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Privacy Policy

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1. Scope Of Policy

The purpose of this policy is to explain how Call Connect collects, protects and uses personal data in providing the high quality of various services in compliance with Information Technology Act and Rules made there under. The various Data protection and privacy laws of India require us to provide you with certain information applicable to its collection of your and your personal data.

We are committed to ensuring that any personal data supplied by our client partners or otherwise generated by our business activities is collected and processed fairly and lawfully. As the customer data is sensitive and represent an important factor and must be protected against the threats posed by unauthorized access in compliance with applicable laws.

Therefore, we have implemented reasonable security practices and standards and have a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with the information assets being protected with the nature of business.

2. Definitions

(i) ‘Access’ with its grammatical variations and cognate expressions means gaining entry into, instructing or communicating with the logical, arithmetical or memory function resources of a computer, computer system or computer network;

(ii) ‘Act’ means the Information Technology Act, 2000 (21 of 2000);

(iii) ‘Biometrics’ means the technologies that measure and analyse human body characteristics, such as ‘fingerprints’, ‘eye retinas and irises’, ‘voice patterns’, ‘facial patterns’, ‘hand measurements’ and ‘DNA’ for authentication purposes;

(iv) ‘Body Corporate’ means any company and includes a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities;

(v) ‘Communication Device’ means cell phones, personal digital assistance, or combination of both or any other device used to communicate, send or transmit any text, video, audio or image;

(vi) ‘Cyber incidents’ means any real or suspected adverse event in relation to cyber security that violates an explicitly or implicitly applicable security policy resulting in unauthorized access, denial of service or disruption, unauthorised use of a computer resource for processing or storage of information or changes to data, information without authorisation;

(vii) ‘Cyber Security’ means protecting information, equipment, devices, computer, computer resource, communication device and information stored therein from unauthorized access, use, disclosure, disruption, modification or destruction.

(viii) ‘Data’ means a representation of information, knowledge, facts, concepts or instructions which are being prepared or have been prepared in a formalised manner, and is intended to be processed is being processed or has been processed in a computer system or computer network and may be in any form (including computer printouts magnetic or optical storage media, punched cards, punched tapes) or stored internally in the memory of the computer;

(ix) ‘Information’ includes data, message, text, images, sound, voice, codes, computer programmes, software and databases or micro film or computer generated micro fiche;

(x) ‘Intermediary’ with respect to any particular electronic records, means any person who on behalf of another person receives, stores or transmits that record or provides any service with respect to that record and includes telecom service providers, network service providers, internet service providers, web hosting service providers, search enginers, online payment sites, online-auction sites, online market places and cyber cafes,

(xi) ‘Personal information’ means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person;

(xii) ‘Reasonable security practices and procedures’ means security practices and procedures designed to protect such information from unauthorised access, damage, use, modification, disclosure or impairment, as may be specified in an agreement between the parties or as may be specified in any law for the time being in force and in the absence of such agreement or any law, such reasonable security practices and procedures, as may be prescribed by the Central Government in consultation with such professional bodies or associations as it may deem fit.

(xiiii) Sensitive personal data or information – Sensitive personal data or information of a person means such personal information which consists of information relating to:-

(a) Password;
(b) Financial information such as Bank account or credit card or debit card or other payment instrument details ;
(c) Physical, physiological and mental health condition;
(d) Sexual orientation;
(e) Medical records and history;
(f) Biometric information;
(g) Any detail relating to the above clauses as provided to body corporate for providing service; and
(h) Any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise:

Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of these rules.

(xiv) ‘Secure System’ means computer hardware, software and procedure that are:-
(a) Reasonably secure from unauthorised access and misuse;
(b) Provide a reasonable level of reliability and correct operation;
(c) Are reasonably suited to performing the intended functions; and
(d) Adhere to generally accepted security procedures;

(xv) ‘We’, ‘us’, ‘our’ and “Call Connect” refer to the Call Connect India Incorporated.

3. The Information Technology Act, 2000 and Rules

The Information Technology Act, 2000 and rules therein provide for various compliances to be made by us, in specific:

A.) The Information Technology (Intermediaries Guidelines) Rules, 2011.

B.) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

 

A. Intermediaries Guidelines

Section 79 of the Information Technology Act provides for exemption from liability of Intermediaries, if certain conditions are fulfilled and also observes due diligence while discharging his duties under this Act and also observes such other guidelines as the Central Government may prescribe in this behalf.

We act as an Intermediary as per the Indian Law, and therefore observe Due Diligence in discharge of our duties:

i) We have published Privacy policy on our website, in compliance with the Indian Act, while agreement may be entered mutually and accordingly Terms of Contract may be finally decided. Further, said rules do not allows us to host, display, upload, modify, publish, transmit, update or share any information that:

(a) Belongs to another person and to which the user does not have any right to;

(b) Is grossly harmful, harassing, blasphemous defamatory, obscene, pornographic, paedophilic, libellous, invasive of another’s privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever;

(c) Harm minors in any way;

(d) Infringes any patent, trademark, copyright or other proprietary rights;

(e) Violates any law for the time being in force;

(f) Deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;

(g) Impersonate another person;

(h) Contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource;

(i) Threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign states, or public order or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting any other nation.

ii) We strictly follow the provisions of the Act or any other laws for the time being in force and take all reasonable measures to secure the computer resource and information contained therein following the reasonable security practices and procedures as prescribed in the Information Technology (Reasonable security practices and procedures and sensitive personal Information) Rules, 2011.

iii) We never deploy or install or modify the technical configuration of computer resource or become party to any such act which may change or has the potential to change the normal course of operation of the computer resource than what it is supposed to perform thereby circumventing any law for the time being in force.

iv) We report cyber security incidents and also share cyber security incidents related information with the Indian Computer Emergency Response Team (CERT-IN). Also, when required by lawful order, we shall also provide information or any such assistance to Government Agencies who are lawfully authorised for investigative, protective, cyber security activity.

v) We have further designated the following person in terms of the Rules, as a Grievance Officer, whose details along with the procedure has also been published upon the website:

Jayender Singh
Legal Counsel
Call Connect India Incorporated

 

B. Reasonable security practices and procedures and sensitive personal data or information

Section 43A of Information Technology Act, lays down for penalty for a Body Corporate, who may be negligent in implementing and maintaining reasonable security practices and procedures and thereby causes wrongful loss or wrongful gain to any person.

Further, the term ‘Reasonable Security Practices and Procedures’ has been defined to mean security practices and procedures designed to protect such information from unauthorised access, damage, use, modification, disclosure or impairment, as may be specified in an agreement between the parties or as may be specified in any law for the time being in force and in the absence of such agreement or any law, such reasonable security practices and procedures, as may be prescribed by the Central Government in consultation with such professional bodies or associations as it may deem fit.

Therefore, in terms of the above provision, Central Government has laid down Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011, which are complied with by Call Connect India as follows:

a) We have implemented necessary reasonable security practices and standards. Further, take very cautious approach as to handling of our client/partner Sensitive Data/ Information.

b) We have provided a compliant Privacy Policy for handling of or dealing in personal information and the same is made available over at Call Connect India website at www.callconnectindia.com to be viewable by the provider of the information and it provides for the following

(i) Clear and easily accessible statements of its practices and policies;
(ii) Type of personal or sensitive personal data or information collected;
(iii) Purpose of collection and usage of such information;
(iv) Disclosure of information including sensitive personal data or information;
(v) Reasonable security practices and procedures;

c) Whenever you provide us with Personal/Sensitive information, we may obtain your consent in writing, which may be through Letter, Email or Fax. The sensitive information is defined to mean such personal information which consists of information relating to:

(a) Password;
(b) Financial information such as Bank account or credit card or debit card or other payment instrument details ;
(c) Physical, physiological and mental health condition;
(d) Sexual orientation;
(e) Medical records and history;
(f) Biometric information;
(g) Any detail relating to the above clauses as provided to body corporate for providing service; and
(h) Any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise:

d) We also make sure that the information collected is for a lawful purpose and is necessary for discharging of proper services and is not retained longer than the same is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.

e) It is further made sure that the information collected shall be used for the purpose for which it has been collected and our partner or client’s will be allowed permission to review the information they had provided and ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible.

f) We never disclose such information to a third party, unless such disclosure has been agreed to in the contract between the body corporate and provider of information, or where the disclosure is necessary for compliance of a legal obligation. And the said third parties will have no right to disclose the said information further.

g) We may disclose the information on obtaining a request from any Government Agency, which may be required for the verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences. Further, it may be disclosed to any third party by any order under the law for the time being in force.

h) We or any person on our behalf shall never publish the said sensitive personal data or information.

 

4. Privacy Policy (printed on the website)

This policy covers how we treat personal information collected and received, including information about you that is personally identifiable but is not otherwise publicly available.

a) We collect personal information when you use our services, which information includes name, address, phone number, financial information or any information required by us to collect under the term of agreement with our client, i.e. the information that you provide us at the time of registering with us or any further data or information belonging to third persons shared with us under a lawful contract, which may be for processing of data or rendering call center services.

b) Further, we may collect information by your use of our services, which includes statistics on our server logs from your browser, including IP address. Further information like Device information, Location information, and Cookies and anonymous identifiers may be used to identify you or your device.

c) We use the basic personal information for the general purposes of fulfilling your requests for products and services, improve our services, conduct research, or send emails containing advertisements/ newsletters/ notifications or otherwise contact you.

d) Further, the data or information provided under lawful contract would be processed within the terms of the contract/agreement and in strict compliance with the Indian Laws and International standards.

e) We shall not rent, sell, or share personal information about you with third parties, except when we have specifically obtained your consent at the time of collection of the information and / or to provide products or services you’ve requested, or under the following circumstances:

1. We respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;

2. We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of User Agreement, or as otherwise required by law;

3. We transfer information about you if our site is acquired by or merged with another company. In this event, we will notify you before information about you are transferred and becomes subject to a different privacy policy;

f) Finally, we never use or share the personally identifiable information provided to us online, in ways or for reasons unrelated to the ones described above.

g) We reserve the right to send you certain communications relating to our services or even sponsored messages, such as service announcements, administrative messages and the Newsletter.

h) Personal information about users that is maintained on our systems is protected using industry standard security measures. We have physical, electronic, and procedural safeguards to protect personal information about our users. However, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure and transmission of information over the Internet is susceptible to possible loss, misrouting, interception and misuse.

i) You may also request that we may delete your Personal Information from system and records, after you cease to avail of our services. However, due to technical constraints and the fact that we backs up our systems, Personal Information may continue to reside in our systems after deletion for some limited time but will be deleted within 72 hours.

j) The personal information is collected and retained by Call Connect Incorporated at its New Delhi Office, whose address is Plot No 82, Sector 12A, Dwarka, New Delhi – 110075.

k) We respect the private lives of users. However, in view of the fact that data is collected in order to assist Call Connect in fulfilling its business activities, the user’s right to privacy may sometime be limited due to the fact the equipment, systems and files intended for work-related matters must be accessible at any time to members of administration, substitute employees or the network administrator.

l) We may update this policy from time to time. We may notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified at the time of registration with us or by placing a notice on our website www.callconnectindia.com.