Privacy Policy
I. OBJECTIVE, SCOPE AND APPLICABILITY OF THE POLICY
The privacy policy ("Policy")
is applicable to the online interfaces of Convivial Software Pvt Ltd.
("TJSBSociety", "us", "we" or "our")
including www.tjsbsociety.com, the mobile site/applications
(including but not limited to the TJSBSociety, white label apps
developed for real estate developers, or any other app) for iOS,
Android, or any other windows operating system (collectively referred
to as "Site").
TJSBSociety's services are offered in
collaboration with the services offered by the Resident Welfare
Association (RWA) of the premises being serviced. The respective RWAs
are our partners and customers. As such, information which is subject
to this Policy may be provided directly by the RWA on behalf of its
residents or may be collected via the direct consent of the residents
or other users who may choose to interact with the Site. The purpose
of this Policy is to describe how TJSBSociety collects, uses,
maintains and shares information about you ("user" or "you"
or "your") on account of data shared by the RWA or you
accessing and using the Site. This information may include but is not
limited to any information you upload, emails that you exchange with
TJSBSociety and other users of the Site and any information
submitted/ provided by you to TJSBSociety. The reference to "user"
or "you" or "your" in this Policy shall also
include a reference to the RWA which acts as a custodian of the user
data provided under relevant contracts/arrangements between the RWA
and the residents.
We recognize the importance of your privacy
and we are committed to ensuring that you are aware of how your
information is being used. Please read this Policy carefully to
understand how we collect and use your information. Your use of the
Site is also governed by our Terms of Service (available on the
Site). You are free to use the Site only if you agree with our
policies and practices encapsulated in this Policy read in
conjunction with the Terms of Service.
By using the Site
and/or by providing your information to us, you consent to the
collection and use of the information you disclose on the Site in
accordance with this Policy. If you wish to contact TJSBSociety in
connection with any matter relating to this Policy or privacy related
issues you may send an email to support@tjsbsociety.com.
You also agree that the information
furnished by you is lawful, true and correct and does not violate or
infringe any laws. In case of any violations, infringement,
furnishing of wrongful or unauthorized information, TJSBSociety shall
not be liable to you or to any third party for the same.
We
use data collection devices such as "cookies" on certain
pages of the Site to help analyse our web page flow, measure
promotional effectiveness, and promote trust and safety. The term
"cookies" means small files placed on your hard drive that
assist us in providing our services. We also use cookies to allow you
to enter your password less frequently during a session. Cookies can
also help us provide information that is targeted to your interests.
You are always free to decline our cookies if your browser permits,
although in that case you may not be able to use certain features on
the Site. Additionally, you may encounter "cookies" or
other similar devices on certain pages of the Site that are placed by
third parties. TJSBSociety does not control the use of cookies by
third parties.
II. TYPES/ NATURE OF INFORMATION WE COLLECT:
There are three (3) general categories
of information we collect.
A. Information you provide us,
to enable your use of the Account/Site
B. Information
you choose to give us
C. Information that is necessary
for the payment related services
Further to each of the
aforementioned categories set out in Section II: Sub-Section A, B and
C above we collect the following types of information from you
(collectively referred to as "Information")
(i) "Personally
Identifiable Information" - information that could be
used to identify you such as your name, email address, age, gender, Photo/image
house ownership/residency details, visitor/guest details, IP
addresses and other similar information;
(ii) "Sensitive
Personal Information" such as passwords in encrypted
form and secured financial/ payment related
information;
(iii) "Non-Personal Information" -
information that cannot be used to identify you such as the webpages
that you have viewed and your usage patterns;
(iv) "Device
Information"- information which is automatically collected
about the device from which the Site is used; and
(v) "Third
party personnel and asset information" - information
provided by RWA about the details of staff working in society and
individual houses, asset & inventory in the
society.
A. Information you provide TJSBSociety to
enable your use of the Account/Site
We ask for and
collect the following Personally Identifiable Information and
Sensitive Personal Information about you when you use the Site. This
information is necessary for performance of the agreement between you
and us and to allow us to comply with our legal obligations. Without
it, we may not be able to provide you with all the requested
services.
(i) Account Information. In order
to use certain features on the Site, TJSBSociety may require you to
create a user account ("Account") which shall include your
user profile ("Profile"). In the alternative, TJSBSociety
may also create a user account for you based on the information
provided by the RWA; this account shall be subject to verification by
the RWA management or directly by you. When you opt to create such an
Account and sign /click on "I Accept" (or any other form of
express consent) in respect of the creation of an Account, we require
you to provide certain Personally Identifiable information such as
your first name, last name, email address, date of birth, phone number, Photo, interests, and depending on the
nature of services you avail, information pertaining to your gender
and marital status.
(ii) Profile and Listing
Information. In addition to (i) above, in order to use
certain features on the Site (such as booking or creating a listing),
we may ask you to provide certain additional Personally Identifiable
Information, which may include your address, phone number, and a
profile picture.
(iii) Identity Verification
Information. To help create and maintain a trusted
environment, we may collect certain Personally Identifiable
Information in order to verify your identity, such as images of
rent agreement, house ownership documents or any other information as may be required to verify your
identity/residency.
(iv) Payment Information. In
addition to the foregoing, in order to use certain other features on
the Site (such as booking or creating a listing), we may require you
to provide certain financial information (as more particularly
described in sub section C below) in order to facilitate the
processing of payments.
(v) Communications with
TJSBSociety and its affiliates and authorised service
providers/agents or other users. When you communicate with
TJSBSociety or use the Site to communicate with TJSBSociety's
affiliates and authorised service providers/agents or when you
communicate with other users of TJSBSociety, we collect all such
correspondence, information about your communication and any
additional information you choose to provide.
(vi) Visitor
Information. TJSBSociety offers a service for intelligent gate and/or
visitor management. Access to the society for third party
vendors / guests is controlled through our Site and is subject to
your consent.
B. Information you choose to give
us
You may choose to provide us with additional
Personally Identifiable Information in order to obtain a better user
experience when using TJSBSociety.
(i) Additional
Profile Information. You may choose to provide additional
Personally Identifiable Information as part of your Profile
(preferred language(s), city, and a personal description). Some of
this information as indicated in your account settings is part of
your public profile page and will be publicly visible to
others.
(ii) Address Book Contact Information. You
may choose to import your address book contacts or enter your
contacts' information manually to access certain features of the
TJSBSociety.
(iii) Other Information. You may
otherwise choose to provide us Information when you fill in a form,
conduct a search, update or add information to your Account, respond
to surveys, post to community forums, interact with other users,
participate in promotions/polls, or use other features/
functionalities of the Site. You may also choose to provide
information in relation to on-premises vehicle management and your
interests etc.
C. Information that is necessary for
the payment related services
TJSBSociety needs to
collect the following Sensitive Personal Information, as it is
necessary for the adequate performance of its agreements with you and
to comply with applicable law (such as anti-money laundering
regulations). Without it, you will not be able to use payment
services offered by TJSBSociety on the Site:
(i) Payment
Information. When you use any payment services on the Site,
certain financial information may be required to facilitate the
processing of such payments. You are to note that TJSBSociety engages
with third party payment service providers in order to enable you to
process your payments in connection with the use of TJSBSociety's
services. You will be required by such third-party payment service
providers to provide certain Sensitive Personal Information. Please
note that to this extent, you will be subject to the terms of use and
privacy policy that is maintained by such third-party service
provider.
(ii) Identity Verification and Other
Information. In connection with the collection of payment
information and processing your payments we may also require certain
information using which we can verify your identity (such as images
of your specified government issued identification including
passport, national ID card, or driving license) or other
authentication information/KYC documents, your date of birth, your
address, e-mail address, phone number and other information (such as
your invoice amount, e-mail id and contact number) in order to verify
your identity, provide the payment services to you, and to comply
with applicable law.
(iii) Financial information
pertaining to Society/Residents/Vendors. TJSBSociety Site
may also be utilized (under relevant contractual arrangements) by the
RWA managements for managing financial information including but not
limited to billing and accounts, payment disbursal/collection from
residents and/or vendors etc.
III. SHARING YOUR INFORMATION:
We share your Information within
TJSBSociety's group companies and with other persons, service
providers and entities who help us provide services to you (e.g.
services partner, social community partner etc). We only share your
information in accordance with the applicable law. In the interest of
clarity, we share your Information for the purposes set out in this
Policy, with the following categories of recipients:
(a) We
use a variety of third-party service providers and vendors to help us
provide products and services related to TJSBSociety, utilities and
services related to living (water, laundry, mobility etc.), and
payment services. For example, service providers which assist us to:
(i) verify your identity or authenticate your identification
documents; (ii) perform product development, software and website
maintenance and debugging; (iii) allow the provision of TJSBSociety
services through third party platforms and software tools (e.g.
through the integration with our API's); or (vi) provide customer
service, advertising, or payments services. These providers have
access to your information to the extent required to perform these
tasks on our behalf and are contractually bound to protect and to use
it only for the purposes for which it was disclosed and consistent
with this Policy.
(b) With persons/entities that own/ manage
other applications or websites that integrate with our API or
services, or those with an API or service with which we are
integrated or choose to integrate in future;
(c) Other
residents of the society and RWA management to the extent it is
required to offer our services and for community engagement.
(d)
Third parties where we have a duty to or are permitted to disclose
your Information by law (e.g. law enforcement officials, government
authorities);
(e) With the police in the exercise of their
functions or with others as required by a court order;
(f)
Third parties where we or any TJSBSociety group company, sell or buy
any business or assets, in which case we may disclose your
Information to the prospective seller or buyer of such business or
assets;
(g) Third parties in connection with any merger, sale
of company assets, consolidation or restructuring, financing, or
acquisition of all or a portion of TJSBSociety or any of the
TJSBSociety group company's business, in which case Information held
by it you may be one of the transferred assets.
Note where we
share your Sensitive Personal Information or Personally Identifiable
Information, appropriate protections will be in place to protect such
information as required by applicable data protection laws.
Sometimes, we may share Information in an aggregated, pseudonymised
and/or anonymised form which cannot reasonably be used to identify an
individual.
IV. PURPOSES FOR WHICH WE USE YOUR INFORMATION:
(a) Correspondence/communication with
you pursuant to you registering an Account or your usage of the
Site;
(b) Verification of your Account;
(c) Ensuring that the
content on the Site is presented in the most effective manner for you
and for your device;
(d) To provide you with newsletters,
information, products or services that you request from us which we
feel may interest you, where you have consented to be contacted for
such purposes;
(e) To notify you about changes to the Site, this
Policy or the Terms of Service;
(f) For the purpose of studying
your usage patterns;
(g) For analytical purposes, including but
not limited to assessing usage data, usage patterns, estimate
audience sizes and other similar activities;
(h) In any other
manner we may describe when you provide the Information;
(i)
Detection and prevention of fraud, spam, abuse, security incidents,
and other harmful activity;
(j) Conducting security investigations
and risk assessments;
(k) Verification or authentication of the
information or identifications provided by you;
(l) Compliance
with our legal obligations and applicable laws;
(m) Compliance and
monitoring of our contractual obligations towards you;
(n)
Resolution of any disputes with you or any of our users and enforce
our agreements with third parties.
In connection with the
activities above, we may conduct profiling based on your interactions
with TJSBSociety, your Profile information and other content you
submit, and information obtained from third parties. In limited
cases, automated processes may restrict or suspend access to Site, if
such processes detect an activity that we think poses a safety or
other risk to TJSBSociety, other users, or third parties.
V. DATA SECURITY
The Information that you provide,
subject to disclosure in accordance with this Policy and Terms of
Service, shall be maintained in a safe and secure manner.
TJSBSociety's databases and Information are stored on secure servers
with appropriate firewalls owned by TJSBSociety or by third
parties.
TJSBSociety gives the user right to withdraw his
consent by sending an email at support@TJSBSociety.com. Some
information/access may still be retained if information has been
provided by the RWA management and is necessary for discharge of our
services.
Given the nature of internet transactions,
TJSBSociety does not take any responsibility for the transmission of
Information including the Information you provide to TJSBSociety. Any
transmission of your Information on the internet is done at your
risk. TJSBSociety does not take any responsibility for you or any
third party circumventing the privacy settings or security measures
contained on the Site.
While TJSBSociety will use all
reasonable efforts to ensure that your Information is safe and
secure, it offers no representation, warranties or other assurances
that the security measures are adequate, safe, fool proof or
impenetrable.
You acknowledge that as a registered user you
are responsible for maintaining the security of your Account such as
your Account login credentials and passwords, and that you should not
provide these credentials to any third party. If it comes to your
knowledge that or if you have reason to believe that your Account
credentials have been stolen or been made known to others, you must
contact us immediately at support@TJSBSociety.com. You acknowledge
that you are responsible for all acts done, using your Account login
credentials. TJSBSociety is not responsible if someone else accesses
your Account on account of your failure to maintain security of your
Account credentials.
VI. YOUR RIGHTS:
(a) Managing Your Information
You
may access and update your Personally Identifiable or Sensitive
Personal Information through your Account settings. Please note that
you do not have the option to connect to third party applications
using your Account. Do note however, TJSBSociety reserves the rights
to save any Non-Personal, Device Information and usage Information
and you are not entitled to seek the deletion of the
same.
TJSBSociety at its sole discretion may permit or deny
the change of any Information, if it is believed such Information is
required to comply with applicable laws.
(b) Rectification of
Inaccurate or Incomplete Information
You have the right to ask us
to correct inaccurate or incomplete Personally Identifiable
Information or Sensitive Personal Information concerning you (and
which you cannot update yourself within your Account) by contacting
data.privacy@eukleiatech.com.
VII. DATA RETENTION AND ERASURE
We retain your Information as long as it is required for it discharge its obligations towards you and/or as may be required under law. However, there may be circumstances that mean we must retain your personal information for longer (e.g. in the event of a dispute etc.). We may retain some of your Personally Identifiable information as necessary for our legitimate business interests, such as fraud detection and prevention, servicing contractual obligations to RWA/vendors and enhancing safety. Information you have shared with others (e.g. reviews, forum postings) may continue to be publicly visible on the Site, even after your Account is cancelled.
VIII. INTERNATIONAL PRIVACY RIGHTS
TJSBSociety's Sites and/or databases are operated and managed on servers that may be located and operated in different jurisdictions. By using and accessing the Site, you consent to the transfer to and processing of your Information including the Sensitive Personal Information and the Personally Identifiable Information, on servers that may be located in a jurisdiction different from where you are located, and that the protection of such Information may be different than required under the laws of your residence or location.
IX. AGE RESTRICTIONS
The Site is only intended for users who are competent to contract under applicable law. If you are not of the requisite age, you are not to provide any Personally Identifiable Information or Sensitive Personal Information. If it comes to TJSBSociety's attention that any such information pertains to an individual who is not competent to contract under applicable law, such Information may be deleted without notice to you.
X. AMENDMENTS TO THE POLICY
This Policy is subject to change at TJSBSociety's sole discretion. Any changes to the Policy will be notified by way of a notice on the page where this Policy is hosted.
XI. TERMS OF USE
This Policy shall form a part of the Terms of Service.
XII. DATA PROTECTION CONTACTS
If you have any questions, comments, complaints or suggestions in relation to this Policy, or any other concerns about the way in which we process information about you, please contact our Grievance Redressal Officer (details mentioned below) at support@tjsbsociety.com. We shall endeavour to address all requests/complaints within thirty (30) days from the date of such a request/complaint being made.
Umesh
Dere
email: umesh@societyrun.com
This Policy has been last updated on 22nd Feb, 2021.