SEQR

Summary

Our Privacy Policy is provided below in entirety. This summary provides an insight into our privacy practices. We intend to continue to communicate and provide meaningful notices when we make changes to our privacy practices.

Nothing in this policy contradicts the following statements.

Collection of data

We do not collect any of your personal information (including personally identifiable information), other than information you voluntarily provide.
We do not collect any sensitive information such as racial or ethnic data, sexual orientation, pregnancy or childbirth information, disability, religious or philosophical beliefs, trade union membership, political opinion, genetic information, or biometric data
We do not sell your personal information to advertisers or other third parties.
We share your personal information only when legally required, or when reasonably necessary to prevent harm in an emergency situation.
We do not have access to your contact list unless you allow us access
We retain your personal information, excluding information you make public, for not more than 30 days after you request deletion.

## Privacy controls

We do not share your activity and/or usage history for the app
We do not share information about searches performed in the app
We do not share your location data - either in coarse or precise form (as a latitude and longitude with three or more decimal places)
We do not track your activities on the device when using other apps or sites
We do not listen/record using the device microphone

## Data use

We do not display 3rd party advertisements in the app, or share the data with entities who display such ads
We do not track usage patterns data to evaluate user behavior, including to understand the effectiveness of existing product features, plan new features, or measure audience size or characteristics

PRIVACY POLICY

The mobile application, ‘SEQR’ (“Application”) is owned and operated by Dhiway Networks Private Limited, a company incorporated in India under the Companies Act, 2013, having its registered office at 1st floor, Wing A, GoodWorks Infinity Park, 21, 2nd main road, Phase-1, Electronic City, Bangalore - 501100 (“Company”).

The Company is, inter alia, engaged in the business of developing, hosting and operating “SEQR”, which is an Application built to identify unsafe websites across the web and notify users of potential harm (together, the “Services”).

This Privacy Policy (“Privacy Policy”) sets out the privacy practices of the Company with respect to the entire content of the Application.

This document is published in accordance with the provisions of the Information Technology Act, 2000 and the Reasonable Security Practices and Procedures and Sensitive Personal Data or Information Rules, 2011 that require publishing the rules and regulations and privacy policy on an online portal. We request you to go through this Privacy Policy and the Terms of Use (available on the Application) carefully before you decide to access this Application.

For the purposes of this Privacy Policy, the words “us”, “we”, and “our” refer to the Company and all references to “you”, “your” or “user”, as applicable mean the person who accesses, uses and/or participates in the Application in any manner or capacity.

We have taken all the necessary and resonable measures to protect and secure your personal information and maintain the confidentiality of the user information and its transmission over the internet.

We’re committed to protecting your privacy and collecting only the minimum amount of information needed to provide our software and services. Your use of the Services indicates you agree to this policy and our Terms of Service.

Complete Terms

As used in this policy, “Personal Information” is data that can identify a particular person or device. Aggregate data is not considered Personal Information.

1. Collection of Personally Identifiable Information (PII)

This version of the SEQR app does not collect any information which can be used to identify an individual user. The complete functionality of the SEQR app is available to the user without any constraints, restrictions and limitations arising from any need to provide personally identifiable information.

2. Collection of Information

To the extent allowed by law, we are the sole owners of the information collected through the Application. To the extent we are not allowed to own the information under law, you hereby grant to us, a perpetual, royalty free and irrevocable license to use the information on the terms and conditions contained herein. We may collect and process information provided by you, including but not limited to:

your email address or an username to communicate with you.
improve the Services and your experience on our site, we may collect aggregate usage data from the Services and our website, including number of page views, visitor browser types, operating systems, or the links clicked to navigate to and from our site.
any data that is automatically captured by the Application and shared voluntarily.

(hereinafter, collectively referred to as “Personal Information”).

3. Use of Information Collected

3.1 Use of Personal Information for Services

The primary goal of the Company in collecting Personal Information is to provide you an online platform for the purpose of providing the Services. The Company may use Personal Information provided by you in the following ways:

To provide and help provide you the Services;
To observe, improve and administer the quality, features and functionality of the Services;
To analyze how the Application is used and to diagnose technical problems;
Remember basic Personal Information provided by you for effective access;
To notify you about any changes to the Application;
To enable the Company to comply with its legal and regulatory obligations;
For the purpose of sending administrative notices, Service-related alerts and other similar communication with a view to performing the Services effectively and optimizing the efficiency of the Application;
Doing troubleshooting, protection against error, project planning, fraud and other criminal activity; and
To enforce the Company’s Terms of Use.

3.2 Sale of Assets, Merger, Acquisition, Bankruptcy

Information collected from you may be transferred to a third party as a result of a sale or acquisition, merger or bankruptcy involving the Company.

3.3 Cookies

Cookies are small portions of information saved by your browser onto your computer / mobile / tablet or other devices. Cookies are used to record various aspects of your visit and assist the Company to provide you with uninterrupted service.

Other than as mentioned elsewhere in this Privacy Policy, the Company may share aggregated demographic information with the Company’s partners or affiliates. This is not linked to any Personal Information that can identify an individual person. The Company will not be liable for transfer of any Personal Information resulting from loss or distribution of data, or corruption of media storage, power failures, natural phenomena, riots, act(s) of vandalism, sabotage, terrorism and any other event beyond the Company’s reasonable control. Further, the Company’s Privacy Policy does not cover the use of cookies by its partners and affiliates since the Company does not have access or control over such cookies.

4.2 Regulatory Disclosures

In the event the Company is required to disclose any Personal Information by law, rule, regulation, enforcement, governmental official, legal or regulatory authorities or any other statutory bodies, court orders or other legal process or for any tax authorities (“Required Disclosures”), your Personal Information may be disclosed pursuant to such Required Disclosures. Required Disclosures may be made without notice to you. The Company may further disclose your Personal Information to such third parties to whom it transfers its rights and duties under any agreement entered into with such third parties and may also disclose your Personal Information to any of its affiliates or related entity.

4.3 Link to Third Party Applications

This Application may contain links which may lead you to other Applications. Please note that once you leave the Company’s Application you will be subjected to the privacy policy of the other Application. The linked sites are not necessarily under the control of the Company. Please be aware that the Company is not responsible for the privacy practices of such other Applications. The Company encourages you to read the privacy policies of each and every Application that collects Personal Information. If you decide to access any of third-party sites linked to the Application, you do this entirely at your own risk. Any links to any third-party partner of the Company should be the responsibility of such third party providing the linking facility, and the Company will not be responsible for notification of any change in the name or location of any information on the third-party Application.

5. Non-Disclosure of Information

The Company pledges that it will not sell or rent your Personal Information to anyone and your Personal Information will be protected and maintained strictly confidential by the Company except in the following cases:

A Required Disclosure of your Personal Information;
The Company may disclose your Personal Information in order to provide you the Services, enforce or apply the Terms of Use, or to protect the rights, property or safety of the Company, its users or others. This includes exchanging information with other companies / agencies that work for fraud prevention;
The Company may disclose your Personal Information to such third parties to whom it transfers its rights and duties under any agreement entered into with such third parties; and
The Company may disclose your Personal Information to any of its affiliates or related entity.

6. Security of Information

The Company has put in place appropriate methods and managerial procedures to safeguard and secure Personal Information. The Company only processes Personal Information in a way that is compatible with and relevant for the purpose for which it was collected from or authorized by the user.
The Company uses commercially reasonable precautions to preserve the integrity and security of your Personal Information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment.
Personal Information that is collected from you may be transferred to, stored and processed at any destination within and / or outside India. By submitting Personal Information on the Application, you agree to this transfer, storing and / or processing. The Company will take such steps as it considers reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.
In using the Application, you accept the inherent security implications of data transmission over the internet. Therefore, the use of the Application will be at your own risk and the Company assumes no liability for any disclosure of Personal Information due to errors in transmission, unauthorised third party access or other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to hold the Company responsible for any breach of security.
In the event the Company becomes aware of any breach of the security of your Personal Information, it will promptly notify you and take appropriate action to the best of its ability to remedy such a breach.

7. Exclusion

This Privacy Policy does not apply to any information other than information collected by the Company through the Application including such information collected in accordance with the clause on “Collection of Information” above. This Privacy Policy will not apply to any unsolicited information provided by you through this Application or through any other means. This includes, but is not limited to, information posted on any public areas of the Application. All such unsolicited information shall be deemed to be non-confidential and the Company will be free to use, disclose such unsolicited information without limitation.
The Company also protects your Personal Information off-line other than as specifically mentioned in this Privacy Policy. Access to your Personal Information is limited to employees, agents or partners and third parties, who the Company reasonably believes will need that information to enable the Company to provide Services as described under Clause 2.1. However, the Company is not responsible for the confidentiality, security or distribution of Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties.

8. Data Retention

The Company shall not retain Personal Information longer than is necessary to fulfil the purposes for which it was collected and as permitted by applicable law. If you wish to cancel your account or request that the Company no longer use your information to provide you Services, contact us through email at data.governance@dhiway.com. However, even after your account is terminated, the Company may retain your Personal Information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons.

The consent that you provide for the collection, use and disclosure of your Personal Information will remain valid until such time it is withdrawn by you in writing. If you withdraw your consent, the Company will stop processing the relevant Personal Information except to the extent that the Company has other grounds for processing such Personal Information under applicable laws. The Company will respond to your request within a reasonable timeframe. You may withdraw your consent at any time by contacting the Company or by using the functionalities of the Application.

10. Right To Correction

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. The Company relies on the users to disclose to it all relevant and accurate information and to inform the Company of any changes. If you wish to make a request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to data.governance@dhiway.com.

11. Data Transfer

The Company may transfer information that it collects about you, including Personal Information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. These countries may have data protection laws that are different from the laws of your country and, in some cases, may not be as protective. The Company shall take appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Policy.

12. Notification of Changes

From time to time, the Company may update this Privacy Policy to reflect changes to its information practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If the Company makes any material changes, it will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

13. Opt Out Procedures

Upon initial communication from the Company, you may opt-out of receiving further communications from the Company. To be completely removed from the Company’s mailing list, you may contact us at data.governance@dhiway.com. If you are using an e-mail forwarding service or any other similar service please make sure to include the correct e-mail address or addresses.

14. Grievance Officer

In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below: Name: Pradeep KP Contact Number: +91 80 47113328 Email Id: grievance.officer@dhiway.com

15. Address for Privacy Questions

Should you have questions about this Privacy Policy or Company’s information collection, use and disclosure practices, you may contact us at data.governance@dhiway.com. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of Personal Information about you. Except where required by law, the Company cannot ensure a response to questions or comments regarding topics unrelated to this policy or the Company’s privacy practices.