Privacy Policy

The platform https://www.palmnote.app ("Palmnote") is owned and operated by Palmnote Technologies Private Limited ("Company"), a company incorporated under the laws of India, and having its registered office at #677, 1 st Floor, 27 th Main, 13 th Cross, HSR Layout, 1 Sector, Bangalore 560 102, Karnataka, India.

For the purposes of this Privacy Policy ("Policy"), "we", "our" and "us" shall mean the Company and "you" and "your" shall mean a User of Palmnote, whether as an Owner, a Member or their authorised users. This Policy is a part of and should be read in conjunction with our Terms of Use. Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Terms of Use. Please access and use the Palmnote platform only if the terms of this Policy are acceptable to you.

We hold the sincere belief that you should always know what data we collect from you, the purposes for which such data is used, and that you should have the ability to make informed decisions about what data you want to share with us. This is why we want to be fully transparent about: (i) how and why we collect, store and use your personal data through the various capacities in which you interact with us. and (ii) the rights that you have to determine the parameters of this interaction.

While we would strongly advise you to read the Policy in full, the following summary will give you a snapshot of the salient points covered herein:

• Your personal data relationship with the Company varies based on the capacity in which you interact with us as a User of the Palmnote platform i.e. whether you are an Owner, a Member or their respective authorised users. Based on this, the type of data we collect and the purpose for which we use it may differ and this Policy will clarify such variations.
• We respect your privacy and do not share any personal data with advertisers or third parties.
• We have adopted reasonable security standards and practices to protect the personal data submitted on the Palmnote platform, as required under applicable laws and best industry practices.

This Policy may be changed from time to time, without compromising on your privacy rights and as permissible under law. The updated Policy will be posted here and material changes, if any, will be communicated to Users. Your use of Palmnote will be governed by the Terms of Use and Privacy Policy posted at the time of your use. This Policy has been last updated on September 24, 2020.

If you have any queries or concerns related to your privacy rights on Palmnote or about this Policy, please contact our Grievance Officer at tibin@palmnote.com.

INFORMATION THAT WE MAY COLLECT

We may collect or process the following information from a User:

• Your name, age, gender, date of birth, phone number and e-mail address.
• Details about your organisation, in case you are creating an Account.
• Details about the organisation you are a part of, in case you are a Member.
• Any content that you voluntarily upload on the Palmnote platform.
• Your username or other relevant unique identifier.
• Your login details and password.
• Your IP address.
• Your location.
• Your behaviour on the Platform, (what pages you land on, how much time you spend etc.).
• The device you use to access the Platform and its details (model, operating system etc.).
• Payment information, in case you are an Owner subscribing to additional or premium services.

You are not compelled to provide any personal information to us. By proceeding to access and use Palmnote, you are consenting to the collection and processing of your personal data in accordance with this Policy. In case you do not want to provide any information to us, you are free to do so, however, your usage of the Palmnote platform, and certain features and facilities thereon, may be impeded.

HOW WE USE THE INFORMATION SUBMITTED

Any information submitted by you will be used to help you access and use the Palmnote platform, and provide you a personalized and productive experience.

We may use the information to check the genuineness of any Owner or Member using the Palmnote platform.

We may use the information to send you messages and notifications, for promotional or transactional purposes, either on behalf of the Company or an Owner, or for compliance with applicable laws.

We may also use the information to process your requests, enquiries and complaints.

We may from time to time use the contact information provided by you to inform you about the features and facilities available on the Palmnote platform and or any additional features and facilities that may be introduced.

We may monitor your use of the Palmnote platform to ensure that it is in line with our Terms of Acceptable Use.

We may also utilise the information for analytics and reviews of the services provided by us.

Any payment related information provided by you for subscribing to additional or premium services will be used by us only for the purpose of processing payments due to us.

We may use any content that you voluntarily upload, post or submit on the Palmnote platform for offering better services to you. We will not be sharing such information with advertisers or third parties. however, we cannot control the usage of such information by other Users of the platform.

We may, if required by law, share the information with law enforcement agencies or courts or tribunals who may call upon us to do so.

We may also use anonymized and aggregate information as permitted under applicable law.

However, we will not share your personally identifiable information with advertisers or marketing agencies.

COMPLIANCE WITH MINORS’ RIGHTS

We understand that many Members may be minors under applicable law i.e. individuals under the age of 18. Accounts for minors below the age of 13 can be created only by the concerned parent/guardian. We may seek parental consent before a minor is permitted to access or use certain features on the Palmnote platform. We also comply with applicable laws, rules and regulations regarding protection of personal data of minors.

SECURITY OF YOUR PERSONAL INFORMATION

We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your data from unauthorized access, use, loss, destruction or disclosure.

All personal data collected or processed by us shall be: (i) in compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and other applicable laws from time to time. and (ii) encrypted using industry-standard cryptographic techniques.

ACCESS, CORRECTION, RETENTION & DELETION OF YOUR DATA

Based on technical feasibility and subject to suitable identity verification, we will provide you with access to any personal information that we may have about you.

You may from time to time seek correction or updation of the data provided by you to us.

Any data or information provided by you will be retained in electronic form in our servers. We can provide a copy of the same to you, upon your request, or transmit it to third parties, upon your instructions.

You may seek deletion and erasure of any data or information provided by you at any time. Upon receiving such request (and subject to suitable identity verification), we shall delete all and any personal data we have about you from our servers, without retaining any copies, unless it is needed to comply with our legal obligations, resolve disputes and/or enforce our agreements. We will, however, not be able to control the use of such information by other Users, even thereafter. Also, deletion of certain data may lead to cancellation of your registration with us or your access to the Palmnote platform.

You may request access, correction or updation, or deletion of your data with us, by contacting us at support@palmnote.com.

SUBPROCESSING

In case we engage any sub-processor in relation to any of the services offered by us on Palmnote, we shall do so in accordance with applicable laws and after entering into suitable contractual arrangements with such sub-processors.

Nevertheless, we will continue to be responsible to you as regards the data we collect from you.

THIRD PARTY LINKS

We do not provide third party website links on Palmnote nor do we endorse any third party websites.

In case you access third party websites based on information shared by other Users, you will be bound by the terms of use and privacy policy of such third party website.

We may receive data whenever you visit a third-party link through our platform which includes your user name, the date and time of your visit to the third party website, the web address or URL, technical information about the IP address, browser and the operating system you use.

YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT IN THE EUROPEAN UNION

In case you are a User entitled to data protection under the European Union’s General Data Protection Regulation, 2016 (GDPR), we would like to inform you that our processes are GDPR compliant. Your rights under the GDPR are set out below:

• RIGHT TO BE INFORMED: You have a right to be informed about the manner in which your personal data is collected or used as elucidated in this Policy.
• RIGHT OF ACCESS: You have a right to access your personal data provided to us by requesting us for the same.
• RIGHT TO RECTIFICATION: You have a right to request us to amend or update your personal data if it is inaccurate or incomplete.
• RIGHT TO ERASURE: You have a right to request us to delete your personal data.
• RIGHT TO RESTRICT: You have a right to request us to temporarily or permanently stop processing all or a part of your personal data for any reason whatsoever, including, without limitation for the purpose of direct marketing.
• RIGHT TO OBJECT: You have a right, at any time, to object to our processing of your personal data under certain circumstances.
• RIGHT TO DATA PORTABILITY: You have a right to request for a copy of your personal data in electronic format and to request for transmission of such personal data to third parties for using such third party products/services.
• RIGHT NOT TO BE SUBJECT TO AUTOMATED DECISION-MAKING: You have a right to ascribe explicit consent requirement for any decisions relating to your personal data. You shall not be subject to automated decision making, including profiling.

We will process your personal only on permissible grounds, such as basis your consent or to render the services you request or to serve legitimate interests, as described in the GDPR. Accordingly, the grounds on which we can engage in processing are as follows:

In case we collect and process ‘special categories of personal data’ (such as ethnic origin, genetics or sexual orientation), we will obtain your separate explicit consent for the same for the specified purpose for which the consent was obtained.

If your personal data is transferred to countries not having an ‘adequate’ level of protection or to entities not registered under the EU-US Privacy Shield framework, we shall enter into appropriate data protection addendums with the transferee parties that comprehensively protect your data. We shall also put in place industry-standard technical and organizational measures (including robust data handling policies) to ensure that such transfers are completed in accordance with applicable laws.

In case you want to exercise the rights set out above, do feel free to contact our Grievance Officer whose details are set out below. If you believe we have used your personal data in violation of the rights above or have not responded to your objections, you may lodge a complaint with your local supervisory authority.

GRIEVANCE OFFICER

The name and contact details of our Grievance Officer, who you may contact if you have any concerns, complaints or feedback pertaining to this Policy or your personal data, are as follows: