PRIVACY POLICY

This document explains how Smith & Arner Facility Services Private Limited (SAFSPL) collects, processes, stores, and/or shares any Personal Information (as defined below) and/or other information from or about the Users. WE VALUE OUR USERS’ PRIVACY AND SO WE HAVE PREPARED THIS PRIVACY POLICY DOCUMENT TO DEMONSTRATE THIS. By accessing and/or using the Platform, you consent to the collection, storage, disclosure, and other uses of your information per this Privacy Policy. As mentioned in the General Terms set out hereinabove, you must be at least of legal age to access the Platform and/or use the Services. PLEASE CAREFULLY READ THIS DOCUMENT BEFORE SUBMITTING ANY INFORMATION ON THE PLATFORM. We may update this statement from time to time by publishing a revised version on the Platform per the Privacy Policy. Please check this Privacy Policy document each time before you share Personal Information with us. SAFSPL may share the information (including your Personal Information) with our Affiliates, employees, directors, agents, contractors, business partners, and our successors or permitted assigns or any third-party service provider, to provide you access to the Platform and/or Services, and by registering on the Platform and/or for our Services, you provide your express consent to us that we may collect, store, share, transmit or otherwise use your information (including Personal Information) per this Privacy Policy in particular and these Terms in general.

  1. COLLECTION

    1. Personal Information: When you create an account or register with us, we collect information that can be used to identify you ("Personal Information"). Personal Information may include your email address, name, username, address, and phone number, PAN Card number, and any other personally identifiable information that you may choose to provide us or that you choose to include in your account on the Platform. We may also collect Personal Information that you provide when you place Bids, make an offer or an Acceptance, or otherwise communicate with us or other Users on or through the Platform.
      THE PLATFORM WILL NOT BE AVAILABLE TO INDIVIDUALS OR ENTITIES NOT REGISTERED WITH SAFSPL. IF YOU ARE NOT REGISTERED, YOU WILL NOT BE ABLE TO USE THE PLATFORM.
    2. Your Content and Communications: Our Services permit you to interact with us through the notification system. We collect and store all of the comments, communications, and chats you post, transmit or generate on the Platform and/or through the Services. When you ask for assistance from SAFSPL for customer support, the contact information you provide will be collected, as well as the information which you post while using the Platform and/or the Services, such as, your user ID number, etc., and any correspondence or information contained within.
    3. Cookies: SAFSPL may employ cookies to track your access to the Platform and/or Services. These technologies operate either by placing a small file that stores some information on your computer or mobile device; and/or by accessing the information on your device. SAFSPL uses cookies and similar technologies to recognize your device, for example by identifying your IP address, and to collect data such as your device’s model, operating system and screen size, other applications installed on your device, time and date, and other information about how you use the Platform and/or Services. SAFSPL uses this information (a) to store and access information; (b) to enable SAFSPL to provide you with more customized services, and (c) to collect other information about your use of our Services.

  2. SAFSPL’S USE AND DISCLOSURE OF INFORMATION

    1. Use of information You agree that SAFSPL and/or service providers on SAFSPL’s behalf may use the information they collect, including your Personal Information for:
      1. contacting you for customer support;
      2. sending you updates or information about the Platform and/or Services;
      3. managing your account and relationship with the Platform and/or Services, and improving your experience when you use it;
      4. improving the Services, research, surveying, and engaging with you, for example by sending you communications for these purposes;
      5. marketing and promotion of the Platform and/or Services and/or other products;
      6. personalizing and optimizing the Platform and/or Services;
      7. sharing promotional content and/or advertising; and
      8. creating reports, analysis, or similar services for research or business intelligence.
      2. You may unsubscribe from some of these messages by sending an email to us at the email address set out in Clause 11 below.
    2. Information available By using the Platform and/or the Services you make certain that your Personal Information will be available to other Users. For example, when a trade is closed on the Platform, SAFSPL provides the contact information of the execution profile or, in case such profile is not available, the commercial profile, to other Users. When you list an auction with your details on the Platform, such listing, post, and/or activity are shared with other Users who may then share this information with others through the Platform and/or Services or outside the Platform and/or Services. You acknowledge that you have no expectation of privacy about the auctions, Bids, Offers, Acceptance, Contract Confirmation, which are posted on the Platform.
      NOTWITHSTANDING THE ABOVE, LISTINGS/POSTINGS MADE ON THE PLATFORM WILL ONLY BE SHARED WITH OTHER USERS.
    3. Other transfers ANY DISCLOSURE IS ALWAYS ON A CONFIDENTIAL BASIS.
      If SAFSPL’s control is acquired by a person(s) other than the present promoters, we may share Personal Information with such person(s), but even they will have to store and use such information in compliance with this Privacy Policy. We may also disclose information for other purposes to the extent authorized and/or required by law or judicial order. Otherwise, we do not disclose information for any other purposes, unless it has your consent.

  3. SECURITY OF YOUR PERSONAL INFORMATION

    SAFSPL takes all reasonable and sound steps to ensure that the information is protected against misuse, loss, unauthorized access, modification, and/or disclosure. SAFSPL adopts and applies appropriate data collection, storage, management practices, and security procedures to protect against unauthorized access, alteration, addition, deletion, disclosure, and/or destruction of a User’s personal information, including their username, email address, password, transaction information, and any other data stored on the Platform. However, no data storage or transmission over the Internet or other network can be guaranteed to be 100% secure. Accordingly, SAFSPL does not guarantee that information will not be accessed, disclosed, altered, or destroyed by any breach of any of the abovementioned safeguards. To the extent applicable, SAFSPL complies with all applicable data protection laws, and you (the User) are duly bound to provide all reasonable assistance and information to SAFSPL about compliance with such laws.

  4. ACCESS TO PERSONAL INFORMATION

    You have the right to access the Personal Information we collect and hold about you. If at any time you would like to access or change your Personal Information, or you would like more information on our approach to protecting your privacy, please contact us at the contact details set out in Clause 11 below. You can opt-out of receiving certain promotional or marketing material by selecting the unsubscribe option contained within the emails providing such material or contacting us at the contact details set out in Clause 11 below. However, you cannot opt out of receiving all e-mails from us about your use of the Platform, such as e-mails about the status of your account.

  5. DATA PROTECTION PRACTICES

    Our data is hosted in Endurance International Group India Pri and the data is encrypted at rest and in transit using Encryption Standards. We utilize network firewalls built into Endurance International Group India Pri to ensure further security. We use Endurance International Group India Pri for monitoring the systems, access logs, and activity on our infrastructure.

  6. ADOPTION OF STANDARD PRACTICES

    We have implemented standard security best practices and have a comprehensively documented information security program in compliance with Rule 8 of the Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011. However, this is to further record and clarify, the Company is not required to comply with any specific ISO standard as per the Applicable Laws.

  7. DATA RETENTION POLICY

    We are committed to protecting and respecting your privacy and will comply with all applicable data protection laws in all our dealings with your personal data. We review and update our data retention policies regularly to protect data securely and ensure that it is not deleted prematurely, either inadvertently or maliciously.

    1. User Data Retention

      1. Personal Data of the Users, such as but not limited to the below
        1. Full Name;
        2. Email address;
        3. Phone number;
        4. Physical Address;
        5. Id Photo;
        6. Id Proof details;
        7. Family Details;
        8. Gender;
        9. Age
        10. Date / Place of Birth;
        11. Use of cookies on web;
        12. Bank Account details;
        13. Transaction Information;
      2. Geo- Location Information: Use and store information about your location- to provide features of our Service, to improve and customise our offerings;
      3. Usage Information is captured - Your interactions with the platform;
      4. Non-Identifying Information - Whenever you visit our website, we may collect non-identifying information, such as referring URL, browser, operating system, and Internet Service Provider;
      5. We may give information to law enforcement if we are compelled to by a court order, if there has been a violation of any Indian laws or if a violation of the Terms of Service or Privacy Policy has occurred;
      6. We retain residual information in our backup and/or database. Such information would be deleted subject to contractual agreements, provided that region/country’s law permits the same.
    2. Corporate Data Retention
      1. Including but not limited to, business records, files, finances, taxes, legal and vendor partners, corporate announcements, shareholding patterns, both paper or electronic records;
      2. Excluding Customer (User) data and Employee Data;
      3. Protect data from destruction for a length of time till the servers are operated by the Company;
      4. Obtain approval of legal department to permanently delete the data after period mentioned above is over.
    3. Employee Data Retention
      1. Including but not limited to, memoranda, contracts, emails, expense records and performance reports;
      2. Email, Slack, Notion, HR data to be retained for period in accordance with Applicable Laws;
    4. The policy to be reviewed periodically by the senior management. Accordingly suggest changes while facing practical difficulties or comply with legislations;
    5. Certain records to be kept for Perpetuity, unless mentioned otherwise:
      1. Board of Directors Records of minutes of meetings;
      2. Press Releases and Public Filings documents;
      3. Book of Accounts and Tax Records;
      4. Employment Records including recruitment, employment and personal information. Retained for 3 years from cessation of employment;
      5. Intellectual Property Records;
      6. Execution copies of all contracts should be retained for at least 3 years following the expiry or termination of the contracts.
  8. TERM

    SAFSPL may retain the information (including Personal Information) for as long as is necessary to fulfill the purposes for which it was collected or as needed to provide, even after you have discontinued or deleted any account or have ended the provision of the Services, if retention of such information is reasonably necessary to comply with SAFSPL’s legal obligations, regulatory requirements and for resolving disputes between Users or for preventing fraud, for backup, archival, and/or audit purposes or any other use.

  9. GENERAL TERMS

    Notwithstanding anything to the contrary in this Privacy Policy, SAFSPL may preserve or disclose your information: (a) to the extent reasonably necessary to comply with a law, regulation, or legal request; (b) to protect the safety of any person; (c) to address fraud, security or technical issues; or (d) to protect SAFSPL’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party, including a government’s request to disclose your information. If any court or other competent authority finds any of this Privacy Policy to be invalid or unenforceable, the other terms of this Privacy Policy will not be affected.

  10. CHANGES TO THIS PRIVACY POLICY

    The most recent version of this Privacy Policy will govern the use of the information (including Personal Information) on the Platform. We may revise or amend this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Platform. SAFSPL may also, but is not required to, notify you of changes to the Privacy Policy via email to the email address associated with your account. If you object to any changes to the Privacy Policy, you should immediately stop using the Platform and/or Services and close any related accounts. By continuing to access or use the Platform and/or Services after changes have become effective, you agree to be bound by the revised Privacy Policy.

  11. COMPLAINT & GRIEVANCE MECHANISM

    To Address the queries/concerns of the users we have defined Complaint & Grievance Mechanism.

    1. Level 1: Users can reach us through the “Help via Call” feature on the mobile application or can write to us at support@naveenmandi.in.
    2. Level 2: If the user query/concerns are not addressed to the expected levels, then they can reach the Grievance Officer- Mr. Awdesh Mishra. Email id: grievanceofficer@naveenmandi.in ; Grievance officer acknowledges the receipt of any user query/concerns within 72 hours and redresses the complaint within 3 month from the date of receipt of the complaint.
    3. Level 3: In the unlikely event that your issue remains unresolved to your satisfaction despite escalating to our Grievance Officer, you can reach out to our Nodal Officer Mr. Amiya Sharma– nodalofficer@naveenmandi.in . We will respond within 7 business days from the date of receipt of your email.