PRIVACY POLICY
Please read this policy carefully
We, Harbinger Systems Private Limited, are the owners of http://www.exaltive.com/ (“Website”) which showcases our products and services (“Offerings”).
We respect data privacy rights and are committed to protecting personal information collected on this Website. This privacy policy (“Privacy Policy”) sets forth how we use and protect the personal information collected on this Website.
1. What Qualifies as Personal Information
For the purposes of this Privacy Policy, any information (such as name, email id, company name, phone number, IP address etc.) provided by you or collected by us, as a result of your use / access of the Website, that can identify you as a person shall be referred to as “Personal Information”.
2. Applicability of GDPR
Residents of the European Union (“EU”) should note that this Privacy Policy has been updated in accordance with the requirements of the EU General Data Protection Regulation (the “GDPR”). As per the provisions of the GDPR we shall be considered the Controllers of the Personal information collected as a result of your use / access of the Website.
For Non-EU residents, by continuing to use or access the Website, you agree to this Privacy Policy. If you do not agree to this Privacy Policy, you may not use or access the Website.
3. What Personal/ Non-Personal Information do we Collect?
To request a demo for our Offerings, fill in our product form or to get in touch with us through the through the ‘contact us’ link on the Website you would need to provide us with Personal Information such as your name, country, organization, phone number and e-mail address etc.
We may also automatically collect non-personally identifiable information through cookies to improve our Website and Offerings, such as pattern of your use of the Website, our Offerings, visits, material that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information, IP address and date and time when you access or use website. Cookies are small encrypted files, that the Website transfers to the device through which you access our Website. For more information, please refer to our cookie policy.
Google Analytics-This Website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, text files that are stored on your computer and enable analysis of your use of the Website. The information generated by the cookies about your use of this Website are usually transferred to a server of Google in the US and stored there. In case of activation of IP anonymization on this Website your IP address from Google will be truncated within Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address is transmitted to a Google server in the US and shortened there. You can refuse the use of cookies by selecting the appropriate settings on your browser software. You can also prevent the data generated by the cookie and related to your use of the Website to Google and the processing of these data by Google, by clicking the following link (https://tools.google.com/dlpage/gaoptout), choosing the available browser plug-in and installing it.
Accuracy of information. Please make sure that any Personal Information you share with us is accurate and upto date information. If you are sharing any Personal Information on behalf of a third person, you should ensure that you are authorized to do so.
4. What do we do With Your Personal Information?
We use the Personal Information for the following purposes:
(i) to provide you information about our Offerings and / or our periodic newsletters;
(ii) if we do engage in a business relationship, we may use the Personal Information to provide you the agreed products/ services and to assist you in the event you need any additional support;
(iii) to manage your account;
(iv) for creation or development of business intelligence or data analytics in relation to our Website and/ or the Offerings provided by us;
(v) to assess queries, requirements, and process requests for products and services;
(vi) for client communication, billing and administration;
(vii) to improve usability of the Website and for Website maintenance;
(viii) to process job applications (if you apply for a position with our organization);
(ix) to prevent fraud and abuse;
(x) to enhance the security of the Website;
(xi) to ensure that content from the Website is presented in the most effective manner for you and for your computer;
(xii) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
(xiii) to maintain leads;
(xiv) to run marketing or promotional campaigns;
(xv) to create brand awareness;
(xvi) to improve the Offerings;
(xvii) to provide you information that we may believe may be of your interest;
(xviii) for internal record keeping; and
(xix) to comply with our legal or statutory obligations.
Legal Basis (for EU residents): We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal bases of consent [as provided in Art. 6 (1) (a) of the GDPR], contract [as provided in Art. 6 (1) (b) of the GDPR], or on the basis of our legitimate interests [as provided in Art. 6 (1) (f) of the GDPR], provided that such interests are not overridden by your privacy rights and interests.
5. Whom do we Disclose Your Data to?
We do not sell, rent, share, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Information in the following cases:
- Affiliates: We may provide your Personal Information to our affiliates to enable them to respond to your queries.
- Payment Information: We do not collect banking/ credit card information. Purchases for our offerings are handled by third party websites such as PayPal, among others. For the purpose of the data protection laws and compliances, such third-party service providers shall also act as Data Controllers and we shall not be responsible for the policies and practices followed by such service providers in connection with the privacy and payments.
- Merger or Acquisition: We may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Website, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein.
- Legal and Regulatory Authorities: We may disclose your Personal Information in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.
6. Transfer of Your Personal Information Across Borders (FOR EU RESIDENTS)
We have a worldwide presence through our regional sales or delivery centers. The Personal Information we collect (of EU residents) might be processed outside the EU at a secure center. We collect and transfer Personal Information outside the EU in accordance with the provisions of the GDPR. If you have questions, please contact us as at complianceofficer@harbingergroup.com.
7. How Long do we Retain Your Personal Information?
7.1
We endeavour to only collect only such Personal Information that is necessary for the purposes indicated here, and to retain such data for no longer than is necessary for such purposes. The length of time Personal Information is retained, and criteria for determining that time, are dependent on the nature of the Personal Information and the purpose for which it was provided/ collected.
The below table explains, by way of example, the nature of the data and for how long it is retained.
Nature of the data | Purpose for collection | Period for which it is retained |
Login credentials(Display name, Username, Password, social media authentication information for login using Google, LinkedIn, Twitter, Facebook) | Authenticate users for use of the Product | Deleted after the ‘grace period’* of one month after the expiry date of the subscription. |
Data entered by the user while using various features of the product. (source video links and information, information entered by subscribers while adding interactive layers on videos like annotations, button text, hyperlinks, quiz data, etc) | Facilitate users to use all features of the Product | Deleted after the ‘grace period’* of one month after the expiry date of the subscription. |
*Grace Period is the period after the expiry of the subscription during which Exaltive retains login credentials and user data added by the users while using the product in trial mode or paid subscription mode.
The login information of the user will be retained for one (1) year as a separate backup.
7.2
Subject to this section, we will try to delete your Personal Information upon reasonable written request for the same. Please note, however, that there might be latency in deleting Personal Information from our servers and backed-up versions might exist even after deletion. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact complianceofficer@harbingergroup.com.
8. Our Security Measures
We store your Personal Information in secure servers located in the USA. Although we provide appropriate firewalls and protections, we cannot warrant the security of any Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we assume no liability or responsibility for it. You are required to be careful to avoid “phishing” scams, where someone may send you an e-mail that looks like it is from us asking for your Personal Information.
9. Your Rights (For EU Residents)
You have the right to access your Personal Information in our possession, right to have us rectify or modify any such Personal Information, right to have us erase/delete your Personal Information, right to restrict us from processing such Personal Information, right to object to our use of your Personal Information. If you would like to exercise ANY of these rights, please contact complianceofficer@harbingergroup.com
10. Child Access
Our Website is meant for adults. We do not knowingly collect information from or about children under the age of 18. If you are a parent or guardian and think we have information about your child, please contact complianceofficer@harbingergroup.com.
11. Links to Other Websites
Our Website may contain links to other websites/applications of your interest. Unless the third-party websites/ applications are owned by members of the Harbinger Group, we do not have any control over them and you will be accessing them at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/applications. You should exercise caution and look at the privacy policy applicable to such websites/applications.
12. Limitation of Liability
To the extent permissible under the law, we shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data, information, or other intangible losses (even if we have been advised of the possibility of such damages), arising out of this Privacy Policy.
13. Governing Laws and Disputes
This Privacy Policy shall be construed and governed by the laws of India without regard to principles of conflict of laws. Any dispute arising, between you and us shall be submitted to the arbitration to be conducted in Pune, India in English language, in accordance with the provisions of Arbitration and Conciliation Act of 1996, by a sole arbitrator (appointed by us), and the award made in pursuance thereof shall be binding. Subject to the arbitration provisions, you agree that the courts in Pune, India shall have an exclusive jurisdiction over such disputes.
For any EU residents, this Privacy Policy shall be governed by the provisions of the GDPR.
14. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. We shall provide you with an email notification indicating any material changes in the Privacy Policy. Additionally, you are encouraged to check this Privacy Policy on a regular basis to be aware of the changes made to it.
This Privacy Policy was last modified in November 2018.
15. CONTACT US
If you have any questions or concerns or grievances regarding this Privacy Policy, you can email us at complianceofficer@harbingergroup.com.