What is personal Information
What information is being collected
Where is the information stored
How the information will be processed
Right to access the information/ how and where users can change / amend / delete / object to the information etc.
What is Personal Information and Sensitive Data and Information
"Personal information" means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
Sensitive personal data or information— Sensitive personal data or information of a person means such personal information which consists of information relating to—
your personal picture(s), video(s), text(s), audio(s);
financial information such as Bank account or credit card or debit card or other payment instrument details;
physical, physiological and mental health condition;
medical records and history;
any detail relating to the above clauses for providing products/ service; and any of the information received under above clauses by for processing, stored or processed under lawful contract or otherwise:
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 the purposes of these rules.
Thus, we may use the information freely without your consent in case it is available in Public Domain. Also, we may use above mentioned Sensitive and personal information only in case you provide us the same and agree to our terms.
COLLECTION AND USAGE OF NON-PERSONAL DATA AND APPLICATION DATA
When you visit the Website / Application, we automatically gather and store the following information in order to track use of our Website/Application:
The IP address from which the Website/Application is accessed;
The name of the domain from which our visitors access the Internet;
The type of browser and operating system used to access the Website/Application;
The date and time of your visit to the Website/Application;
Mobile device information (e.g., hardware model, operating system version, device identifier, and mobile network information;
The pages, files, documents and links accessed during your visit; and/or
The internet address of the Website/Application from which you linked to the Website/Application (i.e. the previous site you visited, which referred you to the Website/Application).
The Website/Application shall collect the additional following information:
History of your search data: to see what all pages did the user cover while browsing the Website/Application;
Information provided by you: Any other information provided by you through email, letter or any other medium viz., including your contact details;
Log Data: Whenever you use our Service and if there is an error in the Website/Application, we collect data and information (through third party products) on your phone / computer device called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics. In addition, the Website/Application may collect certain information automatically including the type of mobile device being used to operate the Website/Application, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use and information about the way you use the App etc;
Current location of device by using GPS or Network provider;
Payment Card Details (Excluding your password)
Collection of Data through Social Media Handles(SMH)
When you visit/use our SMH/, we automatically gather and store information that you provide:
We collect the content, communications and other information you provide to us while using our SMH. This includes any and all information that you provide or is visible on open forum, such as your user name, comments, pictures, videos, reviews, location, likes, dislikes or any other information you provide us on our SMH. We may keep a tab on people’s information whom you tag on SMH which may or may not include your friends or relatives.
We collect information about the people, pages, accounts, hashtags and groups that you are connected to or you visit through our SMH. We may also collect information on your interaction with people through our SMH.
We collect information about how you use our SMH picture(s), video(s), text(s), audio(s) or images you upload, category of people you follow or like or dislike and / or category of people who follow / like/ dislike you; your comment or comments about you on our SMH etc.
We also receive and analyse content, communications and information that other people provide when they use our SMH. This can include information about you, such as when others share or comment on a photo/video of you etc.
We keep a track on date and time of your activity on our SMH.
We are committed to striking a fair balance between your personal privacy and ensuring that you obtain full value from the products and services we provide via the Website/Application, while ensuring that we comply with the Information Technology Act 2000 of India, The Information Technology (IT) Rules of India, other Data Protection laws of India, and other prevalent acts or laws including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the “SPDI”) Rules, as amended from time to time. The SPDI Rules states that ‘Sensitive personal data’ or ‘information of a person’ means such personal information which consists of information relating to:
Financial information such as bank account or credit card or debit card or other payment instrument details;
Physical, physiological and mental health condition;
Medical records and history;
Any detail relating to the above clauses as provided to us for providing products/ services; and
Any of the information received under any of the above clauses by us for processing, stored or processed under lawful contract or otherwise.
We are also committed to follow the rules and regulations as prescribed under the General Data Protection Regulation of European Union (GDRP), Data Protection Act, 2018 of U.K. / U.K. General Data Protection Regulation (U.K. GDPR).
COLLECTION AND USE OF PERSONAL DATA
Personal data is neither stored nor captured through the Website/Application without the prior knowledge and consent of users. We may collect and process the following information about you:
information (such as your name, email and postal address, telephone number, job title and date of birth).
in connection with your account - your log-in and password details;
details of any transactions made by you through the Website/Application;
communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Website/Application and its content;
information from surveys, promotions and competitions that we may, from time to time, run on the Website/Application, if you choose to respond to, or participate in, them; and
technical information from your mobile device relating to the services you receive.
Any personal data that you give us will be treated with the utmost care and security. We will hold your personal information on cloud (having single point authentication system) and for as long as it is still used for the purpose stated when originally requested and subsequently be destroyed.
We will use the personal information you provide:
to identify you when you sign in to your account and permit access into limited entry areas of the Website/Application;
to enable us to respond to your requests and process your orders and to provide you with the products/services and information offered through the Website/Application which you request;
to administer your account with us and notify you regarding changes and updates to the Website/Application;
to alert you to special offers, updated information, or new products/services from us or third parties;
to fulfill the terms of a promotion;
to contact you in response to a sign-up form such as the “Contact Us” form;
to verify and carry out financial transactions in relation to payments you make online;
to analyze use of the Website/Application and the people visiting in order to improve our content and products/services including research into our Users’ demographics and tracking of sales data;
to send you information we think you may find useful or which you have requested from us, including receipt of marketing communications such as our periodic newsletter, offers and promotional material;
for marketing and promotional activities for us through the SMH;
for in-depth analysis of the market and user base via statistics and other such means;
for sharing the user experience with prospective clients, investors and user base;
for enabling our representatives/ personnel to understand your needs, provide better experience and improvise accordingly;
for creating and maintaining a brand image for us in the eyes of the existing and prospective users and other market determinants in various ways including:
alert you to special offers, updated information, or new products/services from us or third parties;
send you information we think you may find useful or which you have requested from us, including receipt of marketing communications such as our periodic newsletter.
telemarketing and promotions of our and our associated partners products and services and our partners/ customers products and services.
We make every effort to ensure the secure collection, transmission, storage and use of personal data in accordance with the nature of such data. We reserve the right to share your personal data with third parties on a need to know basis.
SHARING OF PERSONAL DATA
We may share or disclose your personal information in the following instances:
To fulfill a service to you. For example, if you request a product or service from us, we may share your personal information with third parties (like courier services) in order to deliver the product or service to you. In addition, if you email us a question or send us sms, we may use your email address and / or phone number to process your request and respond to your question.
To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your personal information for research, administrative and/or internal business purposes. These parties may use your personal information to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes. IN THE EVENT IF YOU DO NOT WANT US TO SHARE YOUR PERSONAL INFORMATION IN THE MANNER MENTIONED HEREIN, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.
To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Website/Application and provide other administrative services to us (including, but not limited to, order processing and fulfilment, debt collection, providing customer service, maintaining and analysing data, sending customer communications on our behalf and other promotions. We seek to ensure that these unaffiliated third parties will not use the personal information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Website/Application will have access to users’ personal information, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any personal information to us.
To fulfill your order. If you choose to make a purchase on the Website/Application, we may collect your credit card number, billing address and other information related to such purchase, and we may use such collected information in order to fulfill your purchase. We may also provide such information, or other personal information provided by you, to unaffiliated third parties as necessary to complete your purchase (for example, to process your credit card).
To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property or act in urgent circumstances to protect the personal safety of our end users.
To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
To track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
To protect against potential fraud, we may verify with third parties the information collected from our Website/Application. In the course of such verification, we may receive personal information about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us, and that the card has not been reported as lost or stolen.
Except as described in this Policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your personal information to any third parties.
We make every effort to ensure the secure collection, transmission, storage and usage of personal data in accordance with the nature of such data. We reserve the right to share your personal data with third parties on a need to know basis.
Any such user who has provided data to us and wishes for it to be removed in accordance with the laws of the Land, (including right to rectification, right to object/restrict to processing), can contact us through our portal/website / application.
The data thus collected from the you will be GDPR compliant and will uphold:
Right to rectification
Right to be forgotten (erasure of data)
Right to restrict/ object processing
Right to data portability
ACCESS TO PERSONAL DATA
You may request a copy of all the personal information about you saved in our records. On request, we will provide you with a copy of this information subject to a reasonable fee.
RIGHT TO RECTIFICATION
If you think that your data / information in our record is inaccurate or incomplete or has changed, you can ask us to display the correct / accurate / complete data. Should you request that we amend or remove records containing your personal data, we will endeavour to do so as promptly as practical. However, you may receive communications for a transitional period while we process your records.
RIGHT TO ERASURE OF PERSONAL DATA (“THE RIGHT TO BE FORGOTTEN”)
You have the right to erasure of your personal data from our records in the following circumstances:
If the personal information we hold about you is no longer necessary for the purposes for which it was collected.
If you withdraw your consent for the collection, storage and processing of your data.
We are processing your personal information for direct marketing purposes and you want us to discontinue.
If you think we have processed your personal information unlawfully.
In any of the above situations, we may ask you for an explanation and verification of your request.
RIGHT TO RESTRICT / OBJECT TO PROCESSING
You have the right to object for processing your personal data in the following circumstances:
Personal information used for direct marketing
We may use advertisers, third party ad networks, and other advertising companies, to serve advertisements on the Website/Application. Such advertising companies may gather information about your visit to the Website/Application or other sites (such as through cookies, web beacons and other technologies) to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which web pages you were viewing when such ads were delivered.
You have the right to object to the use of your personal information by us to send you direct marketing material at any time. If you opt-out, we will stop using your personal information for direct marketing purposes.
Automated decision making and profiling
We are allowed to carry out automated decisions with no human intervention where you have given your consent to the processing. You have the right to withdraw your consent.
‘Profiling’ is automated use of personal data held on computer to analyse or predict things which have significant effect or legal effect, on the individual. For example, location, health, economic situation, personal preferences or interests etc. You have the right not to be subject to a solely automated decision and / or profiling. If you are concerned that we have made a solely automated decision about you, you can object to the same.
We are also permitted to make automated decisions with no human intervention in the following circumstances:
The automated decision is necessary to enter into, or perform a contract, or complete a contract involving you and us like making an electronic purchase.
The automated decision is allowed under a law passed at European Union level, or at the level of European Union or EEA member state level (i.e., is allowed under a national law) or UK level. The law will provide safeguards to protect your rights and freedoms.
You still have a general right to object on the above and provide reasons for the same. If you object, we will decide whether to review the decision-making process in your specific case after taking into account the facts and circumstances of the case.
RIGHT TO DATA PORTABILITY
You have the right to request and receive a copy of the information provided by you to us in a structured, commonly-used and machine-readable format.
You also have the right to ask us to send the information we hold about you to another organization.
RIGHT TO COMPLAIN TO A NATIONAL DATA PROTECTION REGULATOR
If GDPR is applicable to you and you think we have processed your personal information unfairly or unlawfully, or we have not complied with your rights under GDPR, you have the right to complain to a National Data Protection Regulator.
If Country of Residence is the UK, European Union (EU) or European Economic Area (EEA)
If you live in a country/ territory located in the UK, EU or EEA, and you think that some / all, of the issues have taken place in your country of residence, you can complain to your national data protection regulator.
If Country of Residence is outside the UK, European Union (EU) or European Economic Area (EEA)
If you live outside the UK, EU or EEA, and the data protection issue relates to the processing of personal data in the country you live in, you may be able to complain to your national data protection or privacy regulator. It may be important to note no such Authority exist in India at present.
EXTERNAL LINKS POLICY
The Website/Application may contain hypertext links to other Internet sites which are completely independent of this Website/Application. We make no representation or warranty as to the accuracy, completeness or authenticity of the information contained in any such hypertext link or other Internet site, or that any such other Internet site (or Applications which are linked to such other Internet site) or the server that makes it available is free from computer viruses or any other malicious or impairing computer program, and access to any other Internet sites linked to the Website/Application is at your own risk. Linking to another Website/Application from the Website/Application should not be taken as an endorsement of any kind. Although we endeavour to keep all links up to date, we cannot guarantee that these links will work all the time, and we have no control over the availability of external pages.
FORUMS, CHAT ROOMS AND OTHER PUBLIC POSTING AREAS
Please note that any information you include in a message you post to any chat room, forum or other public posting area is available to anyone with Internet access. If you don’t want people to know your e-mail address, don’t include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE (MALICIOUS OR OTHERWISE) BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.
SOCIAL MEDIA OWNERS
We shall not be held responsible for any act or omission by the Social Media Platform. In case of suspension/termination, hacking or any other activity on your account, we are not responsible for the same. In case of any of the above acts or omissions, kindly contact the platform(s) directly.
We are not liable in case you post any unlawful or infringing content on our SMH. If you post any unlawful or infringing content on our SMH, we reserve our right block the unlawful / infringing content and you from our SMH.
remember that you have used the Website/Application before (this means we can identify the number of unique visitors we receive and allows us to make sure that we have enough capacity for the number of users we get)
allow you to navigate the Website/Application more quickly and easily;
remember your login session so you can move from one page to another within the Website/Application;
store your preferences;
Customise elements of the layout and/or content of the pages of the Website/ Application for you; and
collect statistical information about how you use the Website/Application so that we can improve the Website/Application.
Essential session management
Creating a specific log-in session for a visitor to our Website/Application in order that the Website/Application remembers that a visitor is logged in and that his or her page requests are delivered in an effective, secure and consistent manner.
Recognizing when a visitor to the Website/Application has visited before; this means we can identify the number of unique visitors we receive to the Website/Application and allows us to make sure we have enough capacity for the number of users that we get.
Recognizing when a visitor to the Website/Application is a registered member.
We may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of the Services.
Customising elements of the promotional layout and/or content of the pages of the Website/Application; for example, by storing a country code and providing users with content relevant to their country.
Collecting statistical information about how our visitors use the Website/Application(s) so that we can improve the Website/Application(s) and learn which parts are most popular to visitors.
These Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from children under 18. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and are aware that your child has provided us with personal information, please contact us so that we can take necessary actions.
We take security very seriously and value your trust in providing us your Personal Information. We utilize commercially reasonable safeguards to protect against the unauthorized access, use, modification, destruction or disclosure of your Personal Information. We, thus are striving to use commercially acceptable means of protecting it. We have implemented technology and security features and strict policy guidelines to safeguard the privacy of our customer’s personally identifiable information from unauthorized access and improper use or disclosure. We will continue to enhance the security procedures to the extent possible as new technology becomes available.
No administrator at Skyline will have knowledge of your password. It is important for you to protect against unauthorized access to your password, your computer and your mobile phone. Be sure to log off from your account when finished. We do not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify us by sending an email to __________________.
Skyline makes all User’s information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds its employees to strict confidentiality obligations.
Notwithstanding the above, we are not responsible for the confidentiality, security or distribution of your personal information by the third parties outside the scope of our agreement with third parties. Further, we shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Skyline including but not limited to, acts of government, computer hacking/ penetration testing, unauthorised access to computer data and storage device, phishing, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.
Any information that we collects is not shared with or sold to any third party without the consent of the user or customer, except as mentioned in aforesaid paragraph.
DATA STORAGE AND INTERNATIONAL TRANSFERS
Skyline may collect information relating to the devices through which you access the Website/Application, and data of your usage.However, the Website/Application uses third party services that may collect information used to identify you.
PERMISSIONS REQUIRED BY THE WEBSITE /APPLICATION
There are certain permissions required mentioned as below so that the Application can run smoothly and give you the best output:
LOCATION: Website/Application access the current location of device by using GPS or Network provider.
INTERNET: Website/Application uses the Internet Service (Internet Data) from Network Provider.
STORAGE: Website/Application access the external storage to write data to Memory or Heap on device.
DATA RETENTION POLICY
We retain the data for as long as you use the Website/Application and / or for a reasonable time thereafter depending on the type of information, purpose, means and modes of usage of such information; and according to the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”) and Information Technology Rules 2021. We may save computer web server logs till it is administratively necessary.
We communicate with users who subscribe to our products / services on a regular basis via email and/or text message. For example, for e-mail marketing, we may use your e-mail address to confirm your request, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. If we have the facility and you provide your mobile phone number, we may provide information by text message. Additionally, we may send automated text messages and / or call you. By signing this agreement and providing your mobile phone, you have consented to receive calls, auto-dialled and/or pre-recorded telemarketing text messages or non-automated messages from or on behalf of us and our affiliated companies at the telephone number you provided. You further understand that message and data rates may apply.
We provide you the opportunity to exercise an opt-out choice if you do not want to receive certain types of communication from us, such as emails or updates from us regarding new products and services offered on this Website/Application or if you do not want us to share your personal information with third parties. For e-mails, the opt-out choice may be exercised by ticking or un-ticking the appropriate box if such checkbox is available at the points where information is collected or by contacting us. You also may opt-out of receiving such emails by clicking on the “unsubscribe” link within the text of the email. You may also opt-out by sending us an email at email@example.com. We will process your “unsubscribe” option as soon as possible.
We may change or modify these Privacy time to time without notice to you in our sole discretion. If you use the Website/Application/SMH after any such revisions take effect then you will be taken to have agreed to the revised Terms.
In case of an unfortunate data breach beyond our control, which might put an individual’s rights and freedoms at risk, we are committed to notify the supervisory authority within 72 hours of knowing about data breach.
If the risk to the individual affected by the data breach is high, we will make every endevaour to inform the person concerned as well.
Please submit any questions you have about this Policy or any problems concerning the Website/Application by emailing us at firstname.lastname@example.org.