This Privacy Policy governs how we, PROMORE ADVISORS PRIVATE LIMITED (“PAPL””PROPIRR“ “we,” “us,” or “our”) collect, use, share and process your information, that you provide to us through your use of our website  www.propirr.com (“Website”) in the course of availing services that are made available on the said Website (“Services”), as defined in the Terms to you.

www.Propirr.com , an online Platform, of Promore Advisors Private Limited incorporated under the laws of India and having its registered office located in the State of Maharashtra, understands the importance of your privacy and is obliged to ensure that you are aware of how your information is being used.

PAPL respects your privacy and seeks to comply with applicable legal requirements in respect of data collection, processing and transfer. Please read this Privacy Policy carefully.

WHAT IS PERSONAL INFORMATION?

Personal information is that information which can be used to directly or indirectly identify you. It includes de-identified data that, when linked to other information available to us, would enable us to identify you. Personal data does not include data that has been anonymized or aggregated so that we cannot identify you through it, even in conjunction with other information.

“Sensitive Personal Data or Information” (“SPDI”) means personal information of any individual relating to password; financial information such as bank account or credit card or debit card or other payment instrument details; physical, physiological and mental health condition; sexual orientation; health information such as medical records and history; biometric information; any detail relating to the above as provided to or received by us for processing or storage. However, any data/information relating to an individual that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law shall not qualify as SPDI.

By viewing or visiting our Website, you provide us your consent to process your personal information. In order to access our Services (such as viewing a specific opportunity or contacting PAPL), you will be required to create an account on our Website by providing your personal information, including SPDI, to us. By creating an account, you provide us your explicit consent for the collection, use and disclosure of your SPDI in accordance with this Privacy Policy and the Terms and Conditions. You also represent that you are duly authorised by any third party (including a child or an employer) whose information you may share with us. We shall act as per your representation of authority and shall not make any independent enquiries to ascertain the veracity of your authorisation. In the event you do not have sufficient authorisation, you shall be solely responsible for your acts and omissions including sharing of information with us by you and the consequential processing and actions taken by us in accordance with this Privacy Policy.

ABSOLUTE USER CONSENT:

PLEASE READ THIS PRIVACY POLICY CAREFULLY. YOUR CONSENT TO THE TERMS OF THIS PRIVACY POLICY CREATES LEGAL COMMITMENT FOR YOU AND FOR US. IF YOU DO NOT AGREE WITH ALL THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR WEBSITE

BY ACCESSING OR USING THE WEBSITE, YOU AND THE ENTITY YOU ARE AUTHORISED TO REPRESENT SIGNIFY YOUR AGREEMENT TO BE BOUND BY THE TERMS OF USE.

WHAT DATA COLLECTED FROM USER?

When signing up for our site, you may be asked to enter your name, email address, and phone number to help you get connected with us. Information you provide while visiting our Website or while you are using our website is classified into (i) Personally Identifiable Information, and (ii) Anonymous Information.  The types of information that will be collected by us include the following:

• Contact information: Name, Address, Contact details, Email ID, Phone Number;
• Demographic information: Gender, Age, Date of Birth; Marital Status, Nationality;
• Information pertaining to KYC details such as identity card and other information which is appropriate for legal KYC compliance requirements;
• Your bank account information to process transactions;
• Data regarding your usage of the Services such as search history and history of the appointments made by you through the use of Services;
• Your browsing history including the URL of the site that you visited prior to visiting the Website as well as the Internet Protocol (IP) address of your computer (or the proxy server you used to access the World Wide Web), along your computer operating system and type of web browser you are using as well as the name of your ISP;
• Your information that you make available to us through the social media interface. Please note this will apply if you choose to sign in with your social media account to access or otherwise connect your social media account with the services of PROPIRR, you consent to our collection, storage, and use, in accordance with this Privacy Policy. Please see your social media providers privacy policy and help centre for more information about how they share data when you choose to connect your account;
• Information you provide such data on a voluntary basis. Upon such voluntary disclosure of personal information we may further verify, collate or receive data about you from publicly and commercially available sources (as permitted by law), which we may combine with other data we receive from you. We may also receive data about you from third-party social networking services if you are already connected with those services;
• Any other information relating to the above which you may have shared with us prior to this Privacy Policy for availing any of the Services.

The Website, like many other websites, uses “Cookies”. We use cookies to help us remember and improve our user experience of our site. Cookies are small files that a site transfers to a user’s computer’s Hard drive through a web browser that enables the site’s systems to recognize the user’s browser and remember some information. They are also used to understand the user’s preferences based on previous and current site activity, which allows us to provide you with refined services. Cookies help us compile data about site traffic and interactions to offer better site experiences and tools. You can choose to have your computer warn you each time a cookie is being sent or to turn off all cookies. But, if you choose not to allow cookies, some features of our site will be disabled and will not work accurately.

If you visit any third party websites or links that may be available on the Website, please note that the use and collection of your data will be governed by such third party’s privacy policy.

HOW DO WE USE YOUR DATA?

We use your personal information for purposes that include the following:

• We use data collected from cookies and other technologies to improve your user experience and the overall quality of our Services;
• Send alerts and newsletter(s) to you;
• Communicate with you concerning our Service, so that we can send you details about PROPIRR promotional announcements, marketing purposes and surveys, other services of PROPIRR affiliates;
• For authentication and verification of user;
• To sustain our practices pertaining to risk profiling and other risk management practices;
• Improve our Website and its content to provide better features and Services;
• Conducting market research and surveys with the aim of improving our Services;
• We may share information with law enforcement agencies pursuant to lawful requests for information, and otherwise as required under any law applicable at the given time, both in India and outside India;
• Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings;
• Our automated systems analyse your content to provide you customised search results, recommendations and specific promotions and offers;
• To help advertisers understand our audience and confirm the value of advertising on our Websites (however it is usually in the form of aggregated statistics on traffic to various pages within our site);
• Sharing with our customer support team and other relevant stakeholders to resolve your queries/concerns/feedback related to your rights or Services provided to you.
• If PROPIRR intends on using any Personal Data in any manner that is not compatible with our Privacy Policy, you will be notified prior to the use or at the time at which the Personal Data is collected

HOW LONG WILL WE RETAIN YOUR DATA?

The personal information provided by you is processed by PROPIRR and is kept in a form which permits your identification to be retained for no longer than it is necessary for the purposes for which the personal information is processed. This retention of data is in line with legal, regulatory, contractual or statutory obligations as applicable. At the expiry of such periods, your personal information will be deleted or archived to comply with legal/contractual retention obligations or in accordance with applicable statutory limitation periods.

DISCLOSURE AND TRANSFER OF YOUR DATA

We may share, disclose and in some cases transfer your personal information to such entities as required to provide Services to you, improve our Services, and to provide value added services or other third-party services, to the extent permitted by applicable law. These entities may be located outside India, which you hereby consent to. We require such entities like Google analytics, Optimizely and Hubspot to protect your information through equivalent security measures as what we would adopt. These entities or similar others entities as and when used provide us with information to improve the functionality of the Website.

HOW DO WE PROTECT YOUR DATA?

At PROPIRR, we are strongly committed to protecting the information that you share with us. We ensure that we implement reasonable security practices and procedures (such as managerial, operational, physical and technical) for the purpose of protection of your personal information as the same is of vital importance to us. Your SPDI obtained by us shall not be used or shared other than for the purposes to which you consent.

However, we are not responsible for any loss, unauthorised access, safety issue or any harm caused to you by any misuse of your personal information, unless it is a direct and foreseeable consequence of negligence and non-compliance on our part only. We hereby acknowledge that we are not responsible, in particular, for any third party action or action on your part leading to loss, damage or harm to you or any other person. By accepting this Privacy Policy, you accept that such transmission of your personal information is done at your own risk. Lastly, you are requested to help us protect your privacy by maintaining the secrecy of the username and password you use for any of our Services.

WHAT ARE YOUR RIGHTS?

We take reasonable steps to ensure that your personal information is accurate, complete, and up to date. However, you have the sole responsibility of ensuring that you review the accuracy of information provided by you and contact us in case of discrepancies, or in case you wish to discontinue the use of our Services. You have the following rights with regard to your personal information:

• You have the right to access your personal information, and request updation, correction and deletion. If your personal information changes, you may correct, delete inaccuracies, or amend information by contacting us through info@promoreadvisors.com for customer care. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or subsequently becomes untrue, inaccurate, out of date or incomplete), or we have reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, we may, at our sole discretion, discontinue the provision of the Services to you;
• If you do not want to keep up to date with PROPIRR news and latest information on services and receive such marketing materials, please send an email to info@promoreadvisors.com ;
• To stop us from continuing to use your information, you may revoke, withdraw your consent by writing to us at info@promoreadvisors.com  Please note that upon your refusal to permit us to use any information which we consider to be necessary to provide our Services, we reserve the right to limit or refuse to provide our Services to you;

We will respond to your request expeditiously

THIRD PARTY WEBSITES AND SERVICES

Our Website may contain links to third party services, and give you the ability to access such thirdparty websites, products, and services. Please note that you may proceed to the use of such third party website or service at your own risk and PROPIRR will not be held liable for any outcome or harm arising as a result of your use of such third party websites or services. Please read the privacy policies of any third party before proceeding to use their websites, products, or services.

CHANGES TO THIS PRIVACY POLICY

We may periodically revise or update this Privacy Policy. If we make any changes we will notify you by sending an email that you have used for registering on our website or by a notice on this Site prior to the change becoming effective. Please review this page regularly for the latest updates on our privacy policy.. If you do not agree with any such revised terms, please refrain from using our Services and contact us at info@promoreadvisors.com to close any account you may have created.