Introduction

‍We, at Fyno, aim to adhere to the ethical standards pertaining to collection, usage and safeguarding of the information provided by you during the use of the Website.

Intelligent Acumen Technologies Private Limited, a company incorporated under the laws of India, having our registered office at 2nd Floor, Garuda BHIVE, BTM Layout, Bangalore - 560068, Karnataka, India (hereinafter referred as “Company”, “Fyno”, “We”, “Us” or “Our”).

We respect Your privacy while you access https://www.fyno.io/ (“Website”) and other associated applications, devices, products, online marketplace and services managed by us that reference to this Privacy Policy (collectively referred to as the “Platform”). For the purposes of this privacy policy the term “User(s)” and wherever the context so requires “You”, “Your”, “Yourself” shall mean any natural or legal person who accesses or uses the Platform and in the event that a natural person is representing a business entity, reference to such terms shall include a reference to such business entity as well.

We, at our Company, aim to adhere to the ethical standards pertaining to collection, usage and safeguarding of the information provided by you during the use of the Website.

We have adopted this privacy policy (“Privacy Policy”) to inform You of: (i) the information We collect from You through the Platform; (ii) the manner of collection and processing of such information; (iii) use of such information; and (iv) the steps We take to protect it. Capitalized terms not defined herein shall have the meaning ascribed to them in the Terms and Conditions specified at https://www.fyno.io/terms-of-service. By using the Platform, You unconditionally agree to the terms and conditions of this Privacy Policy and consent to collecting, usage, storage, processing, handling, transferring and sharing of the information submitted by You in accordance with the terms contained hereunder. Please read the Privacy Policy before using the Platform and if You do not agree with the terms and conditions of this Privacy Policy, please do not proceed further to use this Platform. Please note that the capitalized terms not defined under this Privacy Policy shall have the same meaning as assigned to such terms in the Terms of Service.

User information

1. User Provided Information and Access
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   I. We collect Your Information when You successfully submit information while creating Your account and/or while availing our Services on our Platform. While doing so, We may collect data that can be used to uniquely identify or contact a person and/or the business entity that a person represents and shall include, but not be limited to, information regarding Your name, name of the business entity that You represent, address and telephone number of the business entity, Your e-mail address, and such other information for the purposes of identification and verification. We may request you to authenticate your identity through a One-Time Password ("OTP”) or an email containing a verification link. While you are using our Platform, We record your responses and activity data, including but not limited to, textual and voice responses and session details. We do not directly process any payments and do not store your debit/credit card information. Secured socket layer technology is used for processing payment transactions with third party service provider partners. When You submit User Information on the Platform, it shall be deemed that You have granted Us the right to collect, store, process, handle and use such User Information, in accordance with this Privacy Policy (as amended from time to time).II. We may ask for permission to access your data storage. However, the data storage access shall be limited to the access to store the data downloaded or saved during the usage of the Platform or the products directly in the User’s device for ensuring easy storage and access to the User. We shall not utilize this permission to grant access to any other data on the User’s device, except as expressly mentioned in this Privacy Policy.III. The said information collected from the Users could be categorized as “Personal Information”, “Sensitive Personal Information” or other information and would be governed in accordance with the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (the “IT Rules”) and other relevant applicable laws of the jurisdiction shall collectively be referred to as “User Information” in this Policy.IV. We may use the User Information to contact you from time to time, to provide you with the services We offer through the Platform, important information and circulate marketing and promotional material in relation thereto. We may ask you for more information for identification purposes, if required (personal information). The User shall be permitted to access the Platform via any device provided that the log in/access credentials match with the User credentials. V. You may visit the Platform by signing in, for the purpose of browsing the Platform. We will, at all times, provide the option to you to not provide the Personal Information or Sensitive Personal Information, which We seek from you. Where possible, We indicate which fields are mandatory and which fields are optional to be filled on the Platform. You always have the option to not provide information by choosing not to submit particular information or feature on the Platform. In such event, however, the Company fully reserves the right not to allow further usage of the Platform or provide any services/products thereunder to you. VI. By using this Platform, You consent to the collection, storage, use and transfer of the User Information that you provide in connection with any of the services that We offer through our Platform, and You consent to our collection of any changes or updates that you may provide to the User Information. We collect only such User Information that We believe to be relevant for the purpose of identification and verification and is required to understand You or Your interests. It is clarified that We shall not be liable, for any reason whatsoever, for the authenticity of any User Information provided by You to Us. You hereby confirm that the User Information provided by You is and shall continue to be valid, true and accurate to the best of Your knowledge.VII. We may also collect information regarding your location. This information will not be sold to, or shared with, any unaffiliated third party.VIII. Any portion of the Information containing personal data relating to minors or a person of unsound mind provided by you shall be deemed to be given with the consent of the legal guardian. Such consent is deemed to be provided by your registration with us.IX. We shall retain and employ the information collected in accordance with our Privacy Policy and Terms of Service for the duration of your utilization of the Platform.
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2. Information we collect
   
   I. Your name, phone number and email address;
   II. Account, purchase and payment information;
   III. Candidate information (for job applicants);
   IV. Access to securely stored third party credentials (for triggering notifications);
   V. Location data (including IP Address);
   VI. Device data; and 
   VII. Other data collected that could directly or indirectly identify you.
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3. Automatically collected information
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   ‍When you visit the Platform, We may collect certain non-personal information such as your internet protocol address, operating system, browser type, and internet service provider. This type of information does not identify you personally during Your visit to the Platform. We can identify You only after You submit User Information at the time of registering Yourself with the Platform.

Collection of information

1. The User Information is being collected by the Company and the Company will delete any User Information upon the User withdrawing the consent in writing, however, upon the withdrawal of the consent by the User, the Company may, at its option, not provide any services for which the User Information was sought and the User shall not claim deficiency of services on the basis of such non provision of goods and services. 
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2. To enhance Your use of the Platform, certain information may be collected each time You visit the Platform which are saved in server logs. It is clarified that these statistics help Us in improving the efficiency of the Platform by giving Us information relating to Your use of the Platform. Such information may include details of the server from where the Platform is being accessed, the browser and operating system used to browse the Platform, details of Your last visit to the Platform, including time, date and the duration of Your session on the Platform. This information is used by us to understand the number of users visiting the Platform and gather broad demographic information for aggregate use of the Platform. While collecting such information, Your anonymity shall be maintained at all times and at no time can We identify You personally, unless You submit the Information on the Platform or through the e-mail feature. We reserve the right to share such general information to any person on its discretion.
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3. You acknowledge that apart from Your User Information, if You upload or exchange any data, content, information, pictorial representations and/or images including post any comments on the Platform (collectively referred to as the “Content”), such Content may contain information including User Information and the same may be available to the other Users of the Platform. We will not be liable for the disclosure and dissemination of such User Information on the Platform.

Cookies

Like most other Platforms, We use data collection devices known as cookies to collect and store information of Users visiting the Platform. A cookie is a small amount of data that is sent to a User's browser from a web server and is eventually stored on a User's computer hard drive/mobile device. Cookies are a reliable mechanism for Platforms to remember the activities of the User on the Platform and helps in improving Your experience on the Platform. This anonymous information is maintained distinctly and is not linked to the User Information You submit to us. The option of accepting cookies is up to You, however certain features of the Platform including Content and the forms may not be accessible without accepting cookies

To browse anonymously, You may set your browser to disable cookies or delete cookies. Additionally, You may encounter cookies or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties and shall not be liable for any reason whatsoever for these third party cookies.

User rights

Our Company wants to ensure you are fully aware of your data protection rights. Every user is entitled to the following:

The right to access - You have the right to request Our Company copies of your data. Wemay charge you a small fee for this service.

The right to rectification - You have the right to request that Our Company correct anyinformation you believe is inaccurate. You also have the right to request Our Company tocomplete information you believe needs to be completed.

The right to erasure — You have the right to request that Our Company erase your data,under certain conditions.

The right to restrict processing - You have the right to request that Our Company restrict the processing of your personal data, under certain conditions, provided this information is not crucial for the functioning of Fyno in the process of execution of the services.

The right to object to processing - You have the right to object to Our Company's processing of your data, under certain conditions, provided this information is not crucial for the functioning of Fyno in the process of execution of the services.

The right to data portability - You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please email us at: support@fyno.io

Use of the user information

1. We collect the User Information provided by You for the reasons including but not limited to the following:
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   I. To analyse and draw trends from the aggregated statistics of the User activity;
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   II. To provide personalised recommendations and maintain general and personalised content;
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   III. Identification and authentication of your use of Company Services; 
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   IV. To improve our features and provide seamless service;
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   V. To conduct research, to administer the Services;
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   VI. To undertake promotional activities and/or contest;
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   VII. To send you relevant notifications through e-mails and SMS which add to the effectiveness of the service;
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   VIII. To help in detecting and preventing of fraud; 
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   IX. To analyse and monitor activity on Our Platform;
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   X. To protect the integrity of Our Platform;
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   XI. To respond to any queries/doubts raised by You;
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   XII. To protect against imminent harm to the rights, property or safety of the Platform / Company or its users or the public as required or permitted by law;
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   XIII. To send periodic emails for sharing information and updates pertaining to your order, occasional company news, updates, related product or service information, etc.; and
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   XIV. Verifying Your identity.

Disclosure of user information

1. The User Information may be disclosed to affiliated companies within our corporate family, with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third party service providers as necessary for them to perform services such as:
   
   • Processing credit card payments
   • Performing analysis of our Services and customers' demographics
   • Communicating with you, such as by way of email or survey delivery
   • Customer relationship management
   • Security, risk management and compliance
   • Recruiting support and related services
   • Information storage and access
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   In view of the same, You may be subject to the practices of such third parties as well.
    
2. Except as provided under this Privacy Policy, We shall disclose the User Information only under the circumstances where the User has provided express instructions or consent towards such disclosure.

Third party services and user information collection

1. We use a third party payment platform and payment aggregator services to bill you for Our services. We may use and share the User Information with reliable and reputed third-party payment gateway to whom We are associated in order to ensure swift and comfortable payment mechanism for the User. The third party service providers shall provide the Company the phone number, email ID and the address of the User as utilized by the User while completing the payment transaction. 
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2. After the User is directed to the payment mechanism and the payment gateway, the Company is not liable for any data stored, used or accessed by such a third party service provider and the User Information is no longer governed by this Policy or our Website’s Terms of Service. The same shall be subject to the terms and conditions and privacy policy of the third party service provider. For these third party service providers, we recommend that you read their privacy policies in order to understand the manner in which your personal information and your credit/debit card details will be handled by these providers. 

Sharing of data with third parties

1. We will share your User information with third parties only in the ways that are described in this Policy. We may use the individual data and behaviour patterns combined with personal Information to provide you with personalized content, and better your learning objectives. 
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2. The Company may provide and utilize the User Information and data collected to certain third parties for undertaking data analysis via third party analytical tools. The third party analytical tools are utilized in order to analyze the data and information to personalize, drive insights and thereby provide a better performance, improve the quality of features and provide seamless services to the User.
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3. The Company does not sell, trade or rent your Information to any third party unless, we have been expressly authorized by You either in writing or electronically to do so

Security precautions

1. To prevent any form of unlawful interception or misuse of User Information, We use reasonable physical, electronic, and managerial procedures to safeguard and secure the User Information collected. We use reasonably secure and technologically appropriate measures, in compliance with the relevant applicable laws of the jurisdiction to protect You against loss or misuse of Your User Information including internal reviews of data collection, storage and processing practices and other reasonable security measures which are equivalent to security measures that We use to protect Our own confidential information. We have in place a secure server for all Your transactions on the Platform, which, if required to be accessed, are accessible only by Our authorized personnel. However, as You are aware, no internet site is completely free of security risks and We do not make any representation in respect of the same.
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2. We do not warrant that Our Platform or any electronic communication made by Us is free from virus or other harmful effects. In the event of any errors in transmission or in the event of Our Platform being inaccessible due to an act of any third party or due to any outage, or any technical or technological failure, or similar reasons beyond our control, We shall not be held liable or responsible for any losses/ damages incurred by You, and You agree that you will not have any claims against us regarding the same. You explicitly agree that Your use of the Platform and/or services is at Your own individual risk. You agree and confirm that Your User Information may be collected, used, transferred, processed and stored in the manner stipulated in this Privacy Policy. You hereby confirm that You have been made aware of the security measures undertaken by Us and You expressly consent to Us collecting, storing, handling, processing and using Your User Information.
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3. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our third party providers database only to be accessible by those authorized with special access rights to such systems and are required to keep the information confidential. While we have mechanisms in place to safeguard your personal information after we receive it, no transmission of data over the internet can be fully secure and We make no representation in respect of the same.

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Link to third party sites

The Platform may provide third party information and links to other platforms that are not affiliates of or operated or controlled by Us including but not limited to payment gateways or social networking platforms. We are not responsible for any form of transmission, whatsoever, received by You from any third party platform and accordingly do not make any representations concerning the privacy practices or other policies of such third party Platforms. Under no circumstances shall We be deemed to control or guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, cookies, messages or other materials available on such platforms. Any User Information provided by You to such third party Platforms shall be governed in accordance with the privacy policies of such platforms and it is recommended that You review the privacy policy of such platforms prior to using such platforms.

Aggregate statistics

We may at times provide aggregate statistics about our Users and their pattern in addition to certain related site information to certain third parties will be in an aggregate form and does not contain any of your individual detailed personal Information. 

Data security and retention

We follow the required security measures and adopt the required processes to protect and safeguard the personal information and data provided to us.

Once you delete your Information through your account settings such as name and e-mail address on the Website, this deleted information is not stored in any form at our end. The Licensee’s or their clients’ personally identifiable information ("PII ”) shall not be retained, although User data related to the application’s functionality will be retained solely for the purpose of linking it to the original source. Our data retention policy specifies that the data stored in the form of logs on our application, will be maintained for a period of 6 months from its generation and subsequently destroyed. You have every right to cease to hold an account with us. However, the past activity data associated with your account is intact in anonymous form with us and we may utilise it for research and analysis purposes in order to improve the quality of our Services.

Data breach

In case of any data breach of personal data or Information/Website’s database / third- party data, processors is apparent, we will inform all relevant authorities within 72 hours about the same. Further, we shall inform you about the same without any undue delay, if required.

Policy for children

We do not collect personal information of children under 16 years of age. If knowingly or unknowingly, some child under the age of 16 has given us personal data or Information, we will get in touch with parent for consent or delete the said personal data or Information. In the event you want to inform us about such an event, please email us at team@fyno.io.

International data transfer

We share personal data and information with the entities situated outside the European Union. We ensure that your personal information is protected and the data recipient adopts an adequate level of data protection. Further, we ensure that effective legal remedies are available.

Children’s privacy protection

The Service is not for or directed Towards Children. While the Service is not intended for anyone under the age of eighteen (18) years, we do not intend to and will not knowingly collect any personal information from children under the age of eighteen (18) years. Children under the age of eighteen (18) years are prohibited from using the Service. If we learn that we have collected information from a child under the age of eighteen (18) years, we will remove that information immediately and delete it from our servers (subject to applicable law and this Privacy Policy). If you believe content from a child under the age of eighteen (18) years has been posted to the Service, please notify us by contacting us at support@fyno.io.

Change in privacy policy

You acknowledge that becoming a user of the Fyno Services signifies your assent to this PP. In the event there are any changes to this PP or in the way we treat any Customer Data, we shall intimate you of the same via email at least 1 week prior to the enforcement of such change. We will also display a notice on the Platform regarding the above. If after your receipt of a notice of change to the ToS or PP you do not object to the same and/or continue to use the Fyno Services, you will be assumed to have provided your consent to the changes.

Disclosure required by law

We reserve the right to disclose User Information when required by any applicable law. We will disclose such User Information wherein We have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, or other legal process served on Us from any jurisdiction as may have been applicable to Us by virtue of the location of the User of the services or to exercise Our legal rights or defend against legal claims.

Contacting the platform

If You have any questions or grievances regarding (i) this Privacy Policy; (ii) practices of this Platform, or (iii) Your dealings with this Platform or believe that We have not adhered to it, You can contact the officer of the Company at coordinates mentioned below:

Name: Ashwin Agarwal 
Email: team@fyno.io 
Tel: +91 91482 00147 (India)
Alternatively, you can reach us on the helpdesk via support@fyno.io.

The Grievance Officer is identified above pursuant to the provisions of applicable laws including but not limited to the Information Technology Act, 2000 and the Consumer Protection Act, 2019, and the Rules enacted under those laws.

Updation/ deletion of the user information

Once you update/delete your personal User Information through your account settings such as name and e-mail address on the Website, such old/deleted information will not be stored in any form at our end. You have every right to cease to hold an account with us. However, the past activity data associated with your account is intact in anonymous form with us and we may utilise it for research and analysis purposes in order to improve the quality of our Services.

This Privacy Policy shall be read in conjunction with the Platform’s Terms of Service and all the relevant provisions of the Platform’s Terms of Service (including but not limited to indemnification, limitation of liability, governing law and dispute resolution) shall mutatis mutandis apply to this Privacy Policy and be deemed to be incorporated herein by reference.