Privacy Policy

This Privacy Policy expresses our firm commitment to aid our users and visitors better understand what information we collect about them and what may happen to that information. This Privacy Policy is effective as of June 9, 2020.

SBNRI Technologies("SBNRI") values your privacy. In this Privacy Policy ("Policy"), we describe the information that we collect about you when you visit our website and/or mobile application (collectively "Website") and provide your information while using the services available on the Website and other services provided by SBNRI ("Services"), and how we use and disclose that information.

If you have any questions or comments about the Privacy Policy, please contact us at [email protected]. Your use of the Website and/or Services and any personal information you provide on the Website remains subject to the terms of the Policy and SBNRI Terms of Use.

In terms of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, any grievance or complaint may be intimated to Grievance Officer, who may be reached at [email protected]. The complaint shall be redressed within a period of 1 (one) month.

A. Collection of Your Personal Information

1. COLLECTION OF PERSONAL INFORMATION

“Personal information” is defined to include information that whether on its own or in combination with other information may be used to readily identify or contact you such as: name, address, email address, phone number etc.

The type of personal information that we collect from you varies based on your particular interaction with our Website. Personal information collected shall include but is not limited to your name, gender, age, postal address, phone number, email address, contact preferences, ID proof, bank account/credit card/debit card details, KYC details, proof of employment, proof of educational background, and other information that would assist us/our partners in verifying your identity.

If we deem it necessary, in our sole and absolute discretion, we may also ask for and collect supplemental information from third parties, such as information about your credit from a credit bureau (to the extent permitted by law), or information to verify any identification details you provide during registration.

You undertake that your personal information shall at all times be accurate, complete and up-to-date. We shall also make reasonable efforts to provide you with the opportunity to request correction of your personal information provided to us if the same is inaccurate; or even to delete the personal information, if so requested and subject to applicable law. Further, we may decline to process requests which we find to be contrary to the terms laid down under this Policy, Website terms and conditions or any applicable laws, require disproportionate technical effort, jeopardize the privacy of others or are extremely impractical.

2. INFORMATION WE RECIEVE FROM YOUR USE OF OUR SERVICES:

2.1. YOUR CONTACTS

We provide a variety of Services that enable you to effectively manage contact information that you provide to us as part of the Services. SBNRI typically contain information on individuals (or organizations) including names, email addresses, phone numbers and online identifiers. Your Contacts may also contain additional information on individuals such as organizational affiliations, job titles, birthdays, key dates, age, gender, general location, relationships, skills, interests, preferences, notes, photos, tags and other categorizations.

2.2. RELATIONSHIP INFORMATION

Contact book access: Your Contacts suggest a certain relationship between you and the people or organizations those Contacts represent. Your Contacts may explicitly indicate the nature of the relationship. We may also infer the strength or nature of a relationship based on the presence or absence of certain contact information such as mobile numbers or key dates, as well as shared elements such as physical addresses or organizational affiliations. Inferred relationship information may also be based on how you interact with individual Contacts such as how often you access or modify them.
Connected Services: Many of our Services allow you to connect with external systems or databases that may contain information on your relationships, such as “connections” on social networks or other platforms.

3. COLLECTION OF PERSONAL INFORMATION FROM SOCIAL NETWORKING SITES

You may at times be permitted to log into our Website through your other social networking accounts. If you do so, you may enter the email address and password that you use for such social networking accounts. We will ask that you grant us permission to access and collect your basic information (this includes your name, profile picture, gender, networks, user IDs, date of birth, email address, and any other information you have set to public on your account). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public. We store the information that we receive from such social networking sites with other information that we collect from you or receive about you.

Such social networking sites control the information they collect from you. For information about how social networking sites may use and disclose your information, including any information you make public, please consult the respective social networking sites’ privacy policy. We have no control over how any third party site uses or discloses the personal information it collects about you.

4. COLLECTION OF AUTOMATIC INFORMATION, USE OF COOKIES AND OTHER TRACKING DEVICES

We and our third party service providers, which include ad networks, use cookies, web beacons, and other tracking technologies to collect information about your use of our Website and Services, such as your browser type, your ISP or operating system, your domain name, your access time, the URL of the previous website you visited, your page views, your IP address, and the type of device that you use. We also track how frequently you visit our Website and use our Services. We use this information (including the information collected by our third party service providers) for Website analytics (including to determine which portions of our Website are used most frequently, what our users like/do not like), to assist us in determining relevant advertising (both on and off our Website), to evaluate the success of our advertising campaigns, and as otherwise described in this policy. We may obtain your device ID, which is sent to SBNRI’s servers and used in fraud prevention efforts.

Cookies. We and our third party service providers collect information from you by using cookies. A cookie is a small file stored on user's computer hard drive containing information about the user. The cookie helps us analyze web traffic or informs you about your use of a particular website. Cookies allow web applications to respond to you as an individual, tailoring its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. When you visit the Website, we may send one or more cookies (i.e., a small text file containing a string of alphanumeric characters) to your computer that identifies your browser.

Some of these cookies may be connected to third-party companies or websites. The terms of use of such cookies are governed by this Policy and the privacy policy of the relevant third party company or website. For example, Google measures the performance of advertisements by placing cookies on your computer when you click on ads. If you visit the Website when you have such cookies on your computer, we and Google will be able to tell that you saw the ad delivered by Google. The terms of use of these cookies are governed by this Policy and Google's Privacy Policy.

Disabling Cookies. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you disable cookies you may be prevented from taking full advantage of the Website because it may not function properly if the ability to accept cookies is disabled.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

You acknowledge that some entities and /or countries where we may transfer your personal information may not comply with data protection policies which are as stringent as the laws of your own country or the policies followed by SBNRI. You acknowledge that it is adequate that when we transfer your personal information to any other entity within or outside your country of residence, we will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy.

B. How SBNRI Uses the Information We Collect

1. HOW PERSONAL INFORMATION IS USED

We collect your personal information and aggregate information about the use of our Website and Services to better understand your needs and to provide you with a better Website experience. Specifically, we may use your personal information for any of the following reasons and you consent to the same:

To provide our Services to you, including registering you for our Services, verifying your identity and authority to use our Services, and to otherwise enable you to use our Website and our Services;
For customer support and to respond to your inquiries;
For internal record-keeping purposes;
To process billing and payment, including sharing with third party payment gateways in connection with Website and/or Services;
To improve and maintain our Website and our Services (for example, we track information entered through the "Search" function; this helps us determine which areas of our Website users like best and areas that we may want to enhance; we also will use for trouble-shooting purposes, where applicable);
To periodically send promotional emails to the email address you provide regarding new products from SBNRI, special offers from SBNRI or other information about SBNRI that we think you may find interesting;
To contact you via email, telephone, facsimile or mail, or, where requested, by text message, to deliver certain services or information;
For SBNRI 's market research purposes, including, but not limited to, the customization of the Website or Services according to your interests;
We may use your demographic information (i.e., age, postal code, residential and commercial addresses, and other various data) to more effectively facilitate the promotion of goods and services to appropriate target audiences and for other research and analytical purposes;
To resolve disputes, to protect ourselves and other users of our Website and/or Services, and to enforce our Website’s terms and conditions;
We also may compare personal information collected through the Website and/or Services to verify its accuracy with personal information collected from third parties; and
We may combine aggregate data with the personal information we collect about you.

From time to time, SBNRI may use personal information for new and unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change regarding information previously collected, SBNRI shall make reasonable efforts to provide notice and obtain consent of any such uses as may be required by law.

It is further clarified that your registration or provision of information on the Website shall be deemed to be your consent to be contacted for the purposes mentioned above, (i) on the mobile number shared by you even if you are registered with the National Customer Preference Register (NCPR) and have opted out of receiving promotional calls and messages and (ii) by way of SMS or email notifications or messages in any other electronic form.

C. Electronic Newsletters, Invitations, Polls and Surveys

At our sole discretion, SBNRI may offer free services on the Website, which you may select to use or receive at your option. Certain of the following services may require you to provide additional personal information as detailed below:

1. ELECTRONIC NEWSLETTERS

We may offer a free electronic newsletter to users. We will gather the email addresses of users who sign up for SBNRI for the newsletter mailing list. Users may remove themselves from this mailing list by opting out of receiving newsletters during the registration process, by following the link provided in each newsletter that points users to a subscription management page where the user can unsubscribe from receiving newsletters or by changing their preferences in their Settings page.

2. "SEND TO A FRIEND"

Our Website users can voluntarily choose to electronically forward a link, page, or document to someone else by clicking "send to a friend." To do so, the user must provide his or her email address, as well as the email address of the recipient. The user's email address is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose.

3. POLLING

We may offer interactive polls to users so they can easily share their opinions with other users and see what our audience thinks about important issues, Services, and/or the Website. Opinions or other responses to polls are aggregated and are not identifiable to any particular user. We may use a system to "tag" users after they have voted, so they can vote only once on a particular question. This tag is not correlated with information about individual users.

4. SURVEYS

We may conduct user surveys from time to time to better target our content to our Website users. We will not share individual responses from these surveys with any third party. We will share aggregate data with third party service providers, partners, and other third parties. We also will post aggregate data containing survey responses on our Website; that data may be viewed and downloaded by other users of our Website.

D. Security

We employ procedural and technological security measures, which are reasonably designed to help protect your personal information from unauthorized access or disclosure. SBNRI may use encryption, passwords, and physical security measures to help protect your personal information against unauthorized access and disclosure. No security measures, however, are 100% complete. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or private communications will not be collected and used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. SBNRI is not responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your account via unauthorized password activity.

E. Disclosure

We may share the information that we collect about you, including your personal information, as follows:

1. INFORMATION DISCLOSED TO PROTECT US AND OTHERS

We may disclose your information including Personal Information if: (i) it is pursuant to Services that you have requested; (ii) SBNRI reasonably believes that disclosure is necessary in order to comply with a legal process (such as a court order, search warrant, etc.) or other legal requirement of any governmental authority, (iii) disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iv) reasonably necessary to enforce this Privacy Policy, our terms and conditions etc. (v) disclosure is intended to help investigate or prevent unauthorized transactions or other illegal activities, or (vi) necessary or appropriate to protect our rights or property, or the rights or property of any person or entity.

2. INFORMATION DISCLOSED TO THIRD PARTY SERVICE PROVIDERS AND BUSINESS PARTNERS

We may contract with various third parties for the provision and maintenance of the Website, Services and our business operations, and SBNRI may need to share your personal information and data generated by cookies and aggregate information (collectively, "information") with these vendors and service agencies. For example, we may provide your information to a credit card processing company to process your payment. The vendors and service agencies will not receive any right to use your personal information beyond what is necessary to perform its obligations to provide the Services to you. If you complete a survey, we also may share your information with the survey provider; if we offer a survey in conjunction with another entity, we also will disclose the results to that entity.

3. INFORMATION DISCLOSED TO LAW ENFORCEMENT OR GOVERNMENT OFFICIALS

We will disclose your information, including, without limitation, your name, city, state, telephone number, email address, user ID history, quoting and listing history, and fraud complaints, to law enforcement or other government officials if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority.

4. IN THE EVENT OF A CHANGE OF CONTROL OR BANKRUPTCY

In the event that SBNRI undergoes a change in control, including, without limitation, a merger or sale of all or substantially all of SBNRI 's assets to which this Website relates or other corporate reorganization in which SBNRI participates, and is thus merged with or acquired by a third party entity (a "Successor"), SBNRI hereby reserves the right to transfer the information we have collected from the users of the Website and/or Services to such Successor.

In addition, in the event of SBNRI 's bankruptcy, reorganization, receivership, or assignment for the benefit of creditors, or the application or laws or equitable principles affecting creditors' rights generally, SBNRI may not be able to control how your information is transferred, used, or treated and reserves the right to transfer the information we have collected from the users of the Website and/or Services to non-affiliated third parties in such event.

5. INFORMATION DISCLOSED AT YOUR REQUEST

We may share your personal information with other users or third parties to whom you explicitly ask us to send your information or if you explicitly consent to such disclosure upon receipt of a specific Service.

F. Links to External Websites

The Website may contain links to other websites or resources over which SBNRI does not have any control. Such links do not constitute an endorsement by SBNRI of those external websites. You acknowledge that SBNRI is providing these links to you only as a convenience, and further agree that SBNRI is not responsible for the content of such external websites. We are not responsible for the protection and privacy of any information which you provide while visiting such external websites and such sites are not governed by this Policy. Your use of any external website is subject to the terms of use and privacy policy located on the linked to external website.

G. Updating, Deleting and Correcting Your Personal Information

You may choose to restrict the collection or use of your personal information in the following ways: You can review, correct and delete your personal information by emailing us at [email protected]. You must promptly reach out to us to change your information if your personal information changes or is inaccurate. Typically, we will not manually alter your personal information because it is very difficult to verify your identity remotely. Nonetheless, upon your request we may close your account and remove your personal information from view as soon as reasonably possible based on your account activity and in accordance with applicable law. We do retain information from closed accounts in order to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations of any user, enforce our terms and conditions, and take any other actions otherwise permitted by law that we deem necessary in our sole and absolute discretion. Once we have deleted or removed your account, you agree that SBNRI shall not be responsible for any personal information that was not included within your deleted and/or removed account that remains on the Website.

H. What Choices Do I Have Regarding Use of My Personal Information?

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

I. Third-Party Ad Networks

We participate in third party ad networks that may display advertisements on other websites based on your visits to our Website as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party's specific privacy policy, and not by SBNRI’s Policy. We may provide these third-party advertisers with information about your usage of our Site and our services, as well as aggregate or non-personally identifiable information about visitors to our Site and users of our service.

J. Use of SBNRI Information

The Website facilitates your sharing of personal information with SBNRI in order to negotiate, provide, and use the Services. If you agree to contract for a service, you may need to reveal your name, email, phone number, or personal address to SBNRI so that the service may be performed.

Your password is the key to your account. When creating your password you should use unique numbers, letters, special characters, and combinations thereof. In addition, DO NOT disclose your password to anyone. If you do share your password or your personal information with others, you are solely responsible for all actions taken via your account. If you lose control of your password, you may lose substantial control over your personal information and be subject to legally binding actions taken on your behalf. Thus, IF YOUR PASSWORD HAS BEEN COMPROMISED FOR ANY REASON, YOU MUST IMMEDIATELY NOTIFY SBNRI TO CHANGE YOUR PASSWORD.

K. User Generated Content

We invite you to post content on our Website, including your comments, feedback, pictures, and any other information that you would like to be available on our Website. If you post content to our Website, all of the information that you post will be available to all visitors to our Website. If you post your own content on our Website or Services, your posting may become public and SBNRI cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

L. Privacy Policy Updates

THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH ABOVE. SBNRI MAY, IN ITS SOLE AND ABSOLUTE DISCRETION, CHANGE THIS POLICY FROM TIME TO TIME BY UPDATING THIS DOCUMENT. SBNRI WILL POST ITS UPDATED POLICY ON THE WEBSITE ON THIS PAGE. SBNRI ENCOURAGES YOU TO REVIEW THIS POLICY REGULARLY FOR ANY CHANGES. YOUR CONTINUED USE OF THIS WEBSITE AND/OR CONTINUED PROVISION OF PERSONAL INFORMATION TO US WILL BE SUBJECT TO THE TERMS OF THE THEN-CURRENT POLICY.

SB NRI