Anaxee Privacy Policy

1. Background

1.1. www.anaxee.com (“Website”) and the mobile apps, web interfaces, APIs, documentation, servers and all other Intellectual Property, software, products under the brand name Anaxee and infrastructure (collectively referred to as “Anaxee Product” are owned, Anaxee Digital Runners Private Limited (“Company”), a Company, incorporated under the laws of the India and having its corporate office at 74, Dhar Kothi Flat 104, Akta Apartment, Indore, Madhya Pradesh – 452001.

1.2. This Privacy Policy covers:
(i) the type of information collected from the users through the Website, the Anaxee Products, including sensitive Personal Data or information;
(ii) the purpose, means and modes of usage of such information; and (iii) how and to whom such information which has been collected will be disclosed.

1.3. For the purpose of this Privacy Policy, wherever the context so requires the term “administrator”, “customer” shall mean any user using the Anaxee Product or providing information to the employee, runner, consultant, etc. (“Digital Runner”), of the Company. “User” shall mean any natural person who has been invited to use and provide information to Anaxee Product either by themselves or through the Digital Runner by an administrator or customer. The term “We”, “Us”, “Our” shall mean the Company, its employees, Digital Runner, and authorised agents that perform any services on the Company’s behalf.
1.4. This privacy policy primarily covers administrators/customers.
1.5. We reserve the right to make changes to this Privacy Policy at any time. Any such modifications will become effective immediately upon posting to the Website or the Anaxee Product and continued use of the Anaxee Product constitutes agreement to such modifications. You agree to periodically review the current version of the Privacy Policy as posted on the Website. We will notify you of material changes in advance by email or by notice when you log in to the Website and services or both.

For the purposes of this Policy, the key terms are defined as follows:
1. ‘Personal Data’ means any information relating to User or identifiable to User; an identifiable to User is one who can be identified, directly or indirectly, in particular by reference to User such as name, an identification number, government identification numbers, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. ‘Processing’ means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
3. ‘Controller’ means the Company, or administrator. The administrator is the controller for all information related to the customer and the Users invited to Anaxee by them. The Company is the controller for all the information related to the administrators themselves;
4. ‘Processor’ means a Company or third parties engaged by the Company. The Company is a processor for all data entered into Anaxee by Users.
5. ‘Recipient’ means a Company or any legal person, public authority, agency or another body, to which the Personal Data are disclosed, whether a third party or not.
6. ‘Third party’ means a natural or legal person, public authority, agency or body other than the User, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process Personal Data;
7. ‘Consent’ of the User means any freely given, specific, informed and unambiguous indication of the User’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her;
8. ‘Personal Data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed;
9. ‘Sensitive data’ refers to the various categories of Personal Data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from User. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual orientation, or criminal convictions and offences (including information about suspected criminal activities).

2. Information collected from the Administrator/User(s)

2.1. Company protects Personal Data in accordance with applicable laws and our data privacy policies. In addition, Company maintains the appropriate technical and organizational measures to protect Personal Data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto. We collect information directly from administrator, as well as automatically through use of our Website, services through the Anaxee Products and, in some cases, from third parties.
2.1.1. Information That Our Customers Give is:
1. First and last name;
2. Email address(es);
3. Physical Address;
4. Mobile and other phone number(s);
5. Date of birth;
6. Location;
7. Contacts;
8. User Profile photos that you upload
9. Organization information;
10. Preferences;
11. Any other required account or other information requested by Digital Runners.

2.1.2. Information Collected Automatically: When User use or interact with our Website directly and services through our Digital Runner or Anaxee Product, we receive and store information generated by activity, like Usage Data, and other information automatically collected from browser or mobile device. This information may include IP address; browser type and version; preferred language; geographic location using IP address, wireless, or Bluetooth technology on device; operating system and computer platform; the full Uniform Resource Locator (URL) clickstream to, though, and from our Website, including date and time. We also may log the length of time of visit and the number of times User visit and use the services. We may assign User one or more unique identifiers to help keep track of future visits.

2.1.3. Information from Other Sources: If we receive any information about User from other sources, we may add it to the information we already have about User.

2.1.4. Information from our website visitors: Our website visitors contact us for more information or request for product demos. For this purpose, we generally request for name, email, Company name and contact number.

2.2. Sensitive Data: We do not generally seek to collect Sensitive Data (also known as special categories) through this Website or otherwise. Administrator may seek this information and User should ensure User obtain administrator’s privacy policy prior to sharing Sensitive Data via Website, Anaxee Product or Digital Runner.

3. How the collected information will be used

3.1. Lawful Basis of processing
We process your Personal Data only when we have a lawful basis. Presently, we use the performance of contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the data protection regulations.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

3.2. Use of Customer Data – We only process customer data on behalf of our customers and in accordance with their instructions provided in the applicable Services agreement with us. We use the data that we have about you to provide our services and provide support to you.
The information collected by Us when customers use the Website and services, shall be used in the manner described below:
1. Facilitate use of the Anaxee Product, its upgrades, its replacements and to maintain the Anaxee Product.
2. Contact and communicate with Customers and Users with respect to Anaxee Product;
3. Provide technical service and support, including updates;
4. Respond to legal requirements, exercise our legal rights or defend against legal claims, to protect our interests, fight fraud or illegal activity, to enforce our policies, or to protect third party rights, property, or safety.
5. Customize and/or tailor the Anaxee Product and user experience, which may include displaying information based on their search or content from other users.
6. Troubleshooting
7. Responding to our customer on queries and support issues
Responding to our Customer’s end users on queries and support issues
As part of our contractual agreements with our customers, we also provide their end users with support on queries and technical support. In doing so, we act as processors for our customers and any data collected from such end users is collected on behalf of our customers.

3.3. Consent
1. When you give your consent to us for contacting you for marketing purposes by signing up for our blog, demo of Anaxee Products, providing any information to our Digital Runners or during an event that you attend.

2. By accepting this agreement, the user confirms that they have read, understood, and agreed to be bound by its terms and conditions regarding the sending of promotional messages on WhatsApp.

3.4. Users under 16 years of age
The Sites and Digital Runners do not knowingly collect personal information from Users under the age of 16. If you are under the age of 16, you are not permitted to use the Sites and services except maybe as an end user of our customers in accordance with their privacy policy.

4. Disclosure of Personal Information

The following categories of recipients will most likely receive your data in order for us to provide services to you
• Third Party Data Center Services such as AWS, etc.
• Third Party SMTP Services such as Sendgrid, etc.
• Third Party helpdesk applications/tools for troubleshooting
• Third party service providers
• Customers as per our service agreement with them.
Information Sharing and Disclosure

The Company does not sell or rent personal information to third parties. The Company will not disclose your personal information to a third party without your permission, except in connection with performing your background screening, data and document collection, for the Company’s customer or as otherwise described in this Privacy Policy.

When the Company conducts a background screening, data and Document collection, investigation about you, The Company may disclose information that you submit through this web site to the Company’s customer that ordered a background screening, data and Document collection investigation on you. The Company also may disclose your information to certain third parties as necessary to conduct the background investigation (such as educational institutions, prior employers, courts, law enforcement agencies and other persons or entities that may provide or verify information about you), as well as to a third-party representative or subcontractor authorized by the Company to assist in the background screening investigation. These third-party representatives and subcontractors include service providers that help host or support the web site or otherwise provide technical assistance, court researchers and other data and service vendors. The Company transfers to these representatives and subcontractors only the personal information they need to deliver to the Company (for the benefit of the Company’s customer) the requested product or service. The Company prohibits these third parties from using that information for any other purpose. The Company requires that these parties maintain commercially reasonable measures to protect the confidentiality of your information.

The Company also may in good faith disclose personal information and any other additional information available to the Company for any of the following purposes: (i) investigate, prevent or take action regarding actual or suspected illegal activities or fraud, situations involving potential threats to the physical safety of any person, or violations of the Company’s policies; (ii) respond to or defend against subpoenas, court orders, or other legal process; (iii) establish or exercise the Company’s legal rights; or (iv) otherwise comply with applicable law.
The Company may acquire other businesses, and other businesses may acquire the Company. If that occurs, the information The Company collects may be one of the assets examined or transferred as part of the transaction. The Company will not permit another business to examine the information The Company has collected without a confidentiality agreement and only to the extent permitted by law. The Company will not transfer the information it has collected unless the recipient agrees to provide privacy protections equal to or exceeding those established by this Privacy Policy.

5. User’s Rights with respect to Processing Personal Data

Users are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
• Request access to the Personal Data: This right entitles customers to know whether we hold Personal Data about them and, if we do, to obtain information on and a copy of that Personal Data.
• Request a rectification of Personal Data: This right entitles customers to have Personal Data be corrected if it is inaccurate or incomplete.
• Object to the Processing of Personal Data: This right entitles User to request that Company no longer Processes Personal Data.
• Request the erasure of Personal Data: This right entitles User to request the erasure of Personal Data, including where such Personal Data would no longer be necessary to achieve the purposes.
• Request the restriction of the processing of Personal Data: This right entitles User to request that Company only processes Personal Data in limited circumstances, including with consent.
• Request portability of Personal Data: This right entitles User to receive a copy (in a structured, commonly used and machine-readable format) of Personal Data that administrators have provided to Company, or request Company to transmit such Personal Data to another data controller.

As a User, you would need to submit a request via your administrator to request for deletion, opt-out or to receive a copy of your data.
To the extent that the processing of Personal Data is based on Consent, Users have the right to withdraw such Consent at any time by contacting Company’s Data Privacy Officer. Please note that this will not affect Company’s right to process Personal Data obtained prior to the withdrawal of consent, or its right to continue parts of the processing based on other legal basis other than consent.

7. Cookies

7.1. The Anaxee Product uses cookies, which are files that web browser puts on system when User visit a website, to store certain information that is not sensitive personal information. The information collected through these cookies is used by us for the technical administration of the Company’s research and development, and to improve the quality of our services.
7.2. We may use third party cookies to track visitor behaviour and to improve the quality of our services. However, such cookies will not store any kind of personal information, nor will such information be disclosed to any third party.
7.3. These cookies are intended to be automatically cleared or deleted when the User quits the browser application. User are encouraged to use the “clear cookies” functionality of browser to ensure such clearing / deletion, since it is impossible for us to guarantee, predict or provide for the behaviour of system. User have a variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. Users browser and other choices may impact experiences with our products.
7.4. The information we collect with cookies is not sold, rented, or shared with any third parties, other than for internal development and maintenance of the Anaxee Product and to retarget and remarket Anaxee Product and our partner products to User.

8. Third Party Links

8.1. We may provide links to websites for the convenience and information of users. These websites may not be owned, controlled, or operated by us. In those cases, we cannot control how information collected by those websites will be used, shared, or secured. If the user visits linked sites, we strongly recommend that the user reviews the privacy notices or policies posted at those sites. We are not responsible for the content of linked sites, the User’s use of them, or the information practices of their operators.
8.2. Anaxee Products are intended for use by organizations and are administered to User by our customers organization. Use of Anaxee Product is subject to the user organization’s policies, if any. When User use social features of Anaxee, other users in network may see some of activity. Company is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy policy.

9. Data Security Procedures

9.1. We maintain organizational, physical and technical security arrangements for all the Personal Data we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of Personal Data and the processing we undertake to protect any kind of personal sensitive information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.
We adopt market leading security measures to protect Personal Data.
9.2. Regarding use of our Websites, User should understand that the open nature of the internet is such that information and Personal Data flows over networks connecting User to our systems without security measures and may be accessed and used by people other than those for whom the data are intended.

10. Retention of Information

10.1. We will retain Personal Data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that Personal Data are deleted after a reasonable time according to the following retention criteria:
• We retain Data as long as we have an ongoing relationship with our customer. Once our customers choose to close their accounts, the information is deleted within 30 days of such closure. When you decide to close your account, we delete all personal information about you including any user generated content.
• We will only keep the data while account is active or for as long as needed to provide services.
• We retain data for as long as needed in order to comply with our legal and contractual obligations.

11. Choice/Opt-Out

11.1. If the User wishes to opt- out of receiving non-essential (promotional, marketing-related) communications from us, after setting up an account, they may choose to do so by making such preference changes within the application or contacting us at support@anaxee.com

12. Governing Law

12.1. This Privacy Policy shall be governed by and constructed in accordance with the laws of India, without reference to conflict of laws principles. The courts in Indore, India, shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, these Privacy Policy. User agree to submit to the jurisdiction of the courts in Indore, India, and agree to waive any and all objections to the exercise of jurisdiction over the parties by such courts and to venue in such courts.

13. Contact

You may contact us at our mailing address below:
Anaxee Digital Runners Private Limited
301,3rd Floor, Satyaraj complex, 18-PU3,A.B.Road, Indore, 452010, M.P.
Please write to us at support@anaxee.com if:
• Customers and visitors have a general question about how Company protects Personal Data.
• Customers and visitors wish to exercise rights in relation to Personal Data rights.
• Customers and visitors wish to make a complaint about Company’s use of data.
You can contact our Data Privacy Officer at support@anaxee.com.
If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If, despite our commitment and efforts to protect Personal Data, you believe that your data privacy rights have been violated, we encourage and welcome Users to come to the Company first to seek resolution of any complaint.