1. Information Qwardo maintains on behalf of Customer
- Customers choose what information to collect or make available through the Services we provide on their behalf, and the Customer’s end users interacting with the content or Services (“End Users”) may upload or post information to the Services (collectively, “User Content”). Depending on the Customer, User Content may contain Personal Information. For the purpose of clarity, “Personal Information” as used herein shall mean any data of the Customer or the End Users, by which he/ she/ it, as a person can be identified, including without limitation, name, gender, mobile number, business name, address, email address, date of birth, date of incorporation, any identity proof number, phone number etc., to which Qwardo has or is likely to have access by virtue of the Customer’s or the End User’s consensual submission. The Company receives and maintains this information on behalf of the Customers in order to provide the Services, and the Company does not use such information for any other purpose except as set out herein, or as directed by the Customer, or as otherwise required or permitted by applicable law. In the given situation, Qwardo shall process an End Users Personal Information in the role of a processor. The Company relies on the Customers to comply with applicable privacy and related laws when collecting, using or disclosing personal information in connection with the Services.
- If any End Users signed-up to receive marketing communications from one of the Customers of Qwardo and now wish to unsubscribe, please contact the Customer directly as the Company is not responsible for the sending of such communications.
- As an End User, if your data has been submitted to Qwardo by a Customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the Customer directly, because we may only access the User Content upon instructions from the respective Customer. If you wish to make your request directly to Qwardo, please provide the name of Qwardo’s Customer who submitted your data. Qwardo will refer your request to the concerned Customer and will support such Customer as needed in responding to your request within a reasonable timeframe.
2. Information directly collected from the Customers
- Qwardo may also collect such other anonymous data that is not associated with or linked to any Personal Information (“Anonymous Data”) and which, by itself, does not permit the identification of any individual person. Anonymous Data includes without limitation, unique identifiers of the device on which Qwardo is installed, such as VPN, information of WiFi connectivity and such other information. Qwardo may also store these unique identifiers, at many times and create a profile for the respective anonymous based on such Anonymous Data.
- Log file information is automatically reported by the Customer’s browser each time a webpage is viewed. When a Customer registers with Qwardo, its servers automatically record certain information sent by the web browser whenever such Customer visits a website. These server logs may include information such as web request, Internet Protocol (IP) address, Analytical Code, Geo Stamp, browser type, browser language, referring/exit pages and Universal Resource Locators (URL), platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular page, the date and time of the request (“Log File Information”). Such Usage Information collected is not associated with any Personal Information and is only tagged to the unique identifier for a particular device.
You may opt-out of collection and usage of data through cookies by clicking on the “don’t track” or “DNT” option on the Website that lets you tell the Website that you do not want to have your online activities and data tracked.
4. Usage of information
The Company may collect and process the Personal Information and other information collected as mentioned above for any of the following purposes –
- to effectively provide the Services;
- for the purposes of software verification or administering software upgrades;
- to allow the Customers and End Users to participate in surveys regarding Services;
- to improve End Users’ service;
- provide custom, personalized content and information;
- monitor the effectiveness of Our marketing campaigns;
- monitor aggregated metrics such as total number of visitors and traffic;
- to maintain the quality of Services and provide general statistics regarding their use;
- to deliver Services, including email notifications, confirmations, technical notices, updates, security alerts, and support and administrative messages that the Customer or End Users may request;
- archival or backup purposes;
- to alert the Customer about updated information and such other new or updated services that may be offered by us;
- to allow access to exclusive features or functionality of Qwardo;
- to launch and/or open other mobile applications installed on the device of the Customer and End Users based on functionality of Qwardo;
- to resolve disputes, collect fees and troubleshoot problems;
- if you contact Qwardo through the “Contact Us” function on the Website, or by any other means, Qwardo will process your Personal Data to the extent it is necessary for the purpose of its legitimate interests to fulfil your request and communicate with you;
- to plan and host an event or webinar, including engaging in related communication with you;
- to cooperate with public and government authorities, courts or regulators in accordance with the Company’s legal obligations under applicable laws to the extent required; and
- to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters) about the Company and its affiliates and partners, including information about its promotions or events as necessary the Company’s legitimate interests to conduct direct marketing.
5. Sharing of the collected information
- The Company may share the Personal Information received from the Customer:
- with its affiliates in connection with matters relating to the consumption of Services by Customer to help detect and prevent identity theft, fraud and other potentially illegal acts; correlated or multiple accounts to prevent abuse of Services; and to facilitate joint or co-branded services that Customer requests, where such services are provided by more than one corporate entity other than the Company;
- with its contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment; and
- The Company shall not rent, sell or otherwise provide Personal Information received from the Customer and End Users to third parties without their consent, except as described in this Policy or as required by law.
- In case of a merger with or transfer of business of the Company to another business entity, the Company will transfer Customer’s Personal Information and such other information collected to the entity which acquires the business. In such cases, the Company shall require that the new business entity to follow this Policy with respect to the Personal Information.
6. Data security
- The Company is committed to protect the security of any Personal Information and uses reasonable efforts including a variety of security technologies and procedures to help protect such Personal Information from any unauthorized access, loss, use or disclosure. The Company will take all reasonable measures in furtherance of the above commitment. However, the Company cannot guarantee that the Personal Information received from the Customer and other information stored on the servers will be absolutely protected. Company’s systems and the communications networks through which the Customer accesses Qwardo may be subject to security breaches and failures due to circumstances beyond Company’s reasonable control. These may include computer “hacking”, data theft or and physical theft among others. In such situations, the Company, in compliance with the applicable data protection laws, will try to rectify the problems as soon as possible.
- Any data destroyed shall be disposed of in a manner that protects the privacy of the Personal Information received by Qwardo from the Customer in an appropriate manner as per the industry standard practices and norms.
- The Customer hereby acknowledges and understands that all Personal Information provided in using Qwardo is with their knowledgeable consent and at the Customer’s own risk.
7. Customer’s and End User’s Rights
You have certain rights regarding your Personal Information, subject to the local data protection laws. If you are in the European Economic Area (EEA), you have the following rights:
- Right to Access: You have the right to request for a copy of, or access to your Personal Information held by us. You may be required to prove your identity before providing the requested information;
- Right to Rectification: You have the right to direct Qwardo to rectify any inaccurate or incomplete Personal Information;
- Right to Deletion; Right to be Forgotten: You have the right to request that Qwardo to delete your Personal Information to the extent Qwardo is not required to retain such data in order to comply with a legal obligation;
- Right to Restriction of Processing: You have the right to restrict Qwardo from processing your Personal Information;
- Right to Data Portability: You have the right to request Qwardo to transfer your Personal Information to another data controller to the extent possible;
- Right to Object: You have the right to object to any processing of your Personal Information carried out on the basis of our legitimate interests;
- Right to Withdrawal of Consent: If you have consented to the processing of your Personal Information by Qwardo, you have the right to withdraw your consent at any time.
8. International Transfer of Data.
In the process of providing Services to the Customer, Qwardo may transfer the Personal Information and other information that it collects to affiliated entities or other third parties across borders, and from the Customer’s country or jurisdiction to other countries or jurisdictions around the world. Therefore, your Personal Information may be processed outside the EEA, in countries which may not provide for the same level of data protection as in the EEA. In this event, Qwardo will ensure that such recipient offers an adequate level of protection by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or Qwardo will ask you for your prior consent to such international data transfers.
Qwardo may use third-party advertising companies to serve advertisements when the Customers contact them. These companies may use information (not including name, address, email address, or telephone number of the user) about the Customer’s visits to Qwardo and other websites in order to provide advertisements about goods and services of interest to Customers.
11. Contact Us
Any grievances or questions regarding this statement should be directed to the following e-mail address: email@example.com.