ACUMEN TRACK 2 

      ACUMEN TRACK 2 PRIVACY POLICY

This Acumen Track 2  Privacy Policy (“Privacy Policy”) describes how Acumen Private Limited . and its affiliates (collectively we, our, us”) collect, use, share or otherwise process your personal information through Acumen track 2 , (hereinafter referred to as the “Platform”).This Privacy Policy applies to all current and former users accessing or using Our Platform, or otherwise engaging with us through email or other means (collectively, “You” or “Your”)

THIS PRIVACY POLICY IS AN ELECTRONIC RECORD IN THE FORM OF ELECTRONIC CONTRACT IN TERMS OF INDIAN INFORMATION TECHNOLOGY ACT, 2000 AND RULES MADE THEREUNDER (AS AMENDED FROM TIME TO TIME) AND DOES NOT REQUIRE ANY PHYSICAL SIGNATURE OR SEAL.

Terms and Conditions

Acknowledgement: -

PLEASE READ THIS PRIVACY POLICY CAREFULLY. YOU INDICATE THAT YOU UNDERSTAND, AGREE AND CONSENT TO THIS PRIVACY POLICY. HENCE BY VISITING OUR PLATFORM OR BY USING / AVAILING ANY OF OUR SERVICE OR PRODUCT, YOU HEREBY GIVE YOUR UNCONDITIONAL CONSENT OR AGREEMENT TO ACUMEN  PRIVATE LIMITED . AS PROVIDED UNDER SECTION 43A AND SECTION 72A OF INDIAN INFORMATION TECHNOLOGY ACT, 2000 FOR COLLECTION, USE, STORAGE, PROCESSING, SHARING AND TRANSFER AND DISCLOSURE OF YOUR INFORMATION.

YOU ACKNOWLEDGE THAT YOU HAVE ALL LEGAL RIGHTS AND LAWFUL AUTHORITY TO SHARE THE INFORMATION WITH US AND FURTHER ACKNOWLEDGE THAT BY COLLECTING, SHARING, PROCESSING AND TRANSFERRING INFORMATION PROVIDED BY YOU, SHALL NOT CAUSE ANY LOSS OR WRONFUL GAIN TO YOU OR ANY OTHER PERSON.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS / USE OUR PLATFORM OR AVAIL ANY OF OUR SERVICE OR PRODUCT ON OUR PLATFORM.

1.       Information We Collect (Your Information):

We collect the following types of information about You, both through offline documentation that You may provide, as well as when You use Our Platform: User Information, Demographic Information, Behavioural Information, and Indirect Information, (each of which have been defined below, and collectively, “Information”).

          We collect Your Information either directly from You through offline documentation and/or the Platform or indirectly by using different technologies.

·         User Information

In order to access Our Platform, You may be required to provide Us with information in the nature of Your name, email address, mobile number, the company/ organization You work for, title, designation, physical addresses (collectively, “User Information”).

We may also collect User Information when You visit any of Our offices to enquire about, or avail Our Services or attend any seminars, webinars, conferences or events organised by Us. Further, We may collect User Information that You provide Us with for attending meetings held at Our offices such as accessibility and dietary requirements. Such User Information can imply or suggest a member’s health or other information which may include SPDI (as defined below). You agree and acknowledge that such information is only collected temporarily for the aforesaid limited purposes and consent to Our collection thereof.

·         Demographic Information

We may collect from You, information which is not unique to You and refers to selected population characteristics (“Demographic Information”) including age, gender and current location details.

·         Behavioral Information

We may also collect information about how You use the Platform and information about Your mobile device and software including usage statistics, traffic data, Your IP address, browser and operating system type, domain names, access times, locations, and details regarding the parts of the Platform that You access (“Behavioural Information”).

·         Indirect Information

Your use of certain third party services on the Platform also requires Us to collect such information as is considered necessary for that purpose (“Indirect Information”).

While We may collect Demographic Information, Behavioural Information and Indirect Information when You access or use Our Platform, We collect User Information only from You with Your prior consent unless there are other legal grounds for doing so, as further specified in this Privacy Policy. Where You provide Us with User Information of third parties, We understand that You have obtained consent of such third parties, and have sufficient rights, approvals and licenses to provide such information to Us.

The IT Act and the SPDI Rules regulate the collection, usage, retention and disclosure of personal information, which is defined under the SPDI Rules as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person (“Personal Information”).

The SPDI Rules further define “Sensitive Personal Data or Information” (“SPDI”) of a person as Personal Information about that person relating to:

·         passwords;

·         financial information such as details of bank accounts, credit cards, debit cards or other payment instruments;

·         physical, physiological and mental health condition;

·         sexual orientation;

·         medical records and history;

·         biometric information;

·         any detail relating to the above categories, as specified in this paragraph, as provided to the body corporate for providing services; and

·         any of the information received under the above categories, as specified in this paragraph, by a body corporate for processing, stored or processed under lawful contract or otherwise.

Some of the Information collected by Us may qualify as Personal Information.

We understand that all Personal Information provided by You to Us is voluntarily. Collection, use and disclosure of Personal Information requires Your express consent, unless there are other legal grounds available to us to collect such information as further specified in this Privacy Policy. By using or accessing the Platform or otherwise providing Us with Your Personal Information, where applicable, You are providing Us with Your consent to Our use, collection, retention, transfer and disclosure of the Personal Information in accordance with the terms of this Privacy Policy.

In the event of a change in the law applicable to data protection in India, You hereby expressly consent to Our continued use, storage, collection and disclosure of Your Information including Personal Information to the fullest extent permitted under such applicable law. We may reach out to You for obtaining additional consents and approvals as required under the amended law and You will be required to comply with such requests. Should You choose to not provide Us with such additional consents and approvals, We may have to discontinue your access to the Platform.

You may choose to not provide Us with or withdraw any or all information included under Personal Information, but in the event that You do so, We may be unable to allow you to access the Platform or otherwise avail services for the provision of which your information is being collected or processed.

2.       Communication

We may contact You through email, mobile phone, notices posted on Our Platform and other ways including but not limited to text messages and push notifications. We may send You messages or emails about the availability of Our products and services, notifications, promotional messages, security, or other service-related issues. You may change Your communication preferences at any time.

3.       Manner of storage of Your Information

Your Information will mostly be stored in electronic form however certain data may be stored in physical form. We may store, collect, use and process Your Information within Republic of India and/or outside India subject to compliance under applicable laws. We may enter into agreements with third parties (in or outside of India) to store or process Your Information and such third parties may have their own security measures to safeguard Your Information which security standards as comparable with good industry practices.

4.       Purpose of Collection, Storage, Processing of Your Information:

·         To operate and improve the Platform in order to foster a positive user experience and to improve Our business as a whole;

·         Analysing data, tracking trends, building algorithms, creating databases for rating systems, recommendations engines, etc.;

·         Research;

·         For non-targeting reasons such as frequency capping, compliance, information reporting or delivery, market research or product development purposes;

·         To conduct audits and quality assessment procedures; and

·         To analyse the use of Our resources and troubleshooting problems in relation to Our Platform.

 In addition to the above, We also use Your Information, including Personal Information, for the following purposes:

·         For Our internal operational purpose such as record keeping, accounting and compliance with applicable taxation laws;

·         For the purposes of recording information including dates times and locations at which Our Platform have been accessed by using various tracking technologies and thereby improve Our Platform and Your experience by providing You with relevant information based on the above. Your disabling of tracking technologies on the Platform by changing settings on Your smartphone and/or web browser may result in Your inability to use the Platform fully or at all;

·         For providing You with regulatory updates which We believe are relevant for You;

·         To invite You for seminars, webinars and workshops conducted by Us which We believe may be of interest to You;

·         To comply with applicable law;

·         To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or as otherwise required by law;

·         To respond to any queries that You may have, and to communicate information to You, including notifications of any alerts, any updates to the Platform; and

·         To contact You from time to time to record Your valuable feedback on Our Platform, as they currently stand, and/or any potential services that may be offered in the future;

                          (Collectively, the above constitute “the Purposes”).

5.       Disclosure of the Information

We disclose Your Information including Personal Information, as the case may be to third parties in the manner specified below:

·         Disclosing Your Information including Personal Information to companies and individuals who are acting as our counterparties, consultants and advisors in relation to the Platform;

·         Disclosing Your Information including Personal Information to companies and individuals who are authorised by Us to perform certain functions in relation to the Platform and/or Our business, including Our third party service providers, consultants and professional advisors and insurers;

·         We also share aggregated information about You with partners, other Platform users, and other third parties for the purpose of improving Our Platform;

·         We may transfer Information including Personal Information to third parties, including persons outside India, in furtherance of the above; and

·         We may disclose Your Information, including Personal Information, if legally required to do so, pursuant to an order from a governmental entity or in good faith. We will disclose the Information to: 

·         Conform to legal requirements or comply with legal process;

·         Protect Our rights or property;

·         Prevent a crime or protect national security; or

·         Protect the personal safety of users or the public.

6.       Third Party Links

·         The Platform may contain links to third party websites and services (“Third Party Services”). We have no control over such Third Party Services, which are provided by persons or companies other than Us. We are not responsible for any collection or disclosure of Your information by such companies or persons thereof.

·         Further, We are not liable for any loss or damage which may be incurred by You as a result of the collection and/or disclosure of Your information via Third Party Services. We shall not be liable for any disputes arising from or in connection with such transactions between You and the aforementioned third parties.

·         Such third party websites, and external applications or resources, accessible via the Platform may have their own privacy policies governing the collection, storage, transfer, retention and/or disclosure of Your information that You may be subject to. We recommend that You exercise reasonable diligence, as You would in traditional offline channels and practice judgment and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the third party website or application’s privacy policy.

7.       Security Measures:

We take utmost care to secure Your Information from unauthorised access, usage or disclosure or alteration. We take appropriate steps and security measures to safeguard Your Information and make sure that Your Information is secured as mandated by law. For this purpose we adopt reasonable security practices and procedures, in line with the industry standard, to include, technical, operational, managerial and physical security controls in order to protect your personal information from unauthorized access, or disclosure while it is under our control.

While We protect Your Personal information as per industry standards, You acknowledge that the internet or computer networks are not fully secure and that We cannot provide any absolute assurance regarding the security of Your Personal information. Therefore You acknowledge that You shall not hold responsible Us in any manner whatsoever for loss of Your Information, or any other data, which You shares with Us or which We have with Us if such loss or any damage caused to You because of Force Majeure events. You further acknowledge that any information (including your personal information) transmitted to Us or from Your use of Platform will therefore be at Your own risk.

It is clarified that Force Majeure events includes any event which is beyond the reasonable control from Our side which may include but not limited to sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorised access to computer, computer system or computer network, computer crashes, breach of security and encryption.

8.       Retention of Information

We will put in place measures such that Your Personal Information, which is in Our possession or under Our control, is destroyed and/or anonymized as soon as and in any case, within 5 (five) years of it being reasonable to assume that (i) the Purpose for which that Personal Information was collected is no longer being served by the retention of such Personal Information; and (ii) retention is no longer necessary for any other reason including applicable law.

If You wish that We no longer use Your Personal Information in accordance with the terms of this Privacy Policy, contact Us at 

             support@triposhare.com

We, however, reserve the right to retain, store and use Your Information including Personal Information for Our business purposes, whether such Information has been deleted or not. After a period of time, Your data may be anonymized and aggregated, and then may be held by Us as long as necessary for Us to provide Our Services effectively.

Please note that Your withdrawal of consent to use Your Personal Information may result in Us not being able to provide You with access to the Platform, or terminate any existing relationship that We may have with You.

9.       Disclaimer

We cannot ensure that all of Your Information including Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. Therefore, although We are committed to protecting Your privacy, We do not promise, and You should not expect, that Your Information or private communications will always remain private. As a user of the Platform, You assume all responsibility and risk for Your use of the Platform, the internet generally, and the information You post or access and for Your conduct on and off the Platform.

10.   Indemnity

You agree and undertake to indemnify Us in any suit or dispute by any third party arising out of disclosure of information by You to third parties either through Our Platform or otherwise, and Your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to Your Information or Personal Information which You may have disclosed to such third parties.

11.   Authorization:

You also acknowledge that all the information provided by You are out of Your free will and in compliance with applicable laws in Your territory. If We found that any of Your Information is in non-compliance with the terms and conditions and Privacy policy, We reserve the right to remove your non-compliant information from its systems. By accessing this website we assume you accept these Privacy Statement and express consenting where required. Do not continue to use Our Platform if you do not agree to take all of the Privacy Policy stated on this page. Our Privacy Policy were created with the help of the Privacy Policy Generator. You are advised to go through terms of use of services for availing servicing from or platform

12.   European Union (EU) privacy/data protection rights

EU General Data Protection Regulation (GDPR) has provided the below rights to the EU residents:

·         Right to information - including contact details to the DPO, the purposes for processing Personal Information and the rights of the individual.

·         Right to access the Personal Information that are processed.

·         Right to erasure (“Right to be forgotten”).

·         Right to rectification.

·         Right to restriction of processing.

·         Right to data portability of the Personal Information supplied to Us by the EU resident.

·         Right to object (opt-out) to processing (unless otherwise We have compelling legitimate grounds).

            EU residents can exercise these rights by raising a request directly by contacting us for any specific requirements.

13.   Change in terms of Privacy Policy:

We reserve the right to amend or modify this Privacy Policy at any time, as and when the need arises. We request you to regularly check this Privacy Policy from time to time to keep you apprise of changes made. Your continued use of the Platform gives your unconditional acceptance to such change in terms of Privacy Policy.

        Particulars of corporate entity, Data Protection Officer/Grievance Officer pursuant to the provisions of Companies Act, 2013 and The Indian Information Technology Act, 2000 and rules made and applicable laws thereunder:

         The particulars of various corporate entities of Track \Always Private Limited . for the above purposes are as under:

             14.  To enhance your experience and enable features , We Allow user to Upload Photos/Images 

         ACUMEN  PRIVATE LIMITED . 

If you have any concern related to this Privacy Policy or collection, storage, retention or disclosure of Your Information under the terms of this Privacy Policy or Terms of Use or any other terms and conditions of Acumen  Private Limited. or its other business entities including any queries or grievances, You can contact through its Data Protection Officer/Grievance Redressal Officer at the below given details:

E-mail :  support@triposhare.com  

Working Days : Monday - Friday

Working Hours : 10:00 am - 07:00 pm

We will strive to address your feedback and concerns in a timely and effective manner.

Please note that the details of the Data Protection Officer/Grievance Officer may be changed by Us from time to time by updating this Privacy Policy.