Last Effective Date: June, 2022

Introduction

Welcome to [www.enhancor.com], a website (the “Website”) provided by Enhancor Services Private Limited /or one of its divisions, affiliates, subsidiaries, or joint ventures (“Enhancor”, “Company,” “we”, “our” or “us”).  Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat such information. If you do not agree with our policies and practices, you should not use the Website. By accessing or using this Website, you agree to this Privacy Policy.

Overview

You may use the website to learn about Enhancor’s operations and services.
Our Website may automatically collect certain information from you.
You have the ability to control how certain information is collected and used, as described below.

IT Act

This Privacy Policy shall be construed to be provided in compliance with the Information Technology Act 2000 and the rules framed thereunder including the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 (“SPI Rules”) (as amended from time to time) (“IT Act”).

Personal Information

The term “Personal Information” means information that you provide to us which personally identifies you to be contacted or identified, such as your name, phone number, email address, and any other data that is tied to such information including the heads outlined below. Our practices and procedures in relation to the collection and use of Personal Information have been set out below in order to ensure safe usage of the Website for you. An indicative list of the Personal Information being collected from you is set out below. Please note that the list above is only indicative, and as such, we may collect more information and data points from you, including as detailed in this Privacy Policy.

• Your full name;
• Contact details including phone numbers, physical address (along with the postal code) and email addresses;
• Details of your family and relatives;
• University / college details;
• Government documents and identification numbers including your Permanent Account Number;
• Academic records and certificates;
• Financial information such as transaction histories, bank accounts, credit and debit card details or other payment instrument details;
• Biometric information;
• Information from your email accounts (as permitted);
• Information from your device (as permitted).

Sensitive Personal Data or Information

Under the SPI Rules, sensitive personal data or information of a person means and includes such personal information about that person relating to the following:

• Passwords;
• Financial information such as bank accounts, credit and debit card details or other payment instrument details;
• Physical, physiological and mental health condition;
• Sexual orientation;
• Medical records and history;
• Biometric information; and
• nformation received by body corporates under lawful contract or otherwise.

It is important to note that, the information that is freely available in the public domain, or accessible under the IT Act, or any other law will not be considered Personal Information, or as Personally Identifiable Information.

Information Collection

As a general principle, you will provide us with your personal data entirely voluntarily. There are generally no detrimental effects for you if you choose not to consent or to provide personal data.

Measures to keep Personal Information Confidential

We take the security of our data and information seriously. We take what we believe are reasonable precautions to protect against unauthorized access to our systems and to prevent data from being disclosed to unauthorized parties. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

Your Personal Information will be kept confidential to the maximum possible extent and will be used to support your relationship with Enhancor and as required under applicable Indian laws. We will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information.

Enhancor uses reasonable security measures, at the minimum those mandated under the IT Act and read with SPI Rules, to safeguard and protect your Personal Information. Enhancor implements such measures, as stated above, to protect against unauthorized access to, and unlawful interception of, Personal Information. Additionally, we have adopted measures to ensure that your Personal Information is accessible to our employees or partners’ employees strictly on a need-to-know basis. You accept the inherent security implications of providing information over internet / cellular / data networks and will not hold Enhancor responsible for any breach of security or the disclosure of Personal Information unless Enhancor has been grossly and willfully negligent.

Personal Information may be kept on our personal data technology systems, those of our contractors or in paper files, but primarily your Personal Information will be stored in an electronic form. Enhancor may store, collect, process and use your Personal Information in countries other than the Republic of India and United States of America but under full compliance with applicable laws. Enhancor may enter into an agreement with third parties (in or outside of India or United States) to store collect, process your Personal Information under full compliance with applicable laws.

Notwithstanding anything contained in this Policy or elsewhere, Enhancor shall not be held responsible for any loss, damage or misuse of your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event. A “Force Majeure Event” shall mean any event that is beyond the reasonable control of Enhancor and shall include, inter alia, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption.

Personal Information excluded from this Policy

Any comments, messages, blogs, scribbles etc. posted / uploaded / conveyed / communicated by users on the public sections of the Website becomes published content and is not considered personal information subject to this Policy.

Cookies and Similar Methods

Browsing information is automatically collected through various means such as cookies and pixels on this Website or in our emails. “Cookies” are pieces of information that may be placed on your device by a service for the purpose of facilitating and enhancing your communication and interaction with that service. Many services use cookies for these purposes. We may use cookies (and similar items such as clear gifs, web beacons, tags, etc…) on our Website to customize your visit, to analyze how you use our Website and for other purposes to make your visit more convenient, to manage the payment process or to enable us to enhance our Websites. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge, but may be used to store your login credentials.

We may use Google Analytics, which is a web analytics service provided by Google, Inc. Google and similar services collect certain information relating to your use of the Website. Such services may use cookies to help the Website analyze how users use the Website. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/).

Based on your web browser, you have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the services.  Further information on cookies is available at www.allaboutcookies.org.

How we use your Information

We use information that we collect from you only as described in this Privacy Policy, or as otherwise disclosed to you at the time of collection:

• To operate and provide you with the Website;
• To provide you with information that you request from us or to send you information about our properties and services, such as through newsletters;
• To analyze and improve the Website; and
• For any other purpose with your consent.

Disclosure of your Information

Generally, we will only disclose your Personal Information when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities. Otherwise, we may share your Personal Information in the following circumstances:
we may share your Personal Information between the other Enhancor entities on a confidential basis where required for the purpose of providing products or services and for administrative, billing and other business purposes;

• we may disclose your contact details on a confidential basis to third parties for the purposes of collecting your feedback on the firm’s service provision, to help us measure our performance and to improve and promote our services;
• we may share your Personal Information with companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such Personal Information is shared;
• we may share your Personal Information with any third party to whom we assign or novate any of our rights or obligations;
• we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for Enhancor to exercise or defend a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
• we may also instruct service providers within or outside Enhancor, domestically or abroad, e.g. shared service centers, to process personal data for Permitted Purposes on our behalf and in accordance with our instructions only. Enhancor will retain control over and will remain fully responsible for your Personal Information and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your Personal Information when engaging such service providers; and
• we may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our Website and our services.

Information about others

If you provide Personal Information to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that Personal Information to us and that, without our taking any further steps, we may collect, use and disclose that Personal Information as described in this Policy. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Policy, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual’s right to obtain access to the Personal Information and make complaints about the handling of the Personal Information, and the consequences if the Personal Information is not provided (such as our inability to provide services).

Browsing Information

Browsing Information may be disclosed to any number of third parties and used for any number of purposes as long as it is not directly linked to your personally identifiable information.

Links to other Sites and Social Media Services

We may create links to other websites that we think may be of interest to you, such as social media platforms, suppliers and other third parties. We do not endorse any other websites and services by providing such links, and our privacy policy applies only to your use of our Website. We are not responsible for the privacy policies of any websites and services we link to on our Website, and you should read the privacy policies of each site you visit to determine what information that site may collect about you.  If you have a previous relationship with a third party, such as a social media platform, then they may recognize you and combine information collected through this Website with information they already possess about you.

Updates to your Personal Information

We strive hard to keep our records updated and accurate with your latest information. You shall be responsible to ensure that the information or data you provide from time to time is and shall be correct, current and updated and you have all the rights, permissions and consent to provide such information or data to us. Based on technical feasibility and requirements of applicable laws, we will provide you with the right to review, access and modify the Personal Information that we maintain about you. We may perform verification before providing you access to this Personal Information. However, we are not responsible for the authenticity of the Personal Information provided by you.

Data Retention

We will retain your information for as long as your account is active or as needed for us to manage and provide our services and for our business needs. Even if we delete some or all of your personal information, we may continue to retain and use de-identified or aggregate data previously collected.

Deletion

If you wish to delete the personal information provided to Enhancor, you can always do so by sending a request to us at [email protected]. You have the right to withdraw the consent provided to us in relation to your Personal Information at any time. However, please note that withdrawal of consent will not be retrospective in nature and shall be applicable prospectively. In case you do not provide your information or consent for usage of Personal Information or subsequently withdraw your consent for usage of the Personal Information so collected, Enhancor reserves the right to discontinue the services for which the said Personal Information was sought.

If you wish to delete the personal information provided to Enhancor, you can always do so by sending a request to us at [email protected].

You may note that correction or deletion of certain information or data may lead to cancellation of your registration with the Website or your access to certain features of the Website. You also agree and acknowledge that certain data or information cannot be corrected or deleted and/or is prohibited from being deleted under any applicable law or in lieu of law enforcement requests or under any judicial proceedings.

Opt-Out

• You may opt-out of our promotion emails at any time by emailing us at [email protected], and we will process your request shortly.
• You may block third party cookies on your device as described above.

Changes to our Privacy Policy

This Policy is subject to modification based on changes in the business, legal and regulatory requirements or at our discretion at any time, and will be made available to you online. We will make all reasonable efforts to communicate to you all significant changes to this Policy. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of the Website following any changes means that you have accepted, consent to, and agree to be bound by such revised Privacy Policy. You are encouraged to periodically visit this page to review the Policy and any changes thereto. In case you discontinue the use of the Website, it will not affect the applicability of the Policy to your prior uses of the Website.

Children

Our Website is not intended for users under 18 years of age. We do not knowingly collect personally identifiable information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any personal information from or about a child under 13, please contact us at [email protected].

Feedback

We are committed to protect your Personal Information collected and processed by us and look forward to your continued support for the same. In case of any feedback or concern regarding protection of your Personal Information, or any privacy related feedback or concerns you may contact us at [email protected].

We welcome your views about our Website and our Policy. If you would like to contact us with any queries or comments, please send an email to [email protected].

Contact Us

If you have any questions about this Privacy Policy, please contact us at [email protected].