Cyril Amarchand Mangaldas owns and manages the website www.cyrilshroff.com and the blogs under the primary domain www.cyrilamarchandblogs.com (“Platforms”). We value your privacy and take our responsibilities in relation to your data seriously.
- Section 43A of the Information Technology Act, 2000 (“IT Act”);
- Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”); and
- Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
- What information We collect;
- How We collect and use that information;
- How You can provide information selectively, and how You can access and update this information; and
- How We process, share and protect Your information.
1.6 If You are accessing or using the Platforms from any location outside India, You do so at Your own risk, and will be solely liable for compliance with any local laws, as may be applicable.
2. Information Collected and Method of Collection
2.1. We collect the following types of information about You, both through offline documentation that You may provide, as well as when You use Our Platforms: User Information, Demographic Information, Behavioural Information, and Indirect Information, (each of which have been defined below, and collectively, “Information”).
2.2. We collect Your Information either directly from You through offline documentation and/or the Platforms or indirectly by using different technologies.
2.3. In order to access Our Platforms, 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”).
2.4. 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.
2.5. 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.
2.6. We may also collect information about how You use the Platforms 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”).
2.7. Your use of certain third party services on the Platforms also requires Us to collect such information as is considered necessary for that purpose (“Indirect Information”).
2.9. 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”).
2.10. The SPDI Rules further define “Sensitive Personal Data or Information” (“SPDI”) of a person as Personal Information about that person relating to:
- 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.
2.11. Some of the Information collected by Us may qualify as Personal Information.
2.13. 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 Platforms.
2.14. 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 Platforms or otherwise avail services for the provision of which your information is being collected or processed.
3. Use of Information
3.1. We use Your Information for the following purposes:
- To operate and improve the Platforms 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.;
- 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 Platforms.
3.2. 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 Platforms have been accessed by using various tracking technologies and thereby improve Our Platforms and Your experience by providing You with relevant information based on the above. Your disabling of tracking technologies on the Platforms 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 Platforms; and
- To contact You from time to time to record Your valuable feedback on Our Platforms, as they currently stand, and/or any potential services that may be offered in the future;
(Collectively, the above constitute “the Purposes”).
3.3. If You wish to opt out of receiving communications such as information regarding the Platforms and/or any regulatory updates provided by Us, You may do so by emailing Us at firstname.lastname@example.org.
3.5. Our processing of Your Personal Information in the context of Your visit to, and use of Our Platforms are based on Our legitimate interests to operate an internet website and blogs for general information and communication purposes, to optimize Our website and blogs, and to protect it from attacks. Furthermore, Our processing of Your Personal Information for providing regulatory updates or conducting other business development activities serves the legitimate interests of the users to receive training in legal matters and know-how and serves Our legitimate interests to develop Our business and promote client relationships.
4. Disclosure of the Information
4.1. 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 Platforms;
- Disclosing Your Information including Personal Information to companies and individuals who are authorised by Us to perform certain functions in relation to the Platforms 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 Platforms;
- 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.
Such third parties may include:
- Any of Our agents, contractors or third party service providers that process or will be processing Your Information, on Our behalf, including but not limited to those which provide administrative or other services to Us such as mailing houses, telecommunication companies, information technology companies and data centres; and
- Third parties, such as service providers, to whom disclosure by Us is for one or more of the Purposes and such third parties would in turn be collecting and processing Your Information including Personal Information for one or more of the Purposes.
5. Third Party Links
5.1. 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.
5.2. 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.
6. Changes to Your Information
6.1. You may review, correct, update, or change Your Personal Information on the Platforms by emailing Us at email@example.com.
6.2. You may also request Us to delete Your Personal Information, and We will comply with such requests within a reasonable time, unless We are required to keep certain information for legal purposes.
6.3. Should You choose to delete Your Personal Information, or modify it in a way that is not verifiable by Us, or leads to such Personal Information being incorrect, We will be unable to provide You with access to Our Platforms, and such a deletion or modification may be regarded as the user seeking to discontinue access to Our Platforms.
6.4. We reserve the right to verify and authenticate Your identity and Your Personal Information in order to ensure accurate delivery of services through the Platform.
6.5. Access to, or correction, updating or deletion of Your Personal Information may be denied or limited by Us if it would violate another person’s rights and/or is not otherwise permitted by applicable law.
7. Security of Your Information
7.1. We endeavour to maintain physical, technical and procedural safeguards that are appropriate to protect Your Information against loss, misuse, copying, damage or modification and unauthorized access or disclosure. Some of the security measures adopted by Us are:
- We review Our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems; and
- We restrict access to Personal Information, to Our employees, agents and service providers who need to know that information in order to process it for Us, and who are subject to strict contractual confidentiality obligations, and who may be disciplined or whose relationship with Us may terminate, if they fail to meet these obligations.
7.2. Further, We shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Our reasonable control including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.
8. Retention of Information
8.1. 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.
8.3. 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.
8.4. 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 Platforms, or terminate any existing relationship that We may have with You.
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 Platforms 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. Grievance Officer and contact information
In accordance with the IT Act and rules made there under, the name and contact details of the Grievance Officer are provided below:
Mr. Rajesh Pai
You may write to him at the following address:
Cyril Amarchand Mangaldas
Peninsula Chambers, Peninsula Corporate Park, G. K. Marg,
Lower Parel West, Mumbai 400013, Maharashtra, INDIA
Email him at firstname.lastname@example.org