the minimum age (described in this paragraph below) or older.
The minimum age for these purposes shall be 16, however if local laws require that you must be older in order for smartcirclegroup to lawfully provide the services in the website/ mobile application to you then that older age shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use smartcirclegroup under the supervision of your parent, legal guardian or responsible adult.
We restrict access to your Personal Information to employees who we believe reasonably need to know/or that information in order to fulfil their jobs to provide, operate, develop, or improve our products or services smartcirclegroup does not rent, sell, or share personal information about you with other people or non-affiliated companies except to provide products or services you've requested, when we have your permission, or under the following circumstances:
We provide the information to trusted partners who work on behalf of or with ‘smartcirclegroup’ under confidentiality agreements. These companies may use your personal information to help smartcirclegroup communicate with you about offers from smartcirclegroup and our marketing partners. However, these companies do not have any independent right to share this information.
We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
smartcirclegroup works with vendors, partners, advertisers, and other service providers in different industries and categories of business.
Retention of personal information
Your personal information processed by smartcirclegroup are kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal information are processed in line with legal, regulatory, contractual or statutory obligations as applicable.
At the expiry of such periods, your personal information will be deleted or archived to comply with legal/contractual retention obligations or in accordance with applicable statutory limitation periods.
To the extent permitted by law, smartcirclegroup may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.
Your Controls and Choices (As applicable under GDPR)
Accessing and Rectifying your personal information
When you use the Services on our Website/application (or any of its sub sites), we make reasonable efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. We ask individual users to identify themselves and the information requested to be accessed or corrected before processing such requests. We may decline to process requests that are unreasonably repetitive or systematic, requiring disproportionate technical effort, jeopardizing the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. You can make such requests by sending us an e-mail
Right to Rectification
You have the right for inaccurate or incomplete data we hold to be updated. You shall have the right to obtain from smartcirclegroup without undue delay the rectification of inaccurate personal information concerning you.
You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and have the right to transmit to another controller, wherever feasible
We retain your personal information as long as necessary for us to provide services to you or you ask us to not retain your data. If you no longer want us to use your information then you can request that we erase your personal information and close your smartcirclegroup Services account. Please note that if you request for the erasure of your personal information;
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend smartcirclegroup service account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the smartcirclegroup Services, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
Withdrawing Consent and Restriction of Processing
For withdrawing your consent at any time during the tenure of your services with us, you may choose to do so by sending us an e-mail. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you and stop any further processing of your personal information
Right to Object to the Processing
Except in very specific cases where provided by law, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you.
Such right can be exercised at any time where your personal data is processed for direct marketing purposes.
Right to object being subjected to a decision based solely on automated processing, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except in specific cases provided by law. smartcirclegroup shall provide information on action taken on a request pertaining to the rights above without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. smartcirclegroup shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for delay.
If you have any complaints regarding processing of your personal information you may contact our Privacy Officer at firstname.lastname@example.org. You have the right to complaint about the data processing activities carried out by smartcirclegroup before the competent data protection authorities.
Security and Compliance with Laws
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall on the cloud; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. If you know or have reason to believe that your smartcirclegroup Services account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.
Social media smartcirclegroup operates channels, pages and accounts on some social media sites to inform, assist and engage with you. smartcirclegroup monitors and records comments and posts made on these channels about smartcirclegroup in order to improve its products and services.
Please note that you must not communicate with smartcirclegroup through such social media sites the following information:
Sensitive personal data including (i) special categories of personal data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation and (ii) other sensitive personal data such as criminal convictions and offences and national identification number ;
Excessive, inappropriate, offensive or insulting information towards individuals.
smartcirclegroup is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. smartcirclegroup is only responsible for its own use of the personal data received through such sites
Changes in the Policy smartcirclegroup reserves the right to update, change or modify this policy at any time. The policy shall come to effect from the date of such update, change or modification.
Contact Information Support
Disclaimer smartcirclegroup shall not be liable for any loss or damage sustained by reason of any disclosure (inadvertent or otherwise) of any information concerning the user's account and / or information relating to or regarding online transactions using credit cards / debit cards and / or their verification process and particulars nor for any error, omission or inaccuracy with respect to any information so disclosed and used whether or not in pursuance of a legal process or otherwise.
Any other personal information shared by you which is not asked by smartcirclegroup during registration, either mandatorily or optionally; accounts to wilful and intentional furnishing; and smartcirclegroup will not be liable for breach of such information.
We have created a few contents which are to be the part of our basket of services in future or for specific subscribers only. We are not liable to provide these contents to all users as it will be our discretion to allow the usage or a limited usage of such contents or a later usage. We have specified the policy for availability of these contents by placing a note. For example, HSN Rate for Goods, Acts as on date, Rules as on date, Practice and Procedure, Overview and Analysis etc.
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