PRIVACY POLICY

1. 1.Introduction:
   1. 1.1.This Privacy Policy document (“Privacy Policy”) constitutes an agreement between Indian PAC Consulting Private Limited, a private limited company, incorporated and registered under Companies Act 2013, and having its Registered Office at Godrej Waterside, Ring Rd, DP Block, Sector V, Bidhannagar, Kolkata, West Bengal 700091 (hereinafter referred to as “I-PAC” “Company”, “us”, “we” and “our”) and all natural persons whose information is either collected/ received/ possessed/ stored/ dealt in/ handled by the Company (hereinafter referred to as the “Volunteer”, “User”, “you” and “your”).
   2. 1.2.Your privacy is important to us and this Privacy Policy shall govern the User’s access to and usage of “Team Jagan Anna” including the website https: //teamjagananna.com and any and all associated software, all online sources, domains and webpages connected therein (hereinafter referred to as “App” or “Website”).
   3. 1.3.The App shall be operated by the Company on behalf of and under the instructions of Yuvajana Sramika Rythu Congress Party (“YSRCP”), a state political party. The ownership and liability of all content, data (by whatever name it may be called) on this App shall lie solely and exclusively with YSRCP. The Company is merely providing technical support with respect to the operation of this App and acting in the capacity of a service provider. The Company does not have any liability with respect to any data, activity, programme, campaign, content or task conducted on or through this App.
   4. 1.4.This Privacy Policy shall be applicable to all Users of the App including all unique users, registered users, recurring users, former users, current users and all other users from time to time. By visiting and/or continuing to use the App, the User agrees to the terms and conditions contained in this Privacy Policy and the Terms and Conditions document. The User undertakes and confirms having read, agreed and understood the terms and conditions as contained in this Privacy Policy including policies in relation to the collection, usage, storage, transfer, processing, dissemination and disclosure of User Information (as defined in Clause 4.1 below).
   5. 1.5.“Applicable Law(s)” means any act, statute, law, legislation, sub-ordinate legislation, regulation, enactment, ordinance, treaty, rule, judgment, order, award, decree, bye-laws, rule of common law, clearances, directions, directives, guidelines, policy, licenses, requirement, or any governmental restriction or condition including any similar form of decision of, or determination, application or execution by, or any interpretation or pronouncement having the force of law of any government authority having jurisdiction over the matter in question, whether in effect as of the date hereof or thereafter, as may be amended, replaced, re-enacted, substituted, modified from time to time.
2. 2.User Consent:
   1. 2.1.This Privacy Policy is being framed in accordance with the Information Technology Act, 2000 (as may be amended, replaced, re-enacted, substituted, modified from time to time), read with Rule 4 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as may be amended, replaced, re-enacted, substituted, modified from time to time, and Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 as may be amended, replaced, re-enacted, substituted, modified from time to time.
   2. 2.2.This Privacy Policy is subject to the Terms and Conditions applicable to the User. Capitalized terms that are used and not defined herein shall have the meaning as assigned to such terms in the Terms and Conditions document and/or Applicable Law (wherever applicable).
   3. 2.3.Any usage of the App by the User, shall be deemed to be an undertaking that they have read, understood, and agreed to the terms outlined in this Privacy Policy and are bound by such terms. The User hereby consents to the collection, dissemination, use, storage of their Information as described in this Privacy Policy or in any manner as the Company and/or YSRCP deems fit in accordance with Applicable Law. The Company reserves the right to change, modify, amend, vary, add or delete clauses from this Privacy Policy, at its absolute discretion, at any time, without any requirement of any notice or intimation to the User whatsoever. Any continued usage by the User subsequent to such changes to the Privacy Policy shall be deemed to be acceptance of the revised terms of such policy. If at any point the User does not agree with the terms and conditions of this Privacy Policy, the User shall refrain from the usage or any access of the App. The User by means of access to the App consents and permits the Company and/or YSRCP to send notifications including but not limited to granting permission for syncing mobile phone contacts, push notifications and/or such other information when choosing to participate in various uses of the Company’s services and/or YSRCP’s campaigns.
   4. 2.4.In the event of any access or usage of the App on behalf of another individual, including but not limited to, using the app on behalf of a minor/insane individual, the User represents and warrants that the User is authorized by such person to accept this Privacy Policy on their behalf and to consent on and behalf of such person to use such person’s Information as described in this Privacy Policy.
3. 3.Access to User Information::
   1. 3.1.The User represents and warrants that any and all Information entered by the User on the App is voluntary, true, correct and updated to the best of their knowledge. The Company may provide an interface for the User to access and change the relevant Information from time to time using the App. The User may at any time withdraw the consent provided by them, permitting us to collect, disseminate, process, use, disclose and store such Information. However, upon withdrawing of such consent, the User will no longer be able to access the App. In the event of such withdrawal of consent the User shall notify the same to the Company immediately and post such notification the Company shall take reasonable measures to delete such User Information from its servers and storage bases.
   2. 3.2.The User’s right to review, update, correct, and delete their personal information may be limited, subject to the Applicable Law: 1) if requests are abusive or unreasonably excessive; 2) where the rights or safety of another user or persons would be affected; 3) if the information or material request relates to existing or anticipated legal proceedings between the User and the Company and/or TMC, or providing access to the User would prejudice negotiations between the Company or an investigation of possible unlawful activity.
4. 4.Collection of User Information:
   1. 4.1.‘Information’, for the purposes of this Privacy Policy, shall mean and include different forms of data, content, information as provided by the User or collected by the Website, but not be limited to, the following personal information that the User may voluntarily provide during registration:

      Name

      Gender

      Contact details including mobile number, home number, whatsapp number

      Address for Correspondence

      Email address

      Date of Birth

      Profile photos/ User registration photos

      Personal/ Social Media Platforms Details including social media handles.

      Constituency, Assembly, District and State Details

      Domicile and Nationality

      IP address

      Other data that could directly or indirectly identify the User; and

      and other information that the User voluntarily choose to provide

   2. 4.2.The Information collected from the User by the Company may be considered as ‘personal information’ or ‘sensitive personal data’ or information under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011. Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for these purposes. During usage of the App, any personal information which is provided by the User is collected and stored by the Company and/or YSRCP in accordance with the Applicable Law and to ensure safe, effective, and customized experience.
   3. 4.3.A User shall have the option to not provide information on the App. Wherever applicable, the App shall indicate compulsory and optional fields. Based on the User’s continued usage on the App, the Company and/or YSRCP may track information in accordance with Applicable Law to serve the User in a better manner.
   4. 4.4.To monitor and analyze the usage flow, customize promotional features, and promote safety, the Company uses data collection files such as “cookies” and pixel tags, and clear gifs on certain pages of the App. “Cookies” are small files that are stored on a user's Device (“Device” shall mean and include, but not be limited to desktop, laptop, mobile phone, tablet or any other consumer electronic device using which the App is accessed). The cookies are designed to hold a marginal amount of data specific to a particular User and app and can be accessed either by the web server or the user device. This allows the server to deliver a page customized to a particular user. Personal information of the User is not stored by the said cookies, however anonymous information pertaining to location data, demographic information, digital footprints across third-party social media handles and/or public websites, website logs, analytics information from websites and software as a service products, IP address, browser information, version of the operating system with relevant Device id and Information may be stored in the form of Cookies in accordance with Applicable Law by the Company.
   5. 4.5.User Information may be collected by the Company directly in the form of emails/ communications/ suggestions etc. that that User may directly provide to the Company or indirectly by means of tracking tools such as google analytics, google webmaster, browser cookies, web beacons etc. by the User’s usage of the App or through third parties in the event the Company decides to use integrated social media feature on the App.
   6. 4.6.In case the User’s browser permits, the User may decline such storage of cookies on their Device, however, on such declination the User may be unable to use certain features on the App. The User understands and confirms that Cookies may be placed on the App by third parties including but not limited to the Company’s service providers, and the Company and/or YSRCP shall not be liable with regards to the storage, usage, dissemination of such Cookies by such third parties and the User shall refer to the cookie policy of such third parties for relevant information.
   7. 4.7.The User’s account registration Information on the App including not limited to any fellowship, internship, volunteer programs as the Company may host from time to time shall be password protected and only the User shall be able to access such Information. The User undertakes that the User shall not share such password with any other individual/ persons. The Company shall not be responsible for any unauthorized access and usage of such User account by any individual other than the User. The User’s account registration Information on the App including not limited to any fellowship, internship, volunteer programs as the Company may host from time to time shall be password protected and only the User shall be able to access such Information. The User undertakes that the User shall not share such password with any other individual/ persons. The Company shall not be responsible for any unauthorized access and usage of such User account by any individual other than the User.
   8. 4.8.The User understands that several third party advertisements may be displayed during the User’s usage of App and that the Company does not exercise any control over the display of such websites or any information provided therein. The User shall not hold the Company and/or YSRCP liable for any actions arising out of such app/links etc. This Privacy Policy also does not relate to any operating system used by a the User to access the App and for any information which may be stored/collected/used/ disseminated by such operating system, the Company and/or YSRCP shall in no way be held responsible/liable by the User .
   9. 4.9.The Company and/or YSRCP does not make any representations related to the privacy practices or policies of such third parties or terms of usage of such websites, and the Company and/or YSRCP does not guarantee the accuracy, veracity or quality of the information, software, sound, graphics, videos, messages or other materials available on such websites. The User understands and confirms that the inclusion of such third party materials in the App, is not an endorsement by the Company and/or YSRCP of the website, the website's provider, or the information contained therein. Visiting a third-party website linked to the App is solely and completely done at the discretion of the User. The Company recommends the User to read the privacy policy of such third-party websites prior to the usage of the same.
   10. 4.10The Company assumes no responsibility or liability whatsoever for the content, accuracy, reliability or opinions expressed in such websites, to which the App maybe linked (a "linked site") and such linked sites are not monitored, investigated, or checked for accuracy or completeness by the Company. It is the responsibility of the User to evaluate the accuracy, reliability, timeliness and completeness of any information available on a linked site. All products, services and content obtained from a linked site are provided "as is" without warranty of any kind, express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, security, or accuracy.
5. 5.Usage of User Information:
   1. 5.1.The Company may use the User’s personal information in accordance with the Applicable Law for carrying out the following functions on behalf of YSRCP:

      • Verification and/or monitoring the behavior of the User on the Website;

      • communication through Email, SMS, Calls, IVR, WhatsApp, and social media platforms

      • process and respond to your comments, queries and requests;

      • to enhance security features of the Website;

       

      • marketing purposes including to contact User about special promotions, offers, new features offered by the Company;

      • To manage our relationship with the User;

      • For security and business continuity and risk management;

       

      • To meet the legitimate interests to be pursued by the Company and/or YSRCP;

      • for any other purpose in accordance with Applicable Law or with consent.

   2. 5.2.The User understands and confirms that the Company may share User Information with third party service providers including vendors, event organizers, payment processors, sponsors, business partners wherever applicable and the User consents to sharing of such information by the Company in accordance with Applicable Law.
   3. 5.3.The User understands and confirms that the Company may create content and collaboration with various collaborators from time to time which may be hosted on the App. The User grants permission to the Company and/or YSRCP to access Information for the purposes of such collaboration. The User understands that certain content shared on the App may be the sole views and opinions of the collaborators and the User shall not hold the Company and/or YSRCP liable with respect to or in relation to any such content.
   4. 5.4. The Company shall collect personal information that is necessary and relevant to the User experience in the Website. Other than as specifically stated in this Privacy Policy, the Company shall disclose your Information without any prior notification or consent including but not limited to where so required under law, under the direction of the Courts of India pursuant to a court order or subpoena or where so requested by a government, statutory, regulatory agency courts, judicial and quasi-judicial authorities and tribunals, arbitrators and arbitration tribunal or when the Company, in its exclusive discretion, finds it necessary to do so, to ensure that its rights of other parties are protected, to prevent harm to persons or property, to counter fraud, security and credit-related risks including potential risks, for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences, or to enforce the Terms and Conditions (wherever applicable).
6. 6.Data Security:
   1. 6.1.The Company has in place, standard security policies and technical measures to store in secured servers, and protect the information that is possessed by the User’s access and use of the App, from any unauthorized access, improper collection, use or disclosure, unlawful modification, and illegal destruction or inadvertent loss. However, for any loss or theft of Information, due to any unauthorized access of the App, the Company and/or YSRCP shall not be held liable for any loss whatsoever.
   2. 6.2.The Company has reasonable security practices in terms of Rule 8 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 and has a comprehensive documented Information Security Programme consisting of operational and physical security control measures to safeguard the information being collected.
   3. 6.3.While the Company takes reasonable efforts to guard Information, no security system is impenetrable and due to the inherent nature of the internet as an open global communications vehicle, the Company cannot guarantee that Information, during transmission through the internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by other unauthorised users, such as hackers. In addition, the Company cannot guarantee that any passively-collected Information the User voluntarily chooses to store in App are maintained at levels of protection to meet specific needs or obligations the User may have relating to that Information. The User understands and confirms that the security policies maintained by the Company shall be considered as optimal for all security purposes so long as they are in compliance with the Applicable Law.
   4. 6.4.Where the User chooses to download information from the App, the responsibility of securing access to such downloaded information rests solely with the User. The Company strongly recommends that users of such downloaded information configure Secure Socket Layers (SSL) to prevent interception of data transmitted over networks and to restrict access to the databases and other storage used to hold data.
7. 7.Data Storage
   1. 7.1.Information provided by the User are retained (for later of the) (i) as long as the purposes for which such Information were collected continue or (ii) for such period so as to satisfy legal, regulatory or accounting requirements or to protect the Company’s and/or YSRCP’s interests. The Company may need to retain User information for a longer period where such information is required for legitimate purposes for e.g. to help the Company and/or YSRCP to respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc. where not so required, the Company may destroy, delete or anonymise it more promptly.
8. 8.International Users:
   1. 8.1.The User understands and acknowledges that the Company primarily stores Information in relation to User data in accordance with the laws of India including Applicable Law. In the event, the User is visiting from any location other than India including but not limited to the European Union or other regions with laws governing data collection, storage and use, the User undertakes and agrees to the transfer of Information to the Company in accordance with the laws of India notwithstanding the data protection and security laws pertaining to such jurisdiction. By providing User Information, the User unequivocally consents to any transfer, storage, usage and processing of Information in accordance with this Privacy Policy. This Privacy Policy shall be applicable even if the Company transfers Information pertaining to Users to other countries.
9. 9.Confidentiality:
   1. 9.1.The User understands the importance of protecting User Information from unauthorized access and undertakes to log off/exit from the App, wherever applicable. The Company does not undertake any liability for any unauthorized use of User account and password. Any unauthorized usage of the User account should be immediately notified to the Company by sending an email to the Company.
   2. 9.2The User undertakes to indemnify the Company and/or YSRCP due to any loss (actual or anticipated) suffered by the Company and/or YSRCP due to such unauthorized use of User Information.
   3. 9.3The Company shall not be liable for any confidentiality, security, or distribution of User Information by the Company in accordance with Applicable Law. The User shall not hold the Company liable for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of the Company including but not limited to, governmental acts, unauthorized access to Device data and storage device, crashes, breach of security/encryption, Internet service or telephone service-related issues, etc.
10. 10.Disclosure Requirements:
    1. 10.1.The Company shall cooperate with law enforcement, regulatory, statutory authorities, government officials, quasi government entities, tribunals, arbitration courts and private parties to comply with the Applicable Law. The Company shall, in its sole discretion, disclose any information about the User to such parties as it deems fit including but not limited to in the event of an emergency or where necessary to respond to claims and legal processes, to protect the interest of the Company’s or of a third party, to protect the safety of the public or an individual, or to prevent or stop any illegal or unlawful activity including financial crime or fraud. In accordance with Applicable Law, the Company shall take reasonable steps to notify the User in the event of disclosure of User Information.
11. 11.Grievance Redressal:
    1. 11.1.As per the Information Technology Act, 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided herein:

       Name: Suman Mitra

       Email: suman.mitra@indianpac.com

       Any questions pertaining to the Privacy Policy or other privacy concerns, can be mailed at suman.mitra@indianpac.com

    2. 11.2The User may contact the aforementioned in the event of any discrepancies/ grievances in relation to the collection, storage, use, disclosure, and transfer of Information under this Privacy Policy or Terms and Conditions. The details of the grievance officer may change from time to time without any prior notice or information to the User, by updating this Privacy Policy.
12. 12.Updates to the Privacy Policy:
    1. 12.1.This Privacy Policy was last updated on June 27, 2023 and may be updated from time to time at the sole discretion of the Company without any prior notice or intimation to the User. The updated copy of such Privacy Policy shall be made available on the App. The User undertakes and confirms to check the App periodically for such updates.
13. 13.YouTube Privacy Policy:
    1. 13.1.We use YouTube Data APIs to help users manage their YouTube accounts. And we follow YouTube and Google policy when using these APIs. Users can revoke the access of our application to their account via the Google security settings page at https://security.google.com/settings/security/permissions

       Google Privacy Policy: https://policies.google.com/privacy

       By using the application, users agree to be bound by the YouTube Terms of Service: https://www.youtube.com/t/terms

14. 14.Twitter Privacy Policy
    1. 14.1.We use Twitter APIs to help users tweet or retweet a tweet on Twitter. We follow Twitter's privacy policy while using these APIs. Twitter's privacy policy can be accessed here. https://twitter.com/en/privacy
15. 15.Facebook Privacy Policy
    1. 15.1.We use Facebook APIs to help users like a post or follow a page. We follow Facebook's privacy policy while using these APIs. Facebook's privacy policy can be accessed in detail here. https://www.facebook.com/about/privacy/
16. 16.Governing Law and Jurisdiction
    1. 16.1.These Privacy Policy shall be governed by the laws of India and any dispute arising from or in relation to the same shall be subject to the exclusive jurisdiction of the courts of Kolkata.

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