We appreciate & value the trust that you have placed on us. Our Privacy &Data Recoverypolicy demonstrates our commitment to the privacy of the users for our Site(www.konnxt.com and its allied sites) and BUZZ App (Android, iOS, Windows app, &anyother product owned by KONNXT PRIVATE LIMITED). Please read the following tolearnmore about our Privacy and Data Recovery policy, and how we treat personallyidentifiable information collected from our visitors and users. Please note that by visiting this Site or using BUZZ App you agree to be boundbytheterms and conditions of this Privacy and Data Recovery Policy which is a legally bindingagreement between you and us, KONNXT PRIVATE LIMITED, the owner of the Site&BUZZApp (“Company”). If you do not agree, please do not use or access this Site or BUZZApp. By mere use or access of the Site or BUZZ App, you expressly consent to our useanddisclosure of your personal information in accordance with this Policy. This Policyisincorporated into and subject to the Terms of Use. PRIVACY & DATA RECOVERY POLICY
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KONNXT PRIVATE LIMITEDThis Privacy and Data Recovery policy (herein after referred to as the Policy) has beenframed and is being issued herewith for implementation in the Company. The Policysetsforth to enforce the entire Privacy and Data Recovery framework & it’s governanceintheCompany. Here the intent of the Policy is to enhance Confidentiality, safety, security, efficiency in processes, data exchange and recovery involving leadership support, organizational structure and strategy through well-defined responsibilities of the Board&executive management
OBJECTIVES
To provide Security oriented services and support to facilitate innovative useof
technology for better company’s decision making and for providing better servicestothe Subscribers
More and More Integration of security and recovery of Data into the operationandother functions in line with the overall business objectives of the company
Provide infrastructure to application subscribers through a more secured platform, cyber security, personalized and timely access of information, services and support. Clearly Defining Roles and responsibilities of the company’s board, management andits customers in enabling corporate governance, leadership support, organizational
structure to ensure Information systems sustains and extends strategies toachieve overall objectives.
SCOPE AND MANDATE
The Mandate of the policy is to set out Company’s approach towards its own informationsecurity management systems. The documents in the Privacy Systems Policy apply to all information and assets whichareowned by the company irrespective of any form, used by the company for business orany other purposes or which are connected to any networks managed by the company. The documents in the Privacy systems Policy set apply to all subscribers of thecompany and any other individual who may process information on behalf of the company. The scope of the Privacy Systems Policy is concerned with the management and securityof
the company’s information assets and the use made of the assets by its employees andother individuals who may legitimately process company’s information on its behalf. This policy and the Framework apply to:
(a) Anyone Individual within the company who accesses company’s informationassetsor technology. This includes employees or any other Individual
(b) Technologies or services used to access or process company’s Information assets
(c) Information assets processed in relation to Government, regulators or any otherentity’s activity or function, including by, for, or with, external parties
(d) Information assets that are stored by the company or an external service provider onbehalf of the company
(e) Information that is transferred from and/or to the government, Regulators or anyother entity for a functional purpose
(f) 3
rd party, public civic or other information that the company stores, curates or useson behalf of another party
(g) Internal and/or external systems that are used to process, transfer or storecompany’s information
PART 1
WHAT THIS PRIVACY POLICY COVERS?
This privacy policy covers treatment of personally identifiable information collectedbythisSite and BUZZ App
- Collection and Use of Personal Information
a) While using BUZZ app, we would collect & store following information:
I. Email Addresses
We automatically read & collect your email addresses available onyourphone. We need email addresses to send you email for updates, Invoices&other communications. We do not share this with any third parties.
II. Phone Number
We collect phone number only when you explicitly give it to us. Thisisneeded to alert text messages etc. Phone Number is also needed for uniqueidentity to help us give you BUZZ points in your BUZZ closed wallet withintheapp.
III. SMS or Message Logs
We may store the log of all the SMS sent to a you on behalf of the Buzz appor Konnxt Pvt Ltd on our server to notify you with status changes or toinform you about other services.
IV. Device ID
We may store your device id such as IMEI number to help us uniquely identifyyou. This is needed as many users carry more than one devices toaccessBUZZ app
V. GPS location & City
We may track your current GPS location & city to offer you personalizednews & information such as other BUZZ users around your location. VI. Device Make, operator name
We collect device type for you to optimize certain features for your devicetype
VII. Network type
We may collect this information as few network types behave differentlyattimes
VIII. Operating System Version Code & Version Name
We may collect operating system version name & version code tooptimizecertain features for your OS version
IX. App Version code and app version name
We may collect app version code and app version name to help support youbetter. 2. The data should be collected in the format for Signup. The above informationmayalsobe used for internal analysis on our users’ demographics, interests, andbehaviorpatterns to help us better understand, protect and serve our users. This information
is analyzed on an aggregated basis. (An extract of data collection procedureispresented in scenario 1)
None of this information is shared with any third parties & may be periodicallydeleted from our servers when not needed. Provided Company do shares datawiththird party for advertisement and usage purposes all routine but does not discloses sensitiveinformation like name and buzz-name. But other information is shared among backendadvertisers. 3. You can visit the Site without revealing any personal information. However, onceyouregister yourself to avail our services, you will be sharing your personal informationwith us. This helps us provide you a safe and customized experience on our site. Wemay automatically track certain information about you based upon your behavior onour Site. 4. For users accessing our Site, the information collected may include the sourceURL, destination URL, your operating system, device, browser information, andyour IPaddress. We use data collection devices such as “cookies” on certain pages of theSite to help analyze our web page flow, measure promotional effectiveness, andpromote trust and safety. “Cookies” are small files placed on your hard drivethatassist us in providing our services. We offer certain features that are only availablethrough the use of a “cookie”. We also use cookies to allow you to enter yourpassword less frequently during a session. Cookies can also help us provideinformation that is targeted to your interests. Most cookies are “session cookies,”meaning that they are automatically deleted from your hard drive at the endof asession. Additionally, you may encounter “cookies” or other similar devices oncertain pages of the Site that are placed by third parties. We do not control theuseof cookies by third parties - If you choose to transact on the Site or the BUZZ App, we may collect informationabout your web behavior, such as your mobile number, your personal informationwhich user have shared, a credit / debit card number and a credit / debit cardexpiration date and/ or other payment instrument details. 6. Information Sharing and Disclosure
We do not share any of your personal information to any third parties. Wemaydisclose your personal information to affiliates who work with us to provide productsand services requested by you. We will share personal information for thesepurposes only with affiliates whose privacy policies are consistent with ours or whoagree to abide by our policies with respect to personal information. Wemay
otherwise disclose your personal information when: We have your express consentto share the information for a specified purpose. We need to respond to subpoenas, court orders or such other legal process. We need to protect the personal safetyof
the users of our Site, BUZZ app or defend the rights or property. We find that youractions on our Sites violate the Terms of Use document or any of our usageguidelines for specific products or services. 7. BUZZ App Privacy Policy
This Privacy Policy describes the policies and procedures of KONNXT PRIVATELIMITED (“BUZZ”) on the collection, use and disclosure of your information whenyouuse the BUZZ Application on your mobile phone. BUZZ app collects andusesinformation as described in “Collection and Use of Personal Information” section. Wewill not use or share your information with anyone except as describedinthisPrivacy Policy. This Privacy Policy does not apply to information we collect byothermeans (including offline) or from other sources. The terms “we”, “us”, and“ourwebsite” refer to BUZZ App or www.konnxt.com or buzz.konnxt.comand theterms”you” and “your” refer to you, as a user of one of our services. The term”personal
information” means information that you provide to us which personally identifiesyou to be contacted or identified, such as your name, phone number, email address, and any other data that is tied to such information. 8. How We Share Your Information
a) Personally Identifiable Information:
I. KONNXT PRIVATE LIMITED (BUZZ) may share your personally identifiableinformation with affiliates for the purpose of providing the Service toyouorwith affiliates offering combined services with us. If we do this, suchaffiliatesuse of your information will be bound by this Privacy Policy. We maystorepersonal information in locations outside our direct control (for instance, onservers or databases co-located with hosting providers). We may shareordisclose your information with your consent, such as if you choose tosignonto the Service through a third-party service on our Site. KONNXT PRIVATELIMITED (BUZZ) may disclose your personal information if requiredtodosoby law or summon or if we believe that it is reasonably necessary tocomplywith a law, regulation or legal request; to protect the safety of any person; toaddress fraud, security or technical issues; or to protect our rightsorproperty. b) Non-Personally Identifiable Information
I. We may aggregate and/or anonymize information collected throughtheService so that the information does not identify you. We mayuseaggregated, anonymized, and other non-personally identifiable information
for any purpose, including for research and marketing purposes, andour useand disclosure of such information is not subject to any restrictions underthis Privacy Policy. II. KONNXT PRIVATE LIMITED (BUZZ) may allow third-party ad servers or adnetworks to serve advertisements on the Service and on third-party services. These third-party ad servers or ad networks use technology to send, directlyto your browser, the advertisements and links that appear on our property. They automatically receive your IP address when this happens. They mayalsouse other technologies (such as cookies, JavaScript, or web beacons) tomeasure the effectiveness of their advertisements and to personalizetheadvertising content. KONNXT PRIVATE LIMITED (BUZZ) does not provideanypersonally identifiable information to these third-party ad servers or adnetworks without your consent. However, please note that if an advertiserasks KONNXT PRIVATE LIMITED (BUZZ) to show an advertisement toacertainaudience and you respond to that advertisement, the advertiser or adservermay conclude that you fit the description of the audience they are tryingtoreach. The KONNXT PRIVATE LIMITED (BUZZ Privacy Policy does not applyto, and we cannot control the activities of, third-party advertisers. Pleaseconsultthe respective privacy policies of such advertisers for more information. 9. Advertising
We may use third-party advertising companies to serve ads when you visit our Site. These companies may use information (not including your name, address, email
address, or telephone number) about your visits to this and other websites inorderto provide advertisements about goods and services of interest to you. 10. Consent
By using the Site and/ or by providing your information, you consent tothecollection and use of the information you disclose on the Site in accordance withthisPrivacy Policy, including but not limited to your consent for sharing your informationas per this privacy policy. 11. Security
Unfortunately, no data transmission over the Internet can be considered100%secure. However we use industry-standard encryption to protect data transmissions. Wealso safeguard your personal information from unauthorized access, throughaccesscontrol procedures, network firewalls and physical security measures.
PART II
DATA BACKUP FRAMEWORK
It is the policy of the company to define the backup process for computers / Laptopsand other electronic device within the company, which are expected to havetheirdata backed up. The policy is designed to protect company’s data and to ensurethatit can be recovered in the event of an equipment failure, intentional destructionof
data, or disaster. This policy applies to all information, critical systems and their dataowned and operated by the organization. 12. Certain Basic Concepts
a) Backup The saving of files onto magnetic tape or other offlinemassstorage media for the purpose of preventing loss of dataintheevent of equipment failure or destruction
b) Archive The saving of old or unused files onto magnetic tape or otheroffline mass storage media for the purpose of releasing on-linestorage room
c) Restore The process of bringing off line storage data back fromtheoffline media and putting it on an online storage systemsuchasa file server. d) Timing
Full back up is performed monthly on the last week of the month. If for publicholiday/maintenance reason, backups are not performed. They are done onnextworking day. (a) Cloud Storage
Cloud Storage – Backups are performed on Storage service as provisionedon“Amazon Web Services “ – please refer to the privacy policy of AWS and Amazononhttps://aws.amazon.com/privacy/ and all data stored and interactions will bemaintained on Mongo DB Atlas please refer to the privacy policy for the sameonhttps://www.mongodb.com/legal/privacy-policy. (b) Cloud Storage Cleaning
Cloud Storage cleaning will be done on a monthly basis within the 10
th day of thefollowing month. In case of emergency situation cleaning is done as soon as possiblefor the CIO and the concerned team.
(c) Monthly Backups
The last week backup tape of every month shall be stored at company’s registeredoffice. Further Backup shall be stored on AWS (any one)
(d) Responsibility
The CIO / IT Administrator or delegate a member of the Information Technology(IT)
department should perform regular backups. The IT department shall test theabilityto restore data from backups. (e) Testing
The ability to restore data from backups shall be tested at least on a monthly/quarterly cycle as per direction of the CIO
(a) Data Backed Up
Data to be backed up include the following information:
i SignUP Details (as specified below)
ii Live Location Details (GPS data)
iii Messages and Chat Logs
iv FrontEnd and Backend Codebase including the database
v Mail archive
vi Legacy Application database
(b) Restoration
Users that need files restored must submit a request to the help desk. That includesinformation about the files, folder and its path with reason – As is
(c) Data Retention
Monthly Data backed up on backup tapes to be retained for Eight years unlessspecifically directed by the CAB
Explanation – In case of day to day routine activities in relation to Data backup the ultimatecompetent authority will be any of the executive Director - Changes to this Privacy Policy
We may at any time, without notice to you and in its sole discretion, amendthispolicy from time to time. Please review this policy periodically. Your continueduseof
this Site after any such amendments signifies your acceptance thereof. 14. Grievance Officer
In accordance with Information Technology Act 2000 and rules made thereunder, the name and contact details of the Grievance Officer are provided below– SOHAM GAIN
135-N, KARUNAMOYEE GHAT
RD REF-C.PYNE 3/5/12
KOLKATA WB 700082 - Questions or Suggestions
If you have questions or suggestions about this privacy policy, or your ownpersonal
information, please e-mail us at buzzofficial@konnxt.com
SCENARIO 1
Information Collected when SIGNUP
Phone Number
Google / Facebook Login (through Google and Facebook, company only gets
authentication notice)
Name
Date of Birth
Profile Picture (From Phone Storage after asking for user permission)
Location of the User(With User Permission , not disclosed to anyone)
[We take data in the format for matching:
User activity on the app (Whichever options they choose and screen time, usage activity:
Matching preference, Buzz line, Profile updating Places where user is most active Downloadand deletion of the application )]
Each user has access to each user’s profile section which contains:
Buzz name
Age
Bio
Location (City & Country)
Profession and Interests
[Company holds rights to use User data keeping their sensitive information intact for
Company related activities for Curating Services Channelizing Advertisement]