Privacy Policy This privacy statement applies to your use of any productsd servicesd contentd featuresd technologiesd or functionsd and all related websitesd mobile appsd mobile sites or other online platform or applications offered to you by us (collectively the dServices/Platformd)d We collectd used and share personal information to help the Adgeen and its affiliate websites work and to keep it safe (details below)d Adgeen India Private Limitedd acting itself and through its subsidiariesd is the data controller of your personal information collectedd This policy is effective 16/02/2021d Information posted on Adgeen is obviously publicly availabled Our servers are located in Mumbaid Indiad Therefored if you choose to provide us with personal informationd you are consenting to the transfer and storage of that information on our serversd 1d What data do we collect about you? 1d1d Data provided through direct interactions 1d1d1d Registration and other account information When you register to use our Servicesd we may collect the following information about you: If you register using your Google account: first named last name and email addressd If you register using your Facebook account: we collect first name and last name as appeared on your Facebook accountd Facebook IDs and the URL to your Facebook profile pictured In the event you have provided permission to Facebook through their in-app privacy option (which appears just before you register on our Platform)d we may collect your genderd age or email id depending on the permissions granted by youd If you register using your Truecaller accountd we collect first named last named email address and your mobile number If you register using your mobile number we collect your mobile numberd If you register using your email id we collect your email id If you register using your Apple ID: your first and last name and email addressd you can decide whether to share your email address with us when you sign in your Apple accountd We also collect your primary email id used to download the application from the app store Depending on the choices you make during the log-in to our Services or during the process of engaging our Servicesd you may opt to give the following additional personal data: Your Name E-mail Address Mobile number Your credit card/debit card details in case you choose to purchase our paid services 1d1d2d Validation of your account We validate the accounts of Adgeen users by using SMS verification to ensure that each account is associated with a real and unique userd This validation process is initiated once you proceed with posting an ad listing d take an action on an ad listing or initiate a purchased In order to validate your accountd we will send you an SMS on a valid mobile number provided by youd This process is entirely free of charged If you do not agree to validate your accountd then your account will remain active and you will be able to use our Services with limited functionalityd This limited functionality of an account implies that you cannot publish new ad listings or editd updated promoted extendd reactivated deactivate or delete existing ad listings until your account is verified by SMSd You will also not be able to receive or reply to any messages from other usersd In case you create several accounts using the same mobile number and validate all those accounts via SMS verificationd all such accounts will have a limited functionality and you will be asked to choose one of themd The account chosen by you will return to full functionalityd and the rest of the accounts will remain to have limited functionalityd Once you have validated your accountd it will remain associated with the mobile number used for the SMS verificationd If you wish to change the mobile number associated with your accountd you will need to contact our Customer Support teamd 1d1d3d Communication through the chat feature on our Platform When you use our chat feature to communicate with other usersd we collect information that you choose to provide to other users through this featured 1d2d Data we collect automatically when you use of our Services When you interact with our Servicesd we automatically collect the following information about you: We collect device-specific information such as operating system versiond unique identifiersd IMEI numberd and standard web log informationd For exampled the name of the mobile network that you are usingd We associate the device identifiers with your accountd 1d2d1 Device Information We may require access to other apps installed on the deviced to enhance your experienced You may choose not to grant access to such appsd which will allow you access to use our servicesd but with limited functionality 1d2d2d Location information Depending on your device permissionsd if you post an item on our Platformd we automatically collect and process information about your actual locationd We use various technologies to determine locationd including IP addressd GPSd Wi-Fi access points and mobile towersd Your location data allows you to see user items near you and helps you in posting items within your locationd In case we need your location datad we will first show you a pop-up which will ask you to choose to allow or not to allow us to access your location datad If you do not allow us to have access to your location datad you will still be able to use our Services but with limited functionalityd If you do allow us to access your location data you can always change this later by going to the settings on our Website or App our Platform and disable the permissions related to location sharingd 1d2d3d Client and Log data Technical detailsd including the Internet Protocol (IP) address of your deviced time zone and operating systemd We will also store your login information (registration dated date of last password changed date of the last successful login)d type and version of your browserd 1d2d4d Clickstream data We collect information about your activity on our Platformd which includes 1d2d4d1d The sites from which you accessed our Platformd date and time stamp of each visitd searches you have performedd listings or advertisement banners you clickedd your interaction with such advertisements or listingsd duration of your visit and the order in which you visit the content on our Platformd 1d2d4d2d Computer sign-on datad statistics on page viewsd traffic to and from Adgeen and Ad data (all through cookies – you can take steps to disable the cookies on your browser although this is likely to affect your ability to use the site)d Google advertising Id on Android App which is a uniqued user-resettable ID for advertisingd provided by Google Play services 1d2d5d Cookies and Similar Technologies We use cookies to manage our users’ sessionsd to store your preference language selection and deliver you relevant advertisementsd dCookiesd are small text files transferred from a web server to the hard drive of your deviced Cookies may be used to collect the date and time of your visitd your browsing historyd your preferencesd and your usernamed You can set your browser to refuse all or some cookiesd or to alert you when websites set or access cookiesd If you disable or refuse cookiesd please note that some parts of our Services/Platform may become inaccessible or not function properly 2d Why do we process your personal information? We will only use your personal data when the law allows us tod Most commonlyd we will use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with youd Where it is necessary for our legitimate interests to improve our Services and to provide you a safe and secure Platformd Where we need to comply with a legal or regulatory obligationd In certain circumstancesd we may also process your personal data based on your consentd If we do thisd we will let you know the purpose and the category of personal data to be processed at the time we seek your consentd We have set out below a description of the reasons for which we use your personal datad [and which of the legal bases we rely on to do sod We have also identified what our legitimate interests ared where appropriate]d 2d1d For providing access and delivering Services through our Platform 2d1d1d If you log in using your mobile number or email idd we use your first name and last named mobile number and/or e-mail address to identify you as a user and provide access to our Platformd 2d1d2d If you log in using your Facebook account or Google account or your Apple ID or your Truecaller accountd we use your first name and last name and your email address of such accountd as well as the URL to your profile picture (except for Apple ID and Truecaller) we use your first name and last name from your Facebook profile and the Facebook e-mail address to identify you as a user on our Platform and to provide you access to our Platformd 2d1d3d We use third party payment service providers to process any payment you make to our Servicesd Depending on the method of paymentd you may be requested to provide us with your payment and credit card details which we will then provide to the payment service provider in order to process your paymentd We do not store your credit card informationd unless you choose the option to save such information in order to make recurring payments easier without having to re-enter your details each timed In such casesd we only store your card holder named the card expiry dated your card type and the last four digits of the card numberd We do not store any credit card code verification values and merely forward such values and your credit card number in an encrypted manner for the purpose of processing your payment by our payment service providerd We process the above information for adequate performance of our contract with youd 2d2d For improving your experience on the Platform and developing new functionalities of the Platform 2d2d1d We use clickstream data to: Offer you tailored contentd such as giving you more relevant search results when using our Servicesd To determine how much time you spend on our Platform and in what manner you navigate through our Platform in order to understand your interests and to improve our Services based on this datad For exampled we may provide you with suggestions on content that you can visit based on the contents you have clickedd To communicate marketing and promotional offersd to monitor and report the effectiveness of the campaign delivery to our business partners and internal business analysisd 2d2d2d If you choose to provide us with your location datad we use your location data for following purposes: To compile anonymous and aggregated information about the characteristics and behavior of usersd including for the purposes of business analysisd segmentation and development of anonymous profilesd To enhance the performance of our Services and to personalize the content we direct towards youd For example - with the help of location data we display ad listings which are in your vicinity to improve your buying experienced For this purposed Google Maps is integrated into our Platformd This means that both Google and we are responsible for the processing of your location data in the context of Google Mapsd In any cased we will not process your location data for any other purposes but those explained in this Privacy Statementd Howeverd Google might process such location data for their own purposes as explained in the Google Privacy Policy which can be reviewed Your use of Google Maps through our Platform is subject to Google Maps’ Terms of Serviced To measure and monitor your interaction with the third-party advertisement bannersd we place on our Platformd 2d2d3d With the help of your account informationd which includes your email ID and phone numberd we map the different devices (such as desktopd mobiled tablets) used by you to access our Platformd This allows us to associate your activity on our Platform across devices and helps us in providing you a seamless experience no matter which device you used 2d2d4d We use the images you uploadd the descriptions and prices you provide in your ad listings to train machine learning models to personalize search results in relation to ad ranking and user interestd to improve the identification and presentation of ad listingsd to improve the search function and to increase the likelihood of a successful saled This helps us to improve our Services and to provide you with a better user experienced 2d2d5d To show and recommend ad listings on our Services that may be of interest to youd we make use of algorithms that use information related to your browsing behaviord items you boughtd clickstream datad your user ID and your location data if you have given us permission to use thisd We use this form of automated decision-making on the basis of our legitimate interest in improving our Services and provide a better user experience by offering you more relevant ad listingsd 2d2d6d We access and analyze your chat messages with other users conducted through the chat function on our Platformd for product enhancement and to provide you with a better user experience (edgd to identify sold items and to provide you with active listings only)d Therefored we develop and train machine learning models and algorithms to automatically analyze your chat contentd To build and train our machine learning models our machine learning specialists may review exemplary chat content manuallyd In these circumstances highly restricted access rights apply to selected machine learning specialists analyzing the chat contentd During this processd we are de-identifying chat content as much as possible by applying a scanning filter to detect and hide personal data such as namesd phone numbersd e-mail addressesd Howeverd there may still be cases beyond our control in which the chat content may show certain personal data that you have chosen to provided We process the above information for adequate performance of our contract with you and on the basis of our legitimate interest to improve your experience of our Servicesd 2d3d To take your feedbackd promote and offer you Services that may be of your interest 2d3d1d We use your mobile numberd log data and unique device identifiers to administer and protect our Platform (including troubleshootingd data analysisd testingd fraud preventiond system maintenanced supportd reporting and hosting of data)d 2d3d2d We access and analyze your chat messages with other users conducted through the chat function on our Services for customer satisfactiond safety and for fraud prevention purposes (edgd to block spam or abusive messages that may have been sent to you by other users)d Therefored we develop and train machine learning models and algorithms helping us to automatically detect and prevent inappropriate and fraudulent user behaviord During the analyzation and training processd we are de-identifying chat content as much as possible by anonymizing the unique identification values assigned to usersd Howeverd there may still be cases beyond our control in which the chat content may show certain personal data that you have chosen to provided Only in limited cases and circumstancesd our customer safety and security specialists review chat content manuallyd for exampled if we have strong indications leading to the urgent suspicion of fraudulent activitiesd In these circumstances highly restrictive access rights apply to selected customer safety and security specialists analyzing the chat contentd 2d3d3d To resolve disputesd prevent and detect fraud on our Servicesd we make use of algorithms that recognize suspicious or fraudulent user behavior based on certain information such as user activity and posted contentd which may lead to us banning certain user accountsd Automated banning happens when there is a very high degree of certainty that an account or action is fraudulentd Otherwise human review takes place by selecting customer safety and security specialists on the basis of highly restrictive access rightsd We use this form of automated decision-making on the basis of our legitimate interest to detect and prevent fraud and to keep our Services safe and secure for our usersd If you think that your account was wrongfully bannedd you can contact our Customer Support teamd in which case our team will review the decision to ban your accountd 2d3d4d We collect certain information from and in relation to the electronic device from which you are accessing our Services on the basis of our legitimate interest in preventing fraud on our Servicesd The information we collect includes your user ID (depending on whether you are logged in)d country domaind IP addressd device language settingsd device brand and typed device operating system and versiond browser type and versiond and device specific software information such as fontsd system and browser Time zoned available video and audio formatsd The device related information is used to determine whether the same device is being used when users interact with our Servicesd We associate such information with a user fraud score on the basis of which we may ban certain usersd If you think that your account was wrongfully bannedd you can contact us through our customer support helpline in which case our team will review the decision to ban your accountd 2d4d To take your feedbackd promote and offer you Services that may be of your interest 2d4d1d We may contact you through your registered mobile number or email id in order to take feedback from you about our Servicesd 2d4d2d We use your email address and mobile number (by SMS) to make suggestions and recommendations to you about our Services that may be of interest to youd 2d4d3d We use clickstream data to monitor and report the effectiveness of the campaign delivery to our business partners and internal business analysisd 2d4d4d If you choose to provide us with your location datad we may use your location data to measure and monitor your interaction with the third-party advertisement banners we place on our Servicesd We process the above information based on our legitimate interest in undertaking marketing activities to offer you Services that may be of your interestd Specificallyd you may receive certain marketing communications from us: By any preferred means of communication if you have requested such information from usd By email or phoned regarding similar products and servicesd if you already use our Services or acquired some of our productsd By phone or emaild if you provided us with your details when you entered a competitiond By phone or email if you registered for a promotiond By phone or emaild if you have provided your feedback for our Services through our Platformd social mediad or any other meansd Being a registered user on our Platformd please note that if you have registered yourself on DND/DNC/NCPR servicesd you will still receive the above communicationsd You can ask us to stop sending you such marketing communication at any time by clicking on the opt-out link in the email sent to you or by changing your notification settings in your account or by stating our calling agent that you do not wish to be contacted for the above marketing communicationsd You agree to receive an email atleast once a year informing you that in case of non-compliance with the Information Technology (Intermediaries Guidelines) Rulesd 2011d these termsd policiesd Adgeen has the right to terminate access or usage rights of users immediately or remove non-compliant informationd or bothd 3d How will we inform you about changes in our privacy statement? Generald We may updated upgraded modify (partially &/or fully) this policy at any timed with updates taking effect when you next post or after 30 daysd whichever is soonerd If we or our corporate affiliates are involved in a merger or acquisitiond we may share personal information with another companyd but this policy will continue to applyd Send questions about this policy to [email protected] You will also receive an e-mail once a year notifying you of any change to this Policyd 4d Communication We will communicate with you by emaild SMS or in the app notification in connection with our Services/Platform to confirm your registrationd to inform you in case your ad listing has become live/expired and other transactional messages in relation to our Servicesd As it is imperative for us to provide you such transactional messages you may not be able to opt -out of such messagesd 5d Who do we share your data with? We may have to share your personal data with the parties set out below for the purposes set out in section 2 aboved 5d1d Corporate affiliates: We may share your data with our group companiesd which are located within as well as outside India and help us in providing business operation services such as product enhancementsd customer support and fraud detection mechanism who help detect or prevent potentially illegal acts and provide joint services (Our corporate affiliates will market only to users who ask them to) 5d2d Third Party Service Providers: We use third party service providers to help us deliver certain aspect of our Services for exampled cloud storage facilitiesd We conduct checks on our third-party service providers and require them to respect the security of your personal data and to treat it in accordance with the lawd We do not allow them to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructionsd 5d3d Advertising and analytics providers: In order to improve our Servicesd we will sometimes share your non-identifiable information with analytics providers that help us analyze how people are using our Platform/Serviced Wed share your information with them in non-identifiable form for monitoring and reporting the effectiveness of the campaign delivery to our business partners and for internal business analysisd 5d5d Law enforcement authoritiesd regulators and others: We may disclose your personal data to law enforcement authoritiesd regulatorsd governmental or public bodies and other relevant third parties comply with any legal or regulatory requirementsd We also reserve the right to make use of the personal information in any investigation or judicial process relating to fraud on account of such transactions during the period Adgeen retains such informationd We may also disclose personal information to enforce our policiesd respond to claims that a posting or other content violates other’s rightsd or protects anyone’s rightsd property or safetyd We may choose to selld transferd or merge parts of our business or our assetsd Alternativelyd we may seek to acquire other businesses or merge with themd If a change happens to our businessd then the new owners may use your personal data in the same way as set out in this privacy statementd 5d7d Accessd Modificationd and Deletion - You can seed modify or erase your personal information by reviewing your posting or account status paged Contact customer support at [email protected] to review any personal information we store that is not available on Adgeend There may be a charge associated with such requests but these will not exceed the amounts permitted by lawd 6d Where do we store your data and for how long? The data we collect about you will be stored and processed in secure servers in order to provide the best possible user experienced For example – for fast website or mobile application build upd We will only retain your personal data for as long as necessary to fulfil the purposes we collected it ford including for the purposes of satisfying any legald accountingd or reporting requirementsd We delete personal information when we no longer need it for the purposes we described earlierd We retain personal information as permitted by law to resolve disputesd enforce our policiesd and prevent bad guys from coming backd To determine the appropriate retention period for personal datad we consider the amountd natured and sensitivity of the personal datad the potential risk of harm from unauthorized use or disclosure of your personal datad the purposes for which we process your personal data and whether we can achieve those purposes through other meansd and the applicable legal requirementsd In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rulesd 2021d we shall retain your information for a period of 180 days or a longer period if required by the court or authorised government agencies after withdrawal or cancellation of your registrationd 7d Technical and organizational measures and processing security All the information we receive about you are stored on secure servers and we have implemented technical and organizational measures that are suitable and necessary to protect your personal data (encryptiond passwordsd physical security))d in accordance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information Rules)d 2011d Adgeen continually evaluates the security of its network and adequacy of its internal information security programd which is designed to (a) help secure your data against accidental or unlawful lossd access or disclosured (b) identify reasonably foreseeable risks to the security of the networkd and (c) minimize security risksd including through risk assessment and regular testingd In additiond we ensure that all payment data are encrypted using SSL technologyd Unfortunatelyd no data transmission over the internet can be guaranteed to be completely secured So while we strive to protect such informationd we cannot ensure or warrant the security of any information you transmit to us and you do so at your own riskd Once any personal information comes into our possessiond we will take reasonable steps to protect that information from misuse and loss and from unauthorised accessd modification or disclosure 8d Links to third-party websites Our Platform may contain links to third party websites or appsd If you click on one of these linksd please note that each one will have its own privacy policyd We do not control these websites/apps and are not responsible for those policiesd When you leave our Platformd we encourage you to read the privacy notice of every website you visitd If you have any queries relating to the processing/ usage of information provided by you or Adgeends Privacy Policyd you may email at mail id or write to us at [email protected] For Users residing in any other part of world: Legal Departmentd Adgeen India Private Limitedd Nod 106d SRK Nagar Postd Krishnarajpuram Hoblid Thanisandra Main Roadd Bangalore- 560045 Contact address