1.1 Ten Times Online Private Limited, (“FLOOR,” or “we,” or “us,” or “our”) is responsible for provision of the App, Website and any of the services accessible through the App and/or Website (our “Services”). Ten Times Online Private Limited is the controller of your personal data in relation to them.
1.3 In the event while using the Services you may be directed to other websites that are operated and controlled by third parties that are beyond our control. This policy does not apply to the privacy practices of these third-party websites. We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites. Please check the privacy policies of these other websites before you submit any personal data to them.
- How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.3 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services.
2.4 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
2.5 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, and company name. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services.
2.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services.
2.7 We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include first and last names, an email address to be used as a login, billing contact information, credit card number and a password. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
2.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
2.11 Please do not supply any other person’s personal data to us unless we prompt you to do so.
2.12 Business Information – Information that is collected by webinar coordinators or moderators is considered confidential. We will not view Business Information except as necessary to appropriately support the service or as required by law. (Business Information includes schedules, attendee lists, subject names, email addresses, names, session records, and any other business information used while in session) When an attendee registers with one of our customers for an online meeting, webinar or training, that information is provided to the organizer of the session. You should be aware that any personally identifiable information you submit while in session and utilizing the chat feature can be read, collected or used by the meeting organizer and other meeting participants. We will not view business information, except as necessary to appropriately support the service and for the purpose of anticipating, diagnosing, supporting or resolving any problems that might limit or disrupt the quality of our customers’ service experience or as required by law.
2.13 We will only use your personal data when we have a legal basis for doing so. The relevant legal bases that we rely on in respect of our processing of your personal data in connection with our Services, are as follows:
Consent: means our processing of your personal data where you have signified your agreement by a statement or action for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want.
Legitimate interests: means our processing of your personal data where this is necessary for our legitimate interests or those of a third party, except where these interests are overridden by your interests or fundamental rights and freedoms. In this case, our legitimate interests are those that we have in:
– to benefit from cost-effective services offered by other service providers;
– to prevent fraud or criminal activity, misuses of our Services as well as the security of our IT systems, architecture and networks and security of our premises;
– to exercise our freedom to conduct a business and right to property; and
– to meet our corporate and social responsibility objectives.
Necessary for compliance with a legal obligation means our processing of your personal data where this is necessary for compliance with a legal obligation that applies to us.
Necessary in connection with a contract means our processing of your personal data where this is necessary for the performance of a contract with you, or in order to take steps at your request before entering into a contract.
Processing in the public interest means our processing of your personal data where this is necessary for reasons of substantial public interest, on the basis of law which is proportionate, respects data protection and provides suitable and specific measures to protect your fundamental rights and interests.
2.14 Purposes for which we use your personal data
|Purpose/Activity||Lawful Basis for Processing|
|Using or sharing personal data to provide products and/or Services to you, to enhance the operations, improve our marketing and promotional efforts, analyse use of the Service, and tailor your experience with third parties.||
|Processing usage data for the purposes of analyzing the use of the website and services.||
|Processing information posted by you/relating to your participation on our platform and your interaction with our Services.||
|Processing, profile data for the purposes of enabling and monitoring your use of our Services.||
|Provision of our services to you, including processing transaction data for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.||
|Allocations of rewards to you, including loyalty points and digital vouchers or subscriptions whenever applicable, including entering a sweepstakes or contest.||
|Sending you marketing communications by electronic means and building profiles of your interests and using this information to provide you with targeted and personalised events online including responding to your queries enquiring about our services.||
|Storing your personal data and keeping records of our processing activities.||
|Complying with legal obligations that apply to us in connection with provision of our Services.||
|Operating and improving our business, use of our Services (including insurance, audit, accounting, training and similar administrative purposes)||
|Managing our relationship with you.||
|Processing your contact details where another user refers the Services to you or invites you to use our Services.||
|Protecting our rights, those of our staff and customers||
3. Providing your personal data to others
3.1 We may disclose your personal data to any professionals that provide services to us, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments.
3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.5 We do disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Non-Personally Identifiable Information.
- Release of Non-Personally Identifiable Information.
5.1. We may disclose or share Non-Personally Identifiable Information with Third Party Providers and the public. For example, we may share aggregated demographic information (which does not include any Personally Identifiable Information) or use Third Party Providers to track and analyze Non-Personally Identifiable usage and volume statistical information from our users to administer the Service. We may also publish this aggregated information for promotional purposes. Such data is collected on our behalf and is owned and used by us.
5.3 Additionally, we share your personal data with other third parties (as explained below).
– public authorities, regulators or judicial bodies where we are compelled by the law to disclose your information or it is otherwise reasonable for us to do so in the circumstances;
– investors, their advisers and other relevant third parties in in the event of an actual or potential sale or other corporate transaction related to our business; and
– any other third parties, if authorized by you to do so in relation to a specific disclosure.
International Transfers from EEA:
When processing your data that has been transferred from European Economic Area or “EEA”; we make sure that this is done using an appropriate level of protection such as putting in place a contract containing Standard Contractual Clauses, which have been approved by the European Commission.
- About cookies
6.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
6.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session.
6.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
- Cookies used by our service providers
- Managing cookies
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
9.2 Blocking all cookies will have a negative impact upon the usability of many websites.
9.3 If you block cookies, you will not be able to use all the features on our website.
10.1 We continuously improve our websites and our products, and we utilize different third-party web analytics tools to help us do so. We are interested in how visitors use our websites, our desktop tools, our mobile applications, what they like and dislike, and where they have problems. Our products, desktop tools and mobile applications use analytical tools to understand feature usage patterns, to enhance and improve your product experience and offer you specific usage tips and guidance. In connection with normal business operations, as well as to increase functionality and enhance your user experience, this usage information may be linked to personal information that we have about individual users. We maintain ownership of this data and we do not share this type of data about individual users with third parties.
10.2 Our mobile applications will also use analytical tools to help gather non-personally identifiable data about download and application usage. We may use information such as IP addresses to determine the general geographic locations of our visitors, but this information is not correlated to personal information about individual users. The web beacons used in conjunction with these tools may gather data such as what browser a person uses, what operating systems are used, domain names, MIME types, what is downloaded, and what content, products and services are reviewed when visiting or registering for services at one of our websites or using one of our mobile applications.
10.3 This information is used solely to assist us in maintaining a more effective and useful websites and products for our customers. This data will not be shared with third parties without your prior consent or unless required by law.
- Consent to Transfer of Information.
- Security of Information.
12.1. In the event you are provided with an opportunity to establish and account or profile on our Site, you may be able to access your Personally Identifiable Information via the Service with your password and username. This password is encrypted. We advise against sharing your password with anyone. If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanism appropriately and limiting access to your computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. If we believe that the security of your information may have been compromised, we may seek to notify you of that development.
12.3. Please be aware that no data transmission over the Internet or via e-mail is completely secure and therefore we cannot guarantee protection of all personal information in all cases. For example, we cannot guarantee protection against interception, misappropriation, misuse, or alteration, or that your information will not be disclosed or accessed by the unauthorized acts of others. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. If you provide us with your credit card number, you should not send it electronically unless the email is encrypted, or your browser indicates that the access to our website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public, not secure, and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other parties.
- European Privacy Rights
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
– baseless or excessive/repeated requests, or
– further copies of the same information.
– Alternatively, in some cases we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know. Please note that, in relation to subject access requests, if we require more time to consider your request where it is complex or where we have received a number of requests from the individual, we will let you know within one month of receiving the request and explain why the extension is necessary
|Rights||What does this mean?|
|The right to rectification||You are entitled to have your personal data corrected if it is inaccurate or incomplete.|
|The right to erasure||This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.|
|The right to restrict processing||You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.|
|The right to data portability||You have rights to obtain and reuse your personal data for your own purposes across different services.|
|The right to object||You have the right to object to certain types of processing, including processing based on Legitimate Interests or which is carried out for the purposes of direct marketing.|
- Marketing Communications
You can sign up to receive email or newsletter communications from us. If you would like to stop receiving these communications, you can update your preferences by using the “Unsubscribe” link found in these emails, or by emailing email@example.com
We may send you push notifications to update you about any events or promotions that we may be running. If you don’t want to receive these types of communications, you can turn off the setting on your device that allows these notifications to be delivered.
15.1 The Service is not directed to children under the age of eighteen (18). If you become aware that your child has provided us with personal information please contact us at the email address listed below. If we become aware that a child under this age has provided us with personal information, we will take steps to remove such information and terminate the child’s account.
- Retaining and deleting personal data
16.1 This Section 15 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
16.2 Personal data that we process for any purpose or purposes shall be kept until such time as we receive a request for deletion from you. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.
16.3 Notwithstanding the other provisions of this Section 16, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Grievance Officer
In accordance with the applicable laws, the name and contact details of the Grievance Officer are provided below:
Mr. Danish Ali Khan
Email ID: firstname.lastname@example.org