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PRIVACY POLICY

This Privacy Policy ("Privacy Policy") describes the types of information that Onato Private Limited, having its office at 6/207, Vipul Khand, Gomti Nagar, Lucknow ("Company"), which is the operator and owner of this App (hereinafter “App”), may collect from a user ("You", "Your", or "User") on or through the App, either directly or in connection with other services rendered by Us, (each a "Service", and collectively the "Services"), and how We use, process, disclose and try to protect such information.

You acknowledge and agree that the Company is responsible for the operation and maintenance of the App, and that any information collected and processed on the App is gathered and used only for the purposes of Our business.

By accessing or using the App or Services, You acknowledge that You have read, comprehended, and agreed to the privacy policies contained in this Privacy Policy (and to the collection, storage, and processing of Your information in accordance with them).

This Privacy Policy is in compliance with the following Laws and Regulations:

Capitalised terms not defined here, including the terms Personal Data, shall have the meaning stated in the Digital Data Protection Act, 2023, whose full text can be found at this link.

In compliance with section 5 of the DPDP Act, this policy acts as a notice on collection of your Personal Data and the purpose of its collection (clause 1 below); the manner in which rights under section 6(4) & 13 and may be exercised (clause 6 below); and, the manner in which you may make a complaint to the Board. As soon as practicable, and by means that we deem appropriate, we may inform you of the same from time to time.

  1. GENERAL TERMS:

By using the App or Service or providing Us with Your information You confirm that You have read, understood, and agreed to the practises and policies outlined in our Terms of Service and this Privacy Policy and agree to abide by them.

If You access or use Services or the App from an overseas location, You are entirely responsible for compliance with any local laws of your location. If accessing our App is prohibited in your location, please do not use the App.

You consent to the collection, use, sharing, and disclosure of Your information in accordance with this Privacy Policy. We retain the right, in Our sole discretion, to alter, modify, add, or delete elements of this Privacy Policy at any time, and your continuing use of the App or Services after any such amendments will be regarded as an implicit acceptance of the Privacy Policy in its revised form. You should review the Privacy Policy on a regular basis to ensure that you are informed of any modifications or updates to the policy's terms. We may also send you notifications of any significant changes to our Privacy Policy or on how we collect and handle private information.

If you do not agree to any of the terms and conditions included in this Privacy Policy, please do not use the App or any Services. This Privacy Policy is subject to change without notice at any time. Please check this policy on the App on a frequent basis to ensure that You are aware of any changes.

  1. YOUR CONSENT

By accessing our the App by filling any onboarding forms (including submitting any OTP sent to you in response to a request by you) or clicking on any notification, SMS or any other messages or by supplying your information by yourself, you agree to the collection, use, storage, disclosure, and other processing of your Personal Information on the App in accordance with the terms of this Privacy Policy. If you submit Personal Information about other persons, you confirm that you have the permission to do so and that you agree to let us use the information in accordance with our Privacy Policy. We may reject any submission made by you at any time without assigning any reason.

Specific Consent: You consent to us (including our affiliates and other third parties whose services you may obtain) contacting you through SMS, instant messaging App, in-App phone call or video call, and/or e-mail for the purposes of providing you Services or showcasing additional Services or other reasons indicated in this Privacy Policy. You also consent to us using your data in other Apps created by us.

  1. INFORMATION HANDLING

In order to provide you with our Services we may require you to provide your contact information to third parties. By making payments to us and using our services you explicitly consent to us providing such information, without any identifiable name and are authorising such third parties, to contact you. Please be aware, that even though we do not collect or require you to furnish any specific names or Personal Information, due to the nature of our Services, You may inadvertently give or We may inadvertently collect information that can specifically identify You or any other individual when you browse the App or use the Service(s).

We may also collect Sensitive Personal Data or Information as defined under SPDI Rules about You when You use Our Service(s) on the App. This information includes Personal Information We receive from You or, on Your behalf, such as information or records relating to the Services availed by You through the App, phone number; name, city of residence, access to your phone contact list (including all information saved in the contact list) and any other information inferred therefrom.

We may also collect payment information such as Your payment card number, expiration date, other bank details, billing and shipping address, Your wallet information or Your UPI information as such. By using the Service, You consent to the recording, storage, and disclosure of such communications You send or receive for these purposes.

The list of information that is identified to be Sensitive Personal Data or Information under SPDI Rules includes the following:

The categories of information that We may gather are listed below:

Information that You provide

Any information You provide on the App or send or furnish to Us about yourself or any one else in any other manner is received and stored by us. We gather registration information such as your phone number, complete name, gender, your city, and email address (as and when collected) when you register on the the App. We use a one-time password issued to Your phone number to validate Your phone number.

We also collect and store contact information that you voluntarily provide to us in order to connect you with other people or third parties who you want to connect with for the purposes of Services or otherwise. We may also collect information from your address book / contacts if you give us such access. We use this information to market our offers, promotions, invitations to join the App or any such services to the contacts in your address book or to the contacts that you explicitly provide to us.

Information that we collect

We collect information while you use the App and which are required for providing You Services on the App including but not limited to the, the App and features you use, and what actions you take in them and other subscription plans, types of content you view or interact with, and how you interact with and other similar attributes.In the event you choose to upload profile picture / photo, do note that the same can be viewed by others.You can choose not to provide certain information eg the profile pictures / photo, but You may not have access to the full extent of the features available on the App.This can include information in or about the content that you provide (e.g. metadata), such as the location of a picture / photo or the date a file was created. Our systems automatically process content and communications that you and others provide to analyse context and what's in them for the purposes described below.

We may obtain information about You from other sources, such as Our partners, advertisers, or third parties registered on the App, and add it to Our account information.

We may collect information you allow us to receive through device settings that you turn on, such as access to your camera or photo information such as the operating system, hardware and software versions information about operations and behaviours performed on the device, such as whether a window is in the foreground or background,

If you use our Products for purchases or other financial transactions (such as when you make a purchase), we collect information about the purchase or transaction. This includes payment information, other account and authentication information, and billing, delivery and contact details.

We also receive and analyse content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, send a message to you or upload, sync or import your contact information.

Such information may include content you post (text, images, graphics, audio, visuals, etc.); Users you follow on the App; Users who follow you on the App; Users who have visited your profile and vice versa; Information on your browser’s user agent string and server logs, including your IP address, information in the cookies and activity on the Application; URL information, time stamp, visit information, your browsing history on the Application; Device information, such as make, model and operating system of the device used for browsing the Application; Date of download and/or reinstall of the App; Events related to your actions (follows, reactions, time spent, etc); Users who send you chat requests and have chatted with you; Locational information as permitted by you etc.

Third Party Tracking Technologies:

"Cookies" and other tracking technologies are used by us. A "cookie" is a text file that is used to gather information about activities on the App, for example. Some cookies and other technologies may be used to retrieve information that a User has already indicated or provided. Most browsers and mobile device settings allow You to manage cookies, including whether or not to accept them and how to delete them. Most browsers/mobile App allow you to be notified when a cookie is received, or you may opt to ban cookies using your browser/mobile applications.

Tracking technologies may collect data such as internet domain and host names, IP addresses, browser software and operating system kinds, stream patterns, and the dates and times that the App are viewed. We use cookies and other tracking technologies to enhance the App, as well as Your experience.

You may refuse all cookies on Your browser or the App at any time by adjusting Your settings to the extent permitted on Your device. However, by doing so, You may be unable to access some features or fully benefit from all products and preference-based advertising in the App. You may delete cookies by following the instructions in your mobile device's "help" file or the browser.

Our App makes use of third-party Software Development Kits (SDKs). The majority of them are various payment methods via which You may pay for an order. To improve Your personal and overall experience, some tools are included.

When You engage with Us, we receive and retain certain sorts of information. For example, when Your web browser visits the App or advertising and other content offered by or on behalf of the App on other web sites, We collect certain kinds of information. Additionally, we may receive/store information on Your mobile device, such as a unique device identifier. We may analyse this data internally and use it to offer You with location-based services such as advertising, search results, and other tailored content.

The DPDP Act, IT Act and the SPDI Rules govern the collection, use, retention, and disclosure of Personal Information, which is defined by the SPDI Rules as any information relating to a natural person that, when combined with other information available or likely to be available to a body corporate, is capable of identifying such person.

You acknowledge that You are freely submitting all information, including Personal Information, SPDI, to Us. Your affirmative consent is required for the collection, use, and dissemination of Personal Information and SPDI.

You are giving Us permission to use, collect, and disclose your Personal Information and SPDI.

Important: You may opt not to supply Us with Personal Information and SPDI; in such an event, We will be unable to provide You with access to the App, or to offer items or provide Services through the App.

Parties who are Privy to Your Information:

Our Company relies heavily on information about You and others users of the App. We will only share Personal Information with third parties as mentioned below after confirming that they have implemented data protection measures and are either subject to this Privacy Policy or follow policies at least as protective as those specified in this Privacy Policy.

You accept the terms of this agreement by using the App and hereby consent to the storage and processing of your Personal Information and SPDI by third parties. We have agreements with third parties such as affiliates or group companies, service providers, retailers, payment gateways, and logistics partners who are the intended recipients and may have access to Personal Information and SPDI but will not disclose such Personal Information or SPDI to any other individual or entity. Some of the third parties are as follows:

It is expressly stated that We will not be held accountable or liable for the acts, omissions, or commissions of such third parties linked with Us. We may, however, assist You in addressing any issues You may have with such third parties.

By using the App, You consent to Us sharing and/or processing Your Personal Information and SPDI with third parties, including those located outside India, as long as they ensure that Your SPDI is protected in accordance with standards comparable to those in India or equivalent international standards.

  1. DISCLOSURE OF INFORMATION

We may release account and other Personal Information when We believe in good faith that such release is appropriate to comply with applicable law including to:

Subject to applicable legislation, We may transmit Personal Information and SPDI to any other corporate body (as defined in the DPDP Act & IT Act, 2000) based in India or any other country that provides at least the same level of data protection as We provide under the provisions of this Agreement.

  1. USAGE OF YOUR INFORMATION

We make use of and gather information in a number of ways in order to deliver Services on the App and to run Our business, including the following:

We may use “cookies” information and “automatically collected” information We collect on the the App to do the following:

We may access or keep Your information if it is required to identify, prevent, or resolve fraud and other criminal behaviour, or to protect the App or safety, property, or rights of others.

We may use information regarding Your location or the location of Your device through which You access the Service for a number of purposes, including without limitation to confirm You are located in a jurisdiction in which the Service is offered and to identify an appropriate delivery partner for conducting the Service effectively.

We may collect, analyse, utilise, publish and produce de-identified information, which may include Your personal or sensitive Personal Information, for any business or other purpose permissible under applicable law, including research and marketing. (collectively referred to as "Purposes").

  1. User Rights

We want to ensure that you are fully empowered on the App and are completely aware of the rights that you are entitled to in the course of using the App. In accordance with sections 11, 12,13 & 14 of the DPDP Act, You have a number of rights in relation to the information we hold about you and We are fully committed to provide you the best and reasonably practicable means of exercising these rights

You may exercise any of these rights by filling out the Grievance Form. This shall be subject to the legal requirements, and our internal procedure.

The App gives you access to a wide range of information regarding Your account and Your activities with the App solely for the purpose of seeing and, in certain situations, amending or deleting information supplied on the App. You have the ability to opt-out of optional services as well, and if you want to opt-in to such services when you join up, you can do so.

  1. WHAT ARE OUR DATA SECURITY PRACTICES?

We implement appropriate technical and organisational security measures to ensure that your personal data is protected to a level commensurate with the risk, taking into account state-of-the-art technologies, implementation costs, the nature, scope, context, and purposes of processing, as well as the likelihood and degree of risk. Personal data is generally transferred encrypted between your end device and us. Third-party access cannot be ruled out if you connect with us by email or through internet service providers or broadband connections. All Personal Information is encrypted in motion and in storage.

  1. HOW SECURE IS THE INFORMATION THAT YOU PROVIDE?

In connection with the collection, storage, and disclosure of Personal Information, we maintain adequate technological, physical, and procedural measures (including SPDI). Due to our security processes, We may occasionally seek verification of identification before disclosing Personal Information to You.

We limit access to Personal Information to Our employees and agents who need to know that information to process it for Us and who are subject to strict contractual confidentiality obligations and may be disciplined or have their relationship with Us terminated if they fail to meet these obligations.

No employee or administrator will have access to Your password or Your account information on the App. It is critical that You safeguard Your account from unauthorized access to Your password and mobile phone.

Important: You must remember to log out of the App once you are done using them. We accept no responsibility for any unauthorised use of Your account or password.

If You suspect any unauthorised use of Your account, You must tell Us immediately by sending an email to the contact information listed in the contact section. You agree to compensate Us for any losses incurred as a result of such unauthorised use of Your account or password.

We will not be able to obtain Your prior consent before disclosing Your information in certain circumstances, including but not limited to information demanded by government agencies or otherwise mandated by law to obtain SPDI, or during investigations of cyber incidents, prosecution of offences, or any other requirement deemed necessary by us.

Furthermore, We shall not be liable for any breach of security or for any third-party actions or events beyond Our reasonable control, including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage devices, computer crashes, breach of security and encryption, poor quality of internet service or telephone service provided by the User etc.

  1. IF YOU ARE A MINOR

The App are accessible exclusively to those who are legally capable of entering into a legally binding contract under the Indian Contract Act, 1872. We implement security measures, including processing Personal Information provided by you, to verify your age. We will restrict/prohibit/stop Your access to the App if you are a Minor. We shall implement such measures as prescribed by the DPDP Act for the purposes of confirming whether you are a minor and on such confirmation seeking the consent of your parent or legal guardian.

If You are a parent or guardian and discover that Your child under the age of 18 has created an account on the Service or has accessed it in any other way without your permission, You may contact Us at grievance.officer@onato.in and request that We delete that minor’s Personally Information information from Our systems.

  1. INTERNATIONAL TRANSFER OF DATA

Personal information about You that we have on file may be transmitted to countries outside of India for any of the purposes outlined in this Privacy Policy in accordance with section 16 of the DPDP Act. You understand and accept that such information may become subject to such countries' laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies, and private persons, as a result of an applicable governmental or regulatory inquiry, court order, or other similar process. Furthermore, a number of nations have agreements with other countries that allow for the exchange of information for law enforcement, taxation, and other purposes.

If we transfer your personal data to third parties for the purposes stated in this Privacy Policy, we will use our best efforts to put appropriate controls and safeguards in place to ensure that your personal data is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a fair, transparent, and lawful manner, and is stored for no longer than is absolutely necessary.

  1. LINKS TO THIRD PARTIES

The App may include hyperlinks to a variety of different websites, as well as ads and connections to third-party App, content, or resources ("Third Party Links"). We have no control over Third Party Links that may appear on the App and are offered by individuals or businesses other than Us. You recognise and accept that We are not responsible for any other sites, App, corporations, or individuals collecting or disclosing Your information. The placement of any Third Party Links on the App should not be regarded as an endorsement, recommendation, or solicitation of such Third Party Links or any other content on or accessible via such Third Party Links.

Additionally, You acknowledge and agree that We are not liable for any loss or damage incurred by You as a result of the collection and/or disclosure of Your information via Third Party Links, or as a result of any reliance placed by You on the completeness, accuracy, or existence of any advertising, products, services, or other materials on, or accessible via, such Third Party Links. This includes any transactions and information exchanged between You and any such third-party sites, App, or resources, which are purely bi-partite in nature. We will not be accountable for any issues that may arise between You and the aforementioned third parties as a result of or in connection with such transactions.

These third-party websites, external App, or resources that are available through the Third Party Links may have their own privacy rules regulating the collection, storage, retention, and dissemination of Your information. We recommend that You exercise reasonable diligence, as You would in traditional offline channels, and use your judgment and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the privacy policies of any third party website or application.

  1. INFORMATION RETENTION AND PURGE

In relation to Personal information and SPDI, we store them for certain predetermined periods on the basis of

We will delete your information whenever you request us to do so. However, we may archive and/or retain some information for legal purposes. Any other information which is processed by us for analytical purposes, will only be processed in an aggregated or non-identifiable basis.

Additionally, We have safeguards in place to ensure that Your Personal Information or SPDI is deleted and/or anonymized as soon as it is reasonable to anticipate that:

i. The reasons for collecting Your Personal Information and SPDI have been met; and

ii. Retention is no longer required by law or for any other reason.

We reserve the right, however, to preserve and maintain Your Personal Information for Our business reasons, regardless of whether such information has been erased. Your data may be anonymized and aggregated after a period of time and then retained by Us for as long as required to allow the purchase of items and provision of Services, or for analytics purposes.

If You wish to revoke Your consent to the processing of Your Personal Information and SPDI, cancel Your account, or request that We stop using Your Personal Information and SPDI to deliver Our products or provide You with services, please contact Us using the contact information provided in the contact section. Please keep in mind, however, that withdrawing permission or canceling your account may result in Our inability to supply goods or offer services to You, or in the termination of any existing relationship We may have with You.

Please note that uninstalling the App WILL NOT result in deletion of Your Personal Information or SPDI.

  1. CHANGES TO YOUR INFORMATION

By logging into Your account, You may check, correct, update, and modify the information You've given. You are not, however, entitled to erase any portion of your Personal Information or other information created on the App. You may request that We erase the information. You may amend Your information at any time by writing to Us at the contact information shown below.

If You choose to update or modify Your Personal Information or SPDI in a way that is not verifiable by Us or results in such information being incorrect, We will be unable to provide You with access to our App, or the Services, as described, and such modification may be interpreted as the User requesting to discontinue access to App, or the Services.

We have the right to verify and validate Your identity and Personal Information to guarantee that goods and services are delivered accurately. We may deny or restrict access to, or correction, update, or deletion of, Your Personal Information or SPDI if doing so would violate the rights of another person and/or is not otherwise authorised by applicable law.

  1. NOTICES

If You have any concerns or complaints regarding the App, please contact Us with a detailed explanation and We will attempt to address the matter for You. You may submit your request using this Grievance Form. If You have any concerns or questions in relation to this Privacy Policy, You may also address them to Our Grievance Officer at:

Name: Sonu Thakur

Address: 6/207, Vipul Khand, Gomti Nagar, Lucknow

E-mail: grievance.officer@onato.in 

We shall endeavour to resolve Your grievances within the timelines prescribed by law.

  1. MISCELLANEOUS

You agree and undertake to compensate Us in the event of any third-party claim or dispute arising out of Your disclosure of information to third parties, whether via the App, and Your use and access to third-party websites, App, and resources. We disclaim any duty for third-party activities involving Your Personal Information or SPDI that You may have supplied to such third parties.

Unless otherwise specifically stated or implied by the context of this Privacy Policy, each clause of this Privacy Policy will be and remain distinct from, independent of, and severable from, all other provisions hereof. The determination or declaration of nullity or voidance of one or more sections shall have no impact on the other provisions of this Privacy Policy.

We cannot guarantee that Your Personal Information and SPDI will never be disclosed in methods not explicitly stated in this Privacy Policy. As a result, although We are dedicated to safeguarding Your privacy, We cannot guarantee that Your information or private conversations will always stay private, and You should not anticipate that they will. As a User of the App, You acknowledge and accept that You are solely responsible and liable for Your use of the App, the internet in general, and the information You post or access, as well as for Your behaviour on and off the App.

This Privacy Policy was last updated on 1 May 2024