Privacy Policy

The Privacy Policy applies only to information collected by us or our trusted and authorized partners [i.e. any third party service providers or business partner(s)]. We recommend you (hereinafter referred to as "you", "your", "user", "end-user", "customer" as applicable) to review the respective privacy statements of all the third parties with whom you interact.

The terms (whether capitalized or not) which have been used herein but are not specifically defined shall have the same meaning as attributed to such term in the Terms and Conditions. The Terms and Conditions, and this Privacy Policy are to be interpreted harmoniously at all events.

As we update, improve, change and expand our products and services and in view of changing technology and legal requirements and compliances thereof, this Privacy Policy may change or be modified from time to time, so please refer back to it periodically as you will be deemed to be governed by the terms of such modified Privacy Policy, as it comes into effect from time to time. If we make a significant or material change in the way we use or share your personal information (as defined hereinafter), we shall notify you on any changes by suitable means. Your continued usage of our services, products, and mobile application shall come under the purview of all the future changes this Privacy Policy will be subjected to.

We consider your privacy of utmost importance and appreciate your trust that we do so carefully and sensibly. For the purposes of clarity, we state that the following Privacy Policy of ours in intended to inform you about how we collect, store, transfer, disclose or process the information you share with us in respect to our services, products and mobile application.

The use, access, installation or general exploration of our products and services states that you expressly consent to our and our trusted and authorized partners' collection, storage, use, processing and disclosure of the information (as defined hereunder) in accordance with the terms of this Privacy Policy and the relevant trusted authorized partner, controlled virtual assistant's specific terms and conditions, disclaimer statement(s) and privacy policy(ies), which may be updated/modified from time to time and shall be available for periodic review by users at their respective websites. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

For the purposes of this Privacy Policy, we determine the type, purposes, conditions and means of processing of your Information as per regulations in force. For the purposes of clarity, this Privacy Policy published and provided to you herein is an electronic record, this electronic record is generated by a computer system and does not require your physical or digital signatures.

User Representations and Warranties

By using and accessing our products, services, mobile application and other services/skills, subscribing to user content and associated services, accessing our platforms and/or by providing your information, you represent and warrant as follows:

1. You are of the legal age under the law applicable in the jurisdiction from where you access the abovementioned, subscribing to user content and associated services, accessing our platforms and/or by providing your Information;
2. You have the lawful authority and capacity to contract and be bound by this Privacy Policy;
3. If you are accepting this Privacy Policy on behalf of a company, limited liability partnership or other legal entity, you have the authority to bind such entity to this Privacy Policy and, in such event, "you" and "your" as used in this Privacy Policy shall refer to such entity (if authorized by the Company);
4. You will comply with all laws and regulations applicable in your jurisdiction; and
5. You shall provide accurate, current and complete information as may be prompted (i.e., registration and user account details) and maintain and undertake to update the same in respect of any changes.

Scope of Privacy Policy

This Privacy Policy encompasses the processing of your personal information shared via our products and services, including:

1. Our Hardware product and parts/components/accessories, including Company branded products ("products"),
2. Services, including software services, technical support and services assessible through our products, Mobile application ("application")
3. Software you will download to your smartphone or tablet to access the product services ("mobile application")

Information That We Gather

We collect certain personal, non-personal and other information and correspondences from you, as indicated below, that we consider necessary for you to access certain products and services (hereinafter collectively referred to as "information"):

The personal information we collect from users helps us personalize and regularly improve your experience and help us with basic information about Internet trends, number of users, traffic on mobile application, and related content with us. Personal information means information that is about any individual, or from which any individual is directly or indirectly identifiable.

Personal information shall include all information that can be linked to a specific individual or used to identify any individual, such as:

• Contact data (such as Your e-mail address, and account details and password)
• Demographic data (such as Your gender, Your date of birth)
• Details of consents (records of consents given with the date and time and other relevant information)
• Alerts and related snippets information (as applicable)
• Any and all details that may be necessary from the Customer ("personal information")

We do not collect or otherwise process personal information about race, religion, sexual orientation or health or any other information that may be deemed to be sensitive under the relevant laws and regulations applicable in the relevant jurisdiction in the ordinary course of our business.

When browsing our mobile application, you are not required to provide any personal information unless and until you choose to create an account.

Any content on the mobile application or Alexa's relevant Amazon entity(ies) or Google Assistant's relevant Google entity(ies) or other public platform, as the case may be, shared by you via reviews, comments, blogs, discussion boards, forums, user testimonials, scribbles, etc., becomes published content and are not considered as personal information and is not protected by the Company.

Personal Information Collected Directly From You

Log In/Registration

Initiating an account with us will require the user to provide certain key personal information which will be required for installation and registration with Company mobile application which is only collected by us when you voluntarily submit it to us and provide consent thereof. For example, if you voluntarily and consensually request a product demo on the mobile application, we consider the information we collect to confirm and process your request, update and respond to any questions you may have.

Videos

Our products may capture, process and store videos that are made by you for various time periods, device configuration and settings adopted by you. For the sake of clarity, videos being captured by the User's Product cannot be stored or accessed by the Company or any third party as these are stored directly in the User's Product device, which the User has complete access. The transit and storage of the collected data is encrypted and only accessible to the user via his/her main registered account or via his/her other accounts as linked on our platform, with your express consent.

Customer Service

We may collect information through our customer support team or communications team that you have shared voluntarily such as subscription details, product serial code, usage details, voice-call recordings, any complaints or issues raised, etc.

Correspondences

When you send emails or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our platform, products and other services.

Personal Information Collected When You Use, Access and Adopt Our Products and Services

Analytics Information/Data

Certain information is collected and processed with users' usage of mobile application, such as log files, preferences, interests or other non-identifying statistics. When you connect your smartphone or tablet to our mobile application we might collect and analyse details including but not limited to IP address, login, name, and email address. Company uses this information for security analysis of Product Usage.

How is the Information Used?

The sole purpose of the use of your personal information shared by you is to provide you with a better product experience, continually improve the services offered by us and our application and smoothen your experience as a user. We may use your personal information shared to us for following purposes:

1. We may use the information to communicate with you to personalize and improve product and service experience and process and fulfil Your request (if any),
2. To improve our products/devices, provide requisite upgrades and customizations and other associated services,
3. For analytics purpose to understand how our products and services are being used,
4. To ensure smooth functioning of our products and services and customer support to take continuous feedback in order to improve our existing services or provide our users with any specific customized service offered by our product,
5. To send marketing communications, product updates or special offers,
6. For safekeeping, safety, security and integrity of the Company, any platforms, applications and customers,
7. As and when required by laws and regulations or any government undertaking or judiciary process extending claim or jurisdiction over the Company or our associates,
8. To maintain your account with us and provide you with a customized service based on your preferences,
9. To enforce this Privacy Policy,
10. To publish any testimonials or reviews that You may have provided on our application and other online platform,
11. Any other specific purpose in which case your consent will be asked prior to using your personal information, and
12. For any other purpose to give effect to the abovementioned.

Information Sharing and Transfer

Further, we may share, release or transfer information about you, in respect of the following:

1. For legitimate business purposes (including but not limited to operating and upgrading our devices, products and services, our online platforms, conducting our business, or providing any service to you), in accordance with applicable law, with other entities within the Company group and/or trusted third parties,
2. When we believe such release is appropriate to comply with the applicable laws, enforce our online platform policies, this Privacy Policy, our devices/products/services security, information of other end-users, or protect ours or others' rights, property, or safety,
3. Experts and professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of strict confidentiality and non-disclosure,
4. We are acquired or go for a merger with another entity. In any such scenarios, Company will notify you before the information is shared or transferred,
5. We believe it is necessary to share the personal information in order to control, investigate or take appropriate action regarding any illegal activity, fraud or any situation involving or causing any potential threat to the safety of any person(s), entity(ies) or group(s),
6. Wherein the access, use, preservation or disclosure of such information is reasonably necessary, in good faith, to satisfy any applicable law, regulation, legal process or enforceable governmental request or court order,
7. To the extent necessary for the establishment, exercise or defence of legal rights and remedies, we shall disclose information to any relevant party, law enforcement agency or competent court of applicable jurisdiction(s),
8. Our business partners or marketing, promotional, advertising processes and additionally analyse and suggest if any other related product(s)/service(s) that shall be suitable for your optimum user experience,
9. You are choosing to invite or link in your circle in respect of our products and services, with your family or friends, and/or
10. In any other situation in which case we will seek prior consent before sharing, releasing or transferring your information to any third party.

Lawful Basis for Processing Information

As outlined in this Privacy Policy, we will not process your personal information without a lawful basis to do so and except for the purposes of legitimate business interest. We may process your personal information on the legal bases of:

1. Consent (where We have obtained your prior, free, unambiguous, clear, indistinguishable, express consent to the processing;
2. Contract (if you have entered into an agreement with us and such processing is a necessary part thereof for the purposes of legitimate business interest);
3. Compliance with applicable laws; and/or
4. To protect the vital interests of any individual.

Further, we may also process certain personal information on the basis of the following legitimate business interests, provided that such interests are not overridden by your data protection and privacy rights and interests:

1. Delivering the services or other associated/linked service requested by you;
2. Analyse and suggest if any other related product/service shall be suitable for you to improve, personalize and customize your user experience;
3. Developing and continuing to develop, upgrade and improve our products and services, our mobile application, learning from your user/media consumption behaviour to better serve you and other users;
4. Helping us modify, upgrade, customize and/or enhance our products and services, our mobile application, software, and its content(s)/service(s), receiving insight as to what users like or dislike, prefer, their habits and patterns in respect of viewing or aspects thereof; and
5. Providing a consistent and secure user experience in connection with our products and services, our mobile application.

Retention of Information

We retain personal information and other information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with the relevant laws and regulations of relevant jurisdiction. The criteria for determining the duration for which we will keep your personal information and other pertinent information are as follows:

1. We will retain copies of your personal information and other pertinent information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Privacy Policy, the Terms and Conditions, any disclaimers and other statements, including for the duration of time we have an ongoing contractual and binding relationship with you and provide services to you;
2. If there is a legal obligation to which we are subject (for example, certain applicable laws require us to keep records for a certain period of time before we can delete them); or
3. Keeping in view our legitimate business interest, including any litigation or regulatory investigations.

Notwithstanding the above, we may choose to delete the personal information shared by the user(s) in case the information is no longer required to carry out our legitimate business interests and the purposes for which we were processing the information for, a request to discontinue a service or deactivation of the account is received unless we are required by applicable the relevant laws and regulations of relevant jurisdiction or any other binding action to retain the information for further processing.

Accessing, Updating and Deleting Your Information

As a user of our products and services range, you may at any time access, correct, delete, and change or transfer your personal information that we hold, including registration and account details. You can update or modify the personal information i.e. your device name, nick name and profile photo by logging in and accessing your account.

If required by you, we will delete the personal information provided by you in connection with use and access of our products and services and all associated/linked services/content, including applications, software, etc, provided to you. We may retain information about you for the purposes authorized under this Privacy Policy, the Terms and Conditions and/or other disclaimers or statements thereof, unless prohibited by the relevant laws and regulations of relevant jurisdiction.

Though you may delete your account, you acknowledge that we may retain certain residual information in connection with your account including but not limited to subscriber related information, payment details and complaints related data (if any). We shall retain your information for our record even after the deletion of your account associated with us and/or any authorized third party partner(s) only in consonance with this Privacy Policy, the Terms and Conditions and/or other disclaimers or statements thereof, including for the purpose of compliance with legal obligations, resolving of disputes and enforcing of agreements.

How Information is Protected?

We are very particular and diligent about the user experience of our end users and ensure proper safeguards to protect the personal information they entrusted to us. We use reasonable security measures to protect information from unauthorized access, maintain data accuracy, and help ensure the appropriate use/disclosure of information. These safeguards take into account the sensitivity of the information that we collect, process and store and the current state of technology.

We take proper, adequate, efficient and best industry standards related technical, physical, administrative and managerial measures to protect your personal information against accidental loss or unlawful acquiring, unauthorised adulteration, or unauthorised access and misuse or any other unlawful way of information processing of the shared information trusted to us by the users.

The foregoing is subject to your compliance with the following:

1. You are responsible for maintaining the security and confidentiality of your user id and password while using and accessing our products, services and applications. You acknowledge that neither we nor any of our directors, shareholders or other representatives shall be liable to you under any circumstances for any direct, indirect, punitive, incidental, special or consequential damages that result from or arise out of, or a breach or, or compromise of registration of your user account with us and/or your ability or inability to use the user account; or
2. Further, you agree and undertake that any information you share on your public profile on our mobile application or with your friends and family via mobile apps will be your responsibility and consequently you shall be imposed with related obligations and liability thereof. We are also not responsible for any personal information you share in associated groups, forums or discussions which are public in nature whether such information has been shared on our mobile application or any of our authorized third party platform(s) and tool(s).

Can Children Access the Products and Services?

International Transfer of Data

To facilitate the provision of our products and services to you, we may store and send your personal information outside the country, where you reside or are a national of, including countries which may have privacy protection laws that are less stringent than the ones at the country you reside in. We are committed to protect your personal information during such transfers. However, by using and accessing your authorized and purchased products/devices and services and thereby giving your consent thereof, you agree and consent to the transfer to and processing of personal information on servers located outside of the country you reside in and that the protection of such information may be different than required under the laws of your residence or nation.

Your Consent

By using and accessing our products and services, and associated services, creating your user account, accessing our platforms and/or by providing your information, you consent to the collection, storing, retention (as per applicable laws), use and sharing of such information in accordance with this Privacy Policy. You specifically agree and consent to us collecting, storing, processing, transferring, retaining (as per applicable laws of India and GCC countries, as the case may be) and sharing information (including personal information) related to you with authorized third parties, our trusted partners and agents, service professionals including vendors for the purposes as set out in this Privacy Policy.

Grievance Redressal Mechanism

Any complaints or concerns with regard to content and/or breach of this Privacy Policy shall be immediately informed to the designated Grievance Officer as mentioned below in writing or through email at: