Privacy Policy

NRA IT Services Private Limited, d.b.a. “NRA IT Services”, a company incorporated under the provisions of the Companies Act, 2013 and having its corporate office at B106, Sector 64, Noida, Uttar Pradesh- 201301 and its Affiliates (collectively with its successors, assigns, subsidiaries, and affiliates), is engaged in the business of providing IT and Marketing services. This Policy outlines NRA IT Service’s practices in relation to the collection, storage, usage, processing, and disclosure of personal data that you have consented to share with NRA IT Services when you access, use, or otherwise interact with NRA IT Service’s website (www.nraitservices.org) or avail services offered by NRA IT Services (“Services”).

At NRA IT Services, we are committed to protecting your personal data and respecting your privacy. In order to provide you with access to the Services, we have to collect and otherwise process certain data about you. This Policy explains how we process and use personal data about you.

Please note that unless specifically defined in this Policy, capitalised terms shall have the same meaning ascribed to them in our Terms of Use available at [•] (the “Terms”). Please read this Policy in consonance with the Terms.

By using the Services, you confirm that you have read and agree to be bound by this Policy and consent to the processing activities described under this Policy.

BACKGROUND AND KEY INFORMATION
1. How this Policy applies: This Policy applies to individuals who, either through themselves or through body corporates, use the Services provided by NRA IT Services. For avoidance of doubt, references to “you” across this Policy are to an end user that uses the Services. By using NRA IT Service’s Website and/ or Services, you consent to the collection, usage, storage, and disclosure of your personal data, as described in and collected by us in accordance with this Policy.
2. Review and Updates: We regularly review and update our Privacy Policy, and we request you to regularly review this Policy. It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
3. Third Party Services: The Website may include links to third party websites, plugins, services, and applications (“Third-Party Services”). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We neither control nor endorse these Third-Party Services and are not responsible for their privacy statements. When you leave the Website or access third party links through the Website, we encourage you to read the privacy policy of such third party service providers.
PERSONAL DATA THAT NRA IT SERVICES COLLECTS

a. We collect different types of personal data about you. This includes, but is not limited to:

1. 1. Contact Data, such as your mailing, office, or home address, location, email addresses, and mobile numbers.
  2. Identity and Profile Data, such as your name, username, or similar identifiers.
  3. Marketing and Communications Data, such as your address, email address, information posted in service requests, offers, wants, feedback, comments, and responses to our user surveys and polls (if any), your preferences in receiving marketing communications from us and our third parties, and your communication preferences.
  4. Technical Data, which includes your IP address, browser type, internet service provider, details of operating system, access time, page views, device ID, device type, frequency of visiting our Website, Website activity, clicks, date and time stamps, location data, and other technology on the devices that you use to access the Website.

b. We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data under law as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

c. What happens if you refuse to provide your personal data? Where we need to collect personal data by law, or under the terms of a contract (such as the agreement and/ or the Terms), and you fail to provide that data when requested, we may not be able to perform the contract (for example, to provide you with the Services). In this case, we may have to cancel or limit your access to the Services.

HOW NRA IT SERVICES COLLECTS PERSONAL DATA

We use different methods to collect personal data from and about you including through:

. Direct Interactions: You provide us your personal data when you interact with us. This includes personal data that you provide when you:

1. 1. Create an account or profile with us;
  2. Use our Services or carry out other activities in connection with the Services;
  3. Request marketing communications to be sent to you;
  4. Report a problem with the Website or our Services, give us feedback, or contact us;
  5. Any offline interactions that you may have with NRA IT Services and/ or its representatives.

a. Automated technologies or interactions: Each time you visit the Website or use the Services, we will automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, web beacons, pixel tags, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites or apps that employ our cookies.

b. Third parties or publicly available sources: We will receive personal data about you from various third parties:

1. 1. Technical data from analytics providers such as Facebook and advertising networks;
  2. Identity and profile-related data and contact data from service professionals, publicly available sources, etc.;
  3. Personal data about you from our affiliated entities.
HOW NRA IT SERVICES USES PERSONAL DATA

. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data when we need to provide you with the Services, enable you to use the Services, or where we need to comply with a legal obligation. We use your personal data for the following purposes:

1. 1. To verify your identity, and if applicable, to register you as a user and/ or to create your account with us;
  2. To provide Services to you;
  3. To enable the provision of Services to you;
  4. To monitor trends and personalise your experience with us;
  5. The improve the functionality of our Services based on the information and feedback we receive from you;
  6. To improve the Services to effectively respond to your Service requests and support needs;
  7. To track transactions and process payments;
  8. To send periodic notifications to manage our relationship with you, including to notify you of changes to the Services, send you information and updates pertaining to the Services you have availed, and to receive occasional company news and updates relating to us or the Services;
  9. To assist you with the facilitation of the Services offered to you, including to send you information and updates about the Services you have availed;
  10. To market and advertise the Services to you;
  11. To comply with legal obligations;
  12. To administer and protect our business and the Services, including for troubleshooting, data analysis, system testing, and performing internal operations;
  13. To improve our business and delivery models;
  14. To perform our obligations that arise out of the arrangement we are about to enter into or have entered into with you;
  15. To enforce our Terms; and
  16. To respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims.

a. You agree and acknowledge that by using our Services and using the Website, you authorize us, our employees, professionals, Vendors, and affiliates to contact you via email, phone, or otherwise. This is to provide the Services to you and ensure that you are aware of all the features of the Services and for related purposes.

b. You agree and acknowledge that any and all information pertaining to you, whether or not you directly provided to us, including but not limited to personal correspondence such as emails, instructions from you, etc., may be collected, compiled, and shared by us with relevant third-parties in order to render the Services to you. This may include but not be limited to Vendors and other professionals, who provide or seek to provide to you the Services.

c. You agree and acknowledge that we may share data with your consent, when it is required by law or by any court or government agency or authority to disclose such information. Such disclosures are made in good faith and belief that it is reasonably necessary to do so for enforcing this Policy or the Terms, or in order to comply with any applicable laws and regulations.

COOKIES

. Cookies are small files that a site or its service provider transfers to your device’s hard drive (if you permit it to) through your web browser that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information.

a. We use cookies to help us distinguish you from other users of the Website, understand and save your preferences for future visits, keep track of advertisements, and compile aggregate data about site traffic and site interaction so that we can offer you a seamless user experience. We may contact third party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

b. Additionally, you may encounter cookies or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties. If you send us personal correspondence, such as emails, or if other users for third parties send us correspondence about your activities or postings on the Website, we may collect such information within a file specific to you.

DISCLOSURES OF YOUR PERSONAL DATA

. We may share your personal data with third parties set out below for the purposes set out in Clause 4 above:

1. 1. Service professionals to enable them to provide you the Services;
  2. External third parties such as:
    - Trusted third parties such as our associate partners, Vendors, and service providers that provide Services for us or on our behalf. This includes hosting and operating our Website, providing marketing assistance, conducting our business, processing payments, and transaction related processes, transmitting content, and providing our Services to you;
    - Analytics service providers and advertising networks that conduct web analytics for us to help improve the Website. These analytics providers may use cookies and other technologies to perform their services; and
    - Regulators and other bodies as required by law or regulation.

a. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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 instructions.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

. Access and Updating your Personal Data: You hereby warrant that all personal data that you provide us is accurate, up to date, and true. When you use our Services, we make the best efforts to provide you with the ability to access and correct inaccurate or deficient data, subject to any legal requirements.

a. Opting-out of Marketing and Promotional Communications: When we send you marketing and promotional content through email, we make best efforts to provide you with the ability to opt-out of such communications by using the opt-out instructions provided in such emails. You understand and acknowledge that it may take us up to 10 business days to give effect to your opt-out request. Please note that we may still send you emails about your account and or any Services you have requested or received from us.

TRANSFERS OF YOUR PERSONAL DATA

. We comply with applicable laws in respect of storage and transfers of personal data. As a part of your use of the Services, the information and personal data you provide to us may be transferred to and stored in countries other than the country you are based in. This may happen if any of our servers are from time to time located in a country other than the one you are based in, or one of our Vendors, partners, or service providers is located in a country other than the one you are based in.

a. By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data in the manner described above.

DATA SECURITY

. We implement appropriate security measures and privacy protective features on our Website including encryption, password protection, and physical security measures to protect your personal data from unauthorized access and disclosure, and follow standards prescribed by applicable law.

a. Where you have chosen a password that enables you to access certain parts of the Services, you are responsible for keeping this password secret and confidential. We will not be responsible for any unauthorized use of your information, or for any lost, stolen, or compromised passwords, or for any activity on your user account due to such unauthorized disclosure of your password. In the event your password has been compromised in any manner whatsoever, you should promptly notify us to enable us to initiate a change of password.

DATA RETENTION

0. You agree and acknowledge that your personal data will continue to be stored and retained by us for as long as necessary to fulfil our stated purposes and for a reasonable period of time after the termination of your account on the Website or access to the Services to comply with our legal rights and obligations.

1. In some circumstances, we may aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

BUSINESS TRANSITIONS

You agree and acknowledge that in the event we go through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

UPDATES TO THIS POLICY

. We may occasionally update this Policy. If we make changes to this policy, we will upload the revised Policy on the website or share it with you through other means, such as email. To the extent permitted under applicable law, by using our website after such notice, you consent to updates made to this Policy.

a. We encourage you to periodically review this Policy for the latest information on our privacy practices.

GRIEVANCE OFFICER

If you have any questions about this Policy, how we process or handle your personal data, or otherwise, you may reach out to us, with your queries, grievances, feedback, and comments at support@nraitservices.org or contact our grievance officer whose contact details are provided below:

Grievance Officer
Name	Designation	Email
Anubhav Gupta	CEO	A.gupta@nraitservices.org

SPECIAL PROVISIONS FOR USERS IN TERRITORIES OUTSIDE INDIA

. As far as permissible under applicable law, you hereby consent to the laws of India being applicable in governing this Policy.

a. Certain privacy laws around the world, including the European General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”), provide users with rights related to their personal information. Consistent with those laws, we give you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.

1. 1. Right to Access & Portability: You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used.
  2. Right to Correction: You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
  3. Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
  4. , Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of NRA IT Services.
  5. Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
  6. Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.

b. The CCPA provides California residents with the following additional rights:

1. 1. Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
  2. Right to Opt-Out: To the extent that we “sell” personal information (as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time.
  3. If you would like to manage, change, limit, or delete your personal information, you can do so by contacting us by submitting a message through support@nraitservices.org. Once you contact us to exercise any of your rights, we will confirm receipt of your request.
  4. Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you Services, providing you with a different level or quality of Services, or charging you different prices or rates for Services. We will respond to your request within a reasonable timeframe.
  5. Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorised agent to make a request on your behalf. In order to designate an authorised agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorised agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.
  6. Additional Disclosures for California Residents
    - Notice of Collection
      1. In addition to the above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. The categories of personal information that we have collected – as described by the CCPA – are:
      2. Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.
      3. Demographics, such as your age or gender, or, where you have provided such information to us voluntarily, demographic information about your race, ethnicity, sexual orientation, or gender identity, provided in relation to specific marketing and advocacy projects and campaigns. This category includes data that may qualify as protected classifications under other California or US federal laws.
      4. Commercial information, including purchases and engagement with the Services.
      5. Internet activity, including your interactions with our Services and what led you to our Services.
      6. Sensory visual data, such as pictures posted on our Service.
      7. Geolocation data provided through location enabled services such as Wi-Fi and GPS.
      8. Inferences, including information about your interests, preferences, and favourites.
    - The Purposes for Our Collection

We collect and use these categories of personal information for our business and commercial purposes, including providing and improving the Services, maintaining the safety and security of the Services, processing transactions, and for advertising and marketing services

1. 1. - Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)

We do not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses described in the “Information Uses, Sharing and Disclosure” Section above, we will comply with applicable law as to those activities.

To opt-out of receiving interest-based advertising, please contact us.

1. 1. - Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.

1. 1. - Shine the Light

California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. NRA IT Services does not share any personal information to third parties for their own direct marketing purposes.

1. 1. - Accessibility

If you have a disability and would like to access this policy in an alternative format, please contact us.

c. GDPR: This sub clause applies only to users from the European Union/ European Economic Area. The EU GDPR requires a legal basis for our processing of personal information. Our legal basis depends on the respective purpose of the data processing. We rely on:

1. 1. Performing a contract when we provide you with our Services or communicate with you about it. This includes processing your personal information to accept and process orders, deliver Services, and process payments.
  2. Our legitimate business interests and the interests of our customers when we improve our Services, when we detect and prevent fraud or abuse, to protect the safety of our users, our own safety, and that of third parties, and when we display interest-based advertising to you.
  3. Your consent: When we ask you for your consent to the processing of your personal information for a specific purpose communicated to you. If you consent to the processing of your personal information by us for a specific purpose, you can withdraw your consent at any time, and we will no longer process your data for that purpose.
  4. Legal obligations: When we process your personal information to comply with a legal obligation. For example, we collect the users’ registered office and account data for the purpose of proof of identity.
  5. These and other legal bases, depending on the purpose for which we use personal information.

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