PRIVACY POLICY

Gokaldas Ventures (“Gokaldas”, “Blackbx” or “we” or “us”), offers this website available at www.blackbx.in (collectively referred to as “Platform”) and any service availed by users (hereinafter referred to as “you”, “your” or “User”) through the Platform, conditioned upon your acceptance of the terms and conditions contained in Gokaldas’ Terms of Use as available on its website [link to the terms of use] and this privacy policy (“Privacy Policy”).

Purpose and Scope

We are strongly committed to respecting your online privacy and recognizes the need for appropriate protection and management of any Personal Information collected and/or collated by us.

The purpose of this Privacy Policy is to ensure that there is an intact charter to collect, use and protect any personal and/or sensitive data collected by us. This Privacy Policy defines our policies and procedure for collection, usage, processing, disclosure and protection of any information obtained by us through the Platform. By using the Platform and availing the services, and voluntarily providing us with information, you are consenting to our use of it in accordance with this Privacy Policy. This Privacy Policy does not apply to third-party links, applications or websites that are connected via links to the Platform or displayed on the Platform.

This Privacy Policy constitutes a legal agreement between you, as a User of the Platform and us, as the owner of the Platform. You must be a natural person who is at least 18 years of age. If you are under the age of 18, it is mandatory that your parent or guardian has read and accepted this Privacy Policy on your behalf, and in such a case this Privacy Policy shall be deemed to be a contract between Blackbx and your legal guardian or parent and to the extent permissible under applicable laws, enforceable against you.

Disclaimer

Please be advised that any Sensitive Information (as defined herein below) procured by us, shall be:

1. processed fairly and lawfully;

2. obtained only for specified and lawful purposes, and not be used in any manner which is against the law or policy in force in India and/ or European Union;

adequate, relevant and not excessive in relation to the purpose for which it is required;

able to be reviewed by the User, from time to time and updated-if need arises; and not kept longer than for the time which it is required or the purpose for which it is required.

Your Consent

Please be advised that by providing the information (as enumerated upon herein below) you provide your consent and authorize us to collect, use or disclose such information for the business and research purposes and as stated in this Privacy Policy, the Terms of Use, and as permitted or required by law.

Moreover, you understand and hereby consent that the information collected by us, may be transferred to any third party for the purpose of services provided through the Platform or to any third party providers for any jointly developed or marketed services, payment processing, order fulfilment, customer services, data analysis, IT services and such other services which enable us to provide you services through the Platform.

By visiting or accessing the Platform and voluntarily providing us with information (including Personal Information), you are consenting to our use of it in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you may refuse or withdraw your consent any time, or alternatively to not provide us with any Personal Information.

Such an intimation to withdraw your consent can be provided in letter, phone or e-mail to the communication details provided below:

Gokaldas Venture
Gokaldas Chambers
222/14, 2nd floor, 5th Main,
Bellary Road,
Sadashivanagar,
Bangalore 560080

Types of Information Collected by Blackbx

    1. Personal information

1.1 Personal information

means and includes any information that relates to a natural person through which an individual is identified, such as the name, contact details, email address, gender, age or any other relevant material provided by a User when they register for an account or use the services made available through the Platform; including but not limited to information gathered through a purchase of a service, survey, e-mail updates. This may also include information regarding the family member, relative, partner, friend or any person related to the User in any way as provided by the User through the Platform. Personal Information may also includes information pertaining to the racial or ethnic origin, health, religion or other beliefs etc. of a User, either as provided by the User through the Platform.

1.2 Sensitive Information

means and includes any information of a person as specified under Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, such as password; financial information such as bank account or credit card or debit card or any other payment information, physical, physiological and mental health information; sexual orientation; medical records and history; biometric information; and any other information provided to Blackbx for rendering service or for processing, storing under a lawful contract or otherwise.

1.3 Technical Information

means and includes any information gathered through various technologies that may employ cookies, web beacons, or similar technologies to automatically record certain information from your device through which you use the Platform. This technical information may include your Internet Protocol (IP) address, device or browser type, advertising ID, Internet service provider (ISP), referring or exit pages, clickstream data, operating system. This data includes usage information and user statistics.

1.4 Integrated Service Information

means and includes any information obtained through access to any other social media platform (Facebook, Google, etc.) integrated with Blackbx (if applicable). Blackbx may collect this information already provided in your integrated service account.

1.5 Information from Blackbx Studio

means and includes any information which is provided in a case where a child is less than 18 years of age and the data provided by their parent and/or guardian.

1.6 Information from your parents/guardian

means and includes any information obtained through access to any other social media platform (Facebook, Google, etc.) integrated with Blackbx (if applicable). Blackbx may collect this information already provided in your integrated service account.

1.6 Locational Information

shall mean and include the information obtained through GPS or other means, such as the geographical location of the user.

    2. Personal information

2.1 Information through use of our service

means and includes information which is procured through the use of our service, including but not limited to the kind of services availed, the feedback of the services provided by you, and the kind of services viewed and availed by you.

2.1 Non-Personal Information

means and includes any information that does not reveal your specific identity, such as, browser information, information collected through Cookies (as defined below), pixel tags and other technologies, demographic information, etc. As is true with most websites, our website gathers some information automatically when you visit the URL of the website and stores it in log files. When you use the website, we may collect certain information about your computer to facilitate, evaluate and verify your use of the website. For example, we may store environmental variables, such as browser type, operating system, speed of the central processing unit (CPU), referring or exit web pages, click patterns and the internet protocol (IP) address of your computer. This information is generally collected in aggregate form, without identifying any user individually.

Purpose of Collection and Usage of Your Information

    1.Support regular Blackbx usage

    1.1 Identity verification

This information is particularly pertinent for identity verification and to authenticate the submissions made on the Platform

    1.2 Internal Record Keeping

We use the information (as enumerated hereinabove), save and except Sensitive Information, to ascertain the types of service more relevant to your interests and to suit your needs. It helps in building a statistical database to analyze the characteristics, behavior and demographics of our Users. This information is used solely to promote our business activitie

    1.3 Communications with Blackbx

We have imbedded a feature on the Platform to provide our Users to have a conversation with Blackbx personnel for providing smooth and efficient services to our Users. However, when you provide us your Personal Information, we may use this information to communicate with you in the future through e-mail, phone or any such information gathered by us through Platform.

    1.4 Ease of use of our service

The information is used to ensure continued service to a User and not to interrupt the services because of any such concern (logistical or otherwise) and depending on the specifics of each user.

    2. Improving your experience

    2.1 Increase output

The information collated through use of our service, save and except Personal Information, Information from your parent/guardian and Sensitive Information, is used to enhance our relationship with you and provide relevant services to User. It is Blackbx’s endeavor to grow interest in a User by providing services which are relevant to a particular User. Moreover, Blackbx uses all this information to analyze the usage trends, learning behaviors and preferences of our Users, to improve the way these services work and look with respect to you, including updating, enhancing the operations and functionality of these features.

    2.2 Business or Research Purposes

The information (as enumerated above), save and except Personal Information and Sensitive Information, is used for business or research purposes, including improving and customizing the Platform for ease of use and the products and services offered by us. We may archive this information to use it for future communications for providing updates and/or surveys.

    2.3 Improve functionality

All information, save and except Personal Information and Sensitive Information, is used to provide a personalized learning and high-quality experience for our Users by increasing site functionality and the services offered by Blackbx.

    2.4 Aggregating Information / Anonymized data

We may aggregate information and analyze it in a manner to further accentuate the level of services that we offer to our users. This information includes average number of users of the Platform, the average clicks of the services offered by us, the features used, the response rate, etc. and other such statistics regarding groups or individuals. In doing so, we shall not be making disclosures of any Sensitive Information as defined above.

Disclosure and Sharing of Information

We do not rent, sell or disclose or share any information that we collect from you, with third parties, save and except in order to provide you services in accordance with this Privacy Policy, and as per the procedure prescribed by law and in compliance with our legal obligations. We may share your information in circumstances and for the purposes as specified hereunder:

    1.When compelled by law

We may disclose any information provided by you on the Platform as may be deemed to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that We may sustain.

    2.Merger or Acquisition

We may share information upon merger or acquisition of Blackbx with any another entity. We shall transmit and transfer the information upon acquisition or merger of Blackbx with another entity.

    3.With our service providers

We may share information with other service providers on a need to know basis, subject to obligations of confidentiality in order for provision of services. We hereby clarify that Blackbx works with vendors, partners, advertisers, and other service providers, including but not limited to those who provide products or services such as contact information verification, payment processing, website hosting, data analysis, infrastructure provision, IT services, auditing services and other similar services, in different industries and categories of business by virtue of lawful contracts instituted between such third parties and Blackbx to improve our product and services. Accordingly, we may share your information with such service provider in order to provide you, our services.

    On your authorization

We may share information with social networking sites: Some of our Users choose to connect their Blackbx account with social networks. In such a case and upon your express authorization, we may share your Personal Information with such networks.

We may share data with third-party applications that you authorize: Third-party application developers and service providers may build complementary services for our Platform, such as a mobile application for visually-impaired learners to access our resources.

Please be advised that the information shall only be shared, without your consent, with government agencies as mandated under the law. You can be assured that no Sensitive Information shall ever be published on the Platform. However, Blackbx shall share such Sensitive Information with its subsidiaries and affiliates, for the purpose of research and to accentuate the services provided by us through Platform.

Transfer of Information

Any information provided by you including Sensitive Information will only be transferred to any other entity or person in India, or located in another country, including but not limited to the subsidiaries and affiliates of Blackbx, that ensures the same level of data protection as is provided in the Privacy Policy. Such a transfer is subject to a lawful contract between Blackbx and the third party or in a case where there is an express authorization for such a transfer to be effectuated.

Your Rights

You retain several rights in relation to your data as provided under applicable law. These may include the rights to:

1. Access, confirm, and review data you may have provided

2. Correct data that may be inaccurate or irrelevant.

3. Deletion and erasure of your data in our possession

4. Receive data we hold about you in a portable format.

5. Object to or restrict any form of processing you may not be comfortable with.

In order to exercise these rights, please contact us on the email address info@blackbx.in.

To update, correct, review, or amend the information that has been previously provided by you, you may make the changes on your account profile page by signing in and saving the said changes/ modifications. Any change/ modification made by you will be reflected on the mobile application. Alternatively, you may write us at the above mentioned email address.

Control the Collection or Use of the Information

If Users have any reservations, constraints or apprehensions regarding the access to, collection, storage, or any other use of the information they have provided to Blackbx, they may withdraw their consent in the manner indicated above.

Retention of Data

All information provided by you, save and except upon withdrawal or termination, shall be retained in locations outside the direct control of Blackbx (for instance, on servers or databases co-locates with hosting providers), as long as your account is active and for use in operational purposes only. We will delete information based on a request received from you within a reasonable period and latest within 90 days of receiving a deletion request. However, we may retain such portion of information to support any contracts between the Users, financial transactions, protecting other users of the Platform and as may be required under applicable law.

Cookies and Other Tracking Technologies

Our Platform may, irrespective of whether or not you are a registered member, utilize “cookies” and other Technical Information. “Cookies” are a small text file constituting of alphanumeric numbers used to collect the information about website activity. The Technical Information helps us analyse web traffic and help you by customizing the Platform to your preferences. A Cookie in no way gives us access to your computer or mobile device. In relation to Cookies, you can deny access to the installation of the Cookies by modifying the settings on your web browser, however this may prevent you from taking full advantage of the Platform. Our use of Cookies and Technical Information allows us to improve our Platform and your experience of our Platform and services. We may also analyze Technical Information that does not contain Personal Information for trends and statistics.

Third Party Services

Blackbx will not sell your information to third parties unless Blackbx has your permission or is required by law to do so. Blackbx may use your information to send you promotional information about third parties which Blackbx think you may find interesting if you tell us that you wish this to happen. In the event you choose to avail any third party services, your use of such services shall be subject to the terms of use and privacy policy of such third parties. We assume no liability for any information disclosed by you to any third parties either through the Platform or otherwise. We shall not be responsible for any disclosure of information due to unauthorized third party access other acts of third parties or acts or omissions beyond our reasonable control and you agree that you will not hold us responsible for any breach of security unless such breach has been caused as s direct result of our negligence or willful default.

Data Security

To protect your privacy and security, Blackbx takes steps to verify your identity before granting you account access or making corrections to your information. You should create and maintain a strong password to help ensure the security of your account.

We use certain physical, managerial, technical or operational safeguards as per industry standards and established best practices to protect the information we collect. We use reasonable security practices and procedures and use secure servers as mandated under applicable laws for protection of your information. We review our information collection, storage and processing practices, including physical security measures to guard against unauthorized access to systems. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the internet. You accept the inherent security implications of data transmission over the internet and the world wide web cannot always be guaranteed as complete secure. Therefore, your use of the Platform will be at Your own risk. If you have any concerns please feel free to contact the Grievance Officer at the details given herein below.

Changes and updates to Policy

Blackbx may modify or revise this Privacy Policy from time to time and shall accordingly notify you of any changes to this Privacy Policy by posting the revised Privacy Policy with an updated date of revision. Blackbx shall endeavor to review, revise, update, modify, amend or correct this Policy on a regular and routine basis, especially whenever a significant update is made to the technology employed by Blackbx for its services. You must periodically review the Privacy Policy for the latest information on our privacy practices. In the event you continue to use the Platform and our services after any update in the Privacy Policy, your use of the Platform shall be subject to such update privacy policy.

Discrepancies and Grievances with Blackbx

In case of any discrepancy or grievance with respect to all or any information shared with Blackbx, please feel free to contact at info@blackbx.in.

We assure you that we shall ensure implementation of this Privacy Policy and shall make the policy available to individuals and redress the grievances of the User expeditiously within one (1) month from the date of receipt of grievance.

If you are in the European Union, you can choose to instead lodge a complaint with your local Data Protection Authority (DPA).

Contacting Blackbx

Please feel free to reach out to us at The Black Box, CRN Chambers Ground Floor No. 13, Kasturba Road Bangalore 560001, in case of any concerns, grievances, or questions relating to our privacy or data related practices.

Miscellaneous

The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. This Privacy Policy does not apply to any information other than the information collected by us through the Platform. This Privacy Policy shall be inapplicable to any unsolicited information you provide us through the Platform or through any other means. All unsolicited information shall be deemed to be non-confidential and we shall be free to use and/ or disclose such unsolicited information without any limitations. The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

Governing Laws and Jurisdiction

This Privacy Policy, our services and the use of it is governed by the laws of India and the courts in Bangalore shall have exclusive jurisdiction over any disputes connected to our Platform or the services.