IF YOU’RE A CITIZEN OF (OR) RESIDE IN EUROPEAN UNION (OR) IS CONSIDERED AS A DATA SUBJECT UNDER THE GENERAL DATA PROTECTION REGULATIONS (“GDPR”), THEN THE GDPR SHALL BE APPLICABLE TO YOU AND THE COMPANY.
1. COLLECTION OF PERSONAL INFORMATION
1.2. It is agreed between the parties that the Company can collect Information pertaining to your identity, demographics, and related evidentiary documentation.
1.3. It is also agreed that the Company may collect your Personal Information when you use our Services or access our Site/App or otherwise interact with us during the course of our relationship.
1.4. The Company may collect, store, process, sensitive Personal Information. This Information may be used to provide you with a better Service experience along with evidentiary purposes.
2. WHAT INFORMATION DO WE COLLECT?
2.1. Our Company collects the following Information from the Vendor (“ Vendor”):
2.1.1. Personal Information
220.127.116.11. Account Holder’s Name
18.104.22.168. Mobile Number
22.214.171.124. Email ID
126.96.36.199. IP Address
188.8.131.52. Government Identity proof of primary account manager of the Vendor
2.1.2. Non-Personal Information
184.108.40.206. Company incorporation documents
220.127.116.11. Authority letter to open account with the Company
18.104.22.168. Product design specification (uploaded in form of product template)
22.214.171.124. Product SKU details
2.2. Our Company collects the following Information from the End-Customer (“End-Customer”)
2.2.1. Personal Information
126.96.36.199. Mobile Number
188.8.131.52. Date of Birth
184.108.40.206. Email address
220.127.116.11. IP address
18.104.22.168. Uploaded photos
2.2.2. Non-Personal Information
22.214.171.124. Product SKU details
126.96.36.199. Product photos
188.8.131.52. Certificate details
184.108.40.206. Verification links
3. HOW DO WE COLLECT YOUR INFORMATION?
3.1. You directly provide the Company with the Information we collect. We collect Information and process Information when:
· Sign-up form is filled in by the Vendor / End-Customer
· Profiled update form is filled in by the Vendor / End -Customer
· Via browser cookies
4. HOW WILL WE USE YOUR INFORMATION?
4.1. Our Company collects your Information so that we can:
4.1.1. Create an organisation Authlink identity.
4.1.2. Provide issuers cryptographic key based signature.
4.1.3. Register a new product template.
4.1.4. Generate smart contract as per product template.
4.1.5. Create a product item’s identity.
4.1.6. Record supply chain information of product with the digital identity.
4.1.7. Product related operations such as transferring, renewing and invalidating products.
4.1.8. Transfer of product ownership to End-Customer at point of sale.
4.1.9. End-Customer can virtually interact with their purchased products.
4.1.10. Perform blockchain based operations including transfer and/or share of ownership
4.1.11. Respond to your request for any Service or assistance
4.1.12. Provide, maintain and improve our Services.
4.1.13. Anticipate and resolve issues and concerns with our Services.
4.1.14. Manage your account
4.1.15. Ensure adherence to legal and regulatory requirements for prevention and detection of frauds and crimes.
4.1.16. The Company may share your Personal Information with the governmental agencies or other authorized law enforcement agencies mandated under law to obtain such Information for verification of identity or for prevention, detection, investigation including but not limited to cyber incidents, prosecutions, and punishment of offences. You agree and acknowledge that our Company shall never be held responsible regarding privacy of your Personal Information in case of sharing your sensitive Personal Information to any to any authorized cyber investigation agency of appropriate government authorities as required under Sections 67C, 69, 69A, 69B, 70B, 79 and 80 of the Act.
5. HOW DO WE STORE YOUR INFORMATION?
5.2. The Information will be stored and processed by Digital Ocean LLC, Google Cloud and Amazon AWS.
5.4. The Company will delete/dispose your Information by using reasonable procedures to erase it or render it unreadable (for example, shredding documents, wiping electronic media etc.) after such period as mentioned above.
5.5. However, please note that such Information provided by you, which is stored in the individual Blockchain nodes as a part of decentralized information storing and recording is not within the control of the Company and the Company does not possess the ability to delete such Information and the same can be deleted / invalidated only by you.
6. SECURITY MEASURES AND PROCEDURES THAT WE HAVE ADOPTED:
6.1. We have implemented reasonable security practices and procedures as per Rule 8 of the Rules.
6.2. We have implemented “Reasonable Security Practices” as required by the Act and the Rules, including any amendment thereof. By complying with such provisions, we assure you proper care and control over our I.T. and security operations as required under relevant sections mainly Section 43, 43A, 45, 66, 72A & 85 of the Act and therefore you agree that we shall not be held responsible for any fraudulent/criminal activity with regard to your Personal Information stored in our Site.
6.3. We have implemented stringent, internationally acceptable standards of technology, managerial security, technical security, operational security and physical security in order to protect your Personal Information from unauthorized access, loss, misuse, disclosure, alteration or destruction.
6.4. The Information resides behind a firewall, with access restricted to our authorized personnel only. Our security practices and procedures limit access to Personal Information on need-only basis. Further, our employees are bound by code of conduct and confidentiality policies which obligate them to protect the confidentiality of Personal Information.
6.5. Our security measures include:
6.5.1. All the information is stored in a secured encrypted database and file storage system.
6.6. Internet Use – We maintain the security of our internet connections, however for reasons outside of our control, security risks may still arise. Any Personal Information transmitted to us or from our online products or Services will therefore be your own risk. However, we will strive to ensure the security of your Information. We observe reasonable security measures to protect your Personal Information against hacking and virus dissemination.
6.7. By using this Site / App or the Services rendered by the Company, you agree that we shall not be held responsible for any uncontrollable security attacks and in such cases, you agree that we shall not be held responsible for any type of financial losses, loss of opportunity, legal cost, attorney’s fees, business losses, reputation loss, direct and indirect losses that may occur to you as per the provisions of Section 43, 43A and 45 of the Act or under any other applicable law.
6.8. We have backup systems in place to ensure data recovery in case of third-party hardware faults. Decentralisation of data among blockchain nodes also ensures data permanency. While the Company ensures industry standard checks in place to safeguard your information, you agree and acknowledge that the Company cannot guarantee recovery of any lost data which is due to third party hardware faults (or) which is not due to the act/omission by the Company.
6.9. You further agree that our Company shall not be held responsible directly or indirectly for any cybercrime related criminal liabilities under the Act, relating to your Information as you have agreed and acknowledged that our Company complies with due diligence (care & controls) requirements of the Act.
6.9.1. Username & password
6.9.2. HTTPS (Secure Socket Layer)
6.9.3. Software firewalls
6.9.4. Anti-virus and anti-spamming software.
6.9.5. Hash algorithms for secured password storage.
6.9.6. Use of strong password.
6.9.7. Log files.
6.9.8. Backup controls.
6.9.9. Cybercrime, cyber law & security awareness for the Company
7. YOU REPRESENT TO THE COMPANY THAT:
7.1. the Information you provide to the Company from time to time is and shall be authentic, correct, current and updated and You have all the rights, permissions and consents as may be required to provide such Information to the Company.
7.2. Your providing of the Information to the Company and Company’s consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third-party agreement, laws, charter documents, judgments, orders and decrees.
7.4. You agree and acknowledge that You are providing your Information out of your free will and consent. You have an option not to provide or permit the Company to collect Your Information or later on withdraw the same.
8. UPDATION OF PERSONAL INFORMATION
8.1. We strive to keep our records updated with your latest Information. To this end, if you see any discrepancy in your Information or if a part of your Information changes, we request you to reach us at firstname.lastname@example.org and communicate the change(s) for updating our records.
9. WHAT ARE YOUR RIGHTS WITH REGARD TO PROTECTION OF YOUR INFORMATION?
Our Company would like to make sure you are fully aware of all your Information protection rights. Every user is entitled to the following:
9.1. The right to access – You have the right to request our Company for copies of your Information. We may charge you a small fee for this service.
9.2. The right to rectification – You have the right to request that our Company correct any Information you believe is inaccurate. You also have the right to request our Company to complete Information you believe is incomplete.
9.3. The right to erasure – You have the right to request that our Company erase your Information, under certain conditions as provided in Article 17 of GDPR.
9.4. The right to restrict processing – You have the right to request that our Company restrict the processing of your Personal Information, under certain conditions as provided in Article 18 of GDPR.
9.5. The right to object to processing – You have the right to object to our Company’s processing of your Personal Information, under certain conditions as provided in Article 21 of GDPR.
9.6. The right to Information portability – You have the right to request that our Company transfer the Information that we have collected to another organization, or directly to you, under certain conditions as provided in Article 20 of GDPR.
9.7. The right to opt-out: Once you are registered at our Site, you will have the option at any stage to inform us that you no longer wish to receive future Services, e-mails and you may “unsubscribe”, “opt-out” or by sending unsubscribe request. Further, as per Rule 5(7) of the Rules, you have an option to withdraw your consent for use of your sensitive Personal Information given earlier to us. Such withdrawal of consent shall be sent in writing to the contact details provided herein below.
9.8. As a responsible Company, we do not use automated decision making or profiling.
9.9. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at:
Write to us at:
S-Link Technology (P) Ltd, Cheran Towers,
78, Govt Arts college Road, Coimbatore.
Tamil Nadu -India -641018
10. WHAT ARE COOKIES?
10.1. Cookies are text files placed on your computer to collect standard internet log Information and visitor behaviour Information. When you visit our Site, we may collect Information from you automatically through cookies or similar technology.
11.1. Save Site login information
11.2. Identify and recognise users
11.3. Preparing customized web pages
11.4. Protecting users from unauthorized access
11.5. Saving user’s encrypted keys
11.6. Saving signing and create transaction information
12. WHAT TYPES OF COOKIES DO WE USE?
There are number of different types of cookies, however, our Site uses:
12.1. Functionality – Our Company uses these cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
12.2. Session cookies - Session cookies are used for storing user’s activity data temporarily in their respective browsers. These cookies store user’s page navigation, encrypted user passkey and pre-rendered webpages. These cookies and recorded information remain active as long as the browser remains active – once the browser is closed, these cookies are destroyed.
12.3. Persistent cookies - Persistent cookies are stored on user’s device for identifying users, recording their sign-in credentials, their account preferences, google analytics and webpage navigation in order to enable a convenient and faster website experience for the users. These cookies have an expiration date set by Company webservers and they expire automatically on 30 days of user inactivity. The user can destroy the information anytime from their device.
13. HOW TO MANAGE COOKIES
13.1. You can set your browser not to accept cookies, and the above Site tells you how to remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result.
14. PRIVACY POLICIES OF OTHER WEBSITES
15.3. If you object to any changes, you may notify us through our Site, email or phone call to unsubscribe you or to remove your Information.
16. HOW TO CONTACT US
Write to us at:
S-Link Technology (P) Ltd, Cheran Towers,
78 ,Govt Arts college Road, Coimbatore.
Tamil Nadu -India -641018
16.2. We have appointed our grievance officer as per Rule 5 (9) of the Rules and you are welcome to keep forth any grievance that you face with regard to privacy of your Information before the grievance officer.
17. APPLICABLE LAWS AND JURISDICTION
18. HOW TO CONTACT THE APPROPRIATE AUTHORITY
18.1. Should you wish to report a complaint or if you feel that our Company has not addressed your concern in a satisfactory manner, you may contact the appropriate authority under the Act or the Information Commissioner’s Office if GDPR is applicable to you, or any other appropriate authority constituted under the relevant law applicable to you.