We, LegalCraft Solutions Pvt. Ltd., a private limited company registered under the Companies Act, 1956 with its registered office on the third floor, 8-2-293/82/A/240, Road No. 36, Jubilee Hills Hyderabad, Telangana, India- 500033 (hereinafter referred to as the “Company”, “our”, “us ” or “we”), take the privacy of users and/or individuals (hereinafter referred to as “you”, “your” and “User”) of Aekam and Kalsy accessing our website and/or application (hereinafter referred to as the “Platform”)a priority and take all steps to ensure Data (defined below) and information pertaining to you is secure and protected.
This privacy policy (hereinafter referred to as “Policy”) governs your interaction with the services provided on the Platform (hereinafter referred to as “Service(s)”) and is designed to help you understand what Data we collect, why we collect such Data, how we store and use the Data and what rights you have with respect to the Data collected.
By accessing and using our Services, you hereby accept and agree to abide by the terms of this Policy.
The Company and the User shall, hereinafter be individually referred to as “Party” and collectively referred to as “Parties”.
Terms that have not been defined herein, but are capitalized shall have the same meaning as attributed to them under the Terms of Use of the Platform.
1.1. Applicable Laws: shall mean and include all statutes, enactments, including but not limited to General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA) and Australian Privacy Principles (APP), acts of legislature or parliament, ordinances, rules, bye-laws, regulations, notifications, guidelines, policies, directions, directives and orders, requirement or other governmental restrictions or any similar form of a decision of, or determination by, or any interpretation, policy or administration of, any government, statutory authority, tribunal, board, court having jurisdiction over the matter in question.
1.2. Data: shall mean the data and information collected by us, including but not limited to Personal, sensitive and/or system data and information, whether or not by automated means, through the Platform which directly or indirectly relates to you and may be subjected to Processing in accordance with this Policy.
1.3. Personal Data: shall mean any data and/or information, including sensitive data, relating to an identified or identifiable natural person, whereby an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
1.4. Process/Processing/Processed: shall mean operation or set of operations performed on the Data or on sets of Data, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, use, alignment or combination, indexing, disclosure by transmission, dissemination or otherwise making available, restriction, erasure or destruction of Data.
2.1. By using our Services and accessing our Platform, you hereby expressly consent to the collection, Processing, storing, disclosing and handling of all your Data, in accordance with the terms of this Policy.
2.2. By your submission of Data, you hereby acknowledge that such submission was consensual and informed on your part and you shall not claim or raise any issue before an authority with competent jurisdiction under the Applicable Law, contesting the same.
2.3. In the event you wish to withdraw your consent regarding Processing of your Data and the terms of this Policy, you may do so by contacting our grievance data officer provided under this Policy. Upon withdrawal of consent, we shall delete your Data, subject to the exceptions laid down under this Policy.
2.4. You hereby understand that such withdrawal may result in the partial or complete termination of your access to our Platform and Services.
3.1. Depending on the Services you use on our Platform, We collect the following Data from you to enable us to provide the Services effectively:
3.2.1. At registration:
3.2.1.1. Name;
3.2.1.2. Date of birth;
3.2.1.3. E-Mail ID;
3.2.1.4. Location;
3.2.1.5. Interests;
3.2.1.6. Images; as profile picture
3.2.1.7. Government issued identification
When you use our Platform and/or avail our Services, we automatically collect Data, which includes but is not limited to; cookie Data (kindly refer to the section titled “Cookie Data” for more information), Platform usage data, Service usage Data, any comments, opinions, feedback and other communications with us or directed at us which you provide through the Platform, posts, technical information about your device for system administration and analysis, including your IP address, unique device identifiers, software version, service provider, operating system, network and browser type, information about how you use the Platform, and such other information that may be automatically collected as part of log files or other metadata.
3.4.1. In furtherance of provision of Services to you and to improve the efficiency of the same, we may obtain Data from third parties, where permitted under Applicable Law and through lawful means.
3.4.2. In consonance with the APP, where it is discovered that Data about you has been collected and/or received by us without our solicitation of the same, we undertake to destroy such Data or ensure that it is de‑identified as soon as practicable and only if it is lawful and reasonable to do so.
3.4.3. In consonance with the GDPR, in the event we obtain Data about you from a third party, we shall provide you the following information within 1 (One) month of us obtaining the same:
3.4.3.1. The purposes of the Processing, for which such Data are intended, as well as the legal basis for and duration of the Processing;
3.4.3.2. The categories of such Data;
3.4.3.3. The recipients or categories of recipients of such data, if any;
3.4.3.4. If we intend to transfer such Data to a recipient in a third country or international organization, reference to the appropriate or suitable safeguards and the means to obtain a copy of them or where they have been made available.
3.4.3.5. The source of obtaining such Data originate, and if applicable, whether it came from publicly accessible sources;
3.4.3.6. Your rights over such Data;
4.1. We collect Data from you, solely for the purposes enumerated herein and do not Process any of your Data in a manner or for a purpose not provided for in this Policy.
4.2.2. To provide third party advertisers and marketers,in accordance with this Policy (kindly refer to the section titled “Advertising and marketing” for more information);
4.2.3. In the case of government-issued identification, we solely Process it for the purposes of verification of the identity of Users
4.2.4. To develop, provide and improve the quality of our Services and/or Platform;
4.2.5. We use your registration Data to create your account on our Platform, to send out alerts, notifications and nudges and to provide you with our Service;
4.2.6. To send you information and promotional materials about our Services;
4.2.7. To respond to support requests;
4.2.8. In compliance with regulatory requirements for the maintenance of records;
4.2.9. To conduct internal reviews of our Platform to help us better understand the use of our Platform;
4.2.10. To protect the security and integrity of our Platform;
4.2.11. In compliance with court orders and legal process, and to enforce our Terms and this Policy;
4.2.12. Any other legal, business or marketing purposes that are consistent with this Policy and strictly on a confidential basis;
4.3. We hereby undertake that we collect only such Data that is necessary for providing you access to our Platform and for rendering our Services to you and do not collect any other Data for any other purpose not specified in this Policy.
5.1.1. Service providers and Advertisers:
5.1.1.1. We may share your Data with our authorized third-party distributors, vendors, suppliers and other service providers who provide services to us or on our behalf, such as operating and supporting the Platform, performing marketing or consulting services, and assisting us with the preparation and mailing of our business and marketing communications and with Processing and fulfillment functions strictly on confidential terms, as reasonably necessary, for the purposes set out in this Policy.
5.1.2.1. We may share your Data with our advertising and analytics partners to understand your behavior, improve existing and/or develop new features.
5.1.2.2. The privacy policy of these third-party companies applies to their Processing of your Data. These third parties may combine your Data with the Data of other consumers for purposes of conducting these studies and/or analytics.
5.1.2.3. We may provide our advertisers or advertising partners with a compilation of your Data that has been obtained from the multiple sources stated hereinabove. We may also Process such compilation to help advertisers reach the kind of audience they want to target.
5.1.4.2. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the Processing of all transferred Data will be subject to this Policy. However, any Data you submit or that is collected after this type of transfer, may be subject to a new privacy policy adopted by the successor entity. You retain the right to restrict the transfer of yourData upon being intimated of the same, however, we wish to inform you that such restriction may result in restriction of the use of the Platform by you.
5.1.3.1. We may share some or all of your Data with our subsidiaries and corporate affiliates, joint ventures, or other companies that are or may come under common control with us. We will require these entities to comply with the terms of this Policy with regard to their Processing of your Data.
5.1.4.1. In the event of a merger, acquisition, reorganization, bankruptcy or other sales of all or a portion of our assets, any Data owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign theData we may have collected about you from thePlatform to third parties.
5.1.5.1. We may disclose your Data as may be legally required in the event of any requirement by court order, government or to any extent required by the Applicable Law or legal proceedings to the appropriate authority in order to comply with the rules and regulations.
5.1.5.2. We shall neither assume any liability nor indemnify you for any loss, damages or expenses incurred by you due to the compulsory disclosure of your Data by us.
5.2. As a requirement under the APP, we hereby declare that we disclose your Data to third parties operating outside Australia for reasons mentioned herein under this Policy, in the following countries:
5.3. We hereby warrant that we have undertaken all reasonable measures, contractual or otherwise, to ensure the third parties we disclose your Data to secure, protect and Process your Data in compliance with the Applicable Laws.
6.1. We have undertaken all reasonable precautions, measures and efforts to protect and keep safe any and all Data pertaining to you. Your Data is safely protected and stored on a cloud based server owned by Google. You hereby understand that the terms of use and privacy policy of such cloud based server, and not this Policy, shall be applicable to the storage of your Data. We suggest that you read such applicable policies to understand the same.
6.2. While we have undertaken all reasonable efforts to safeguard your Data to the acceptable industry standard, no safety measure is foolproof and 100% secure. We provide no guarantee of security of your Data and thus, shall not be responsible for any breach of security in respect of the same, in case of events outside our control, including but not limited to, earthquake, cyclone, tsunami and such natural disasters, as well as riots, acts of war, acts of terror, unauthorized computer attacks, system crashes, software or hardware defects beyond our control etc., and similar events, collectively classified as force majeure events.
6.3. In the event of a Data breach as a result of a force majeure event, you hereby waive any claim against us, our associates, affiliates, employees and/or directors for any losses and/or damages arising out of such breach.
6.4. We shall not be responsible for any breach of security or any other consequence owing to you clicking on any third-party advertiser or such other links that appear on our Platform. The privacy policy and terms of use of the relevant advertising partner or websites shall apply to all such transactions.
6.5. You hereby agree that you shall be solely and personally liable for the security and confidentiality of your account’s login credentials. We shall not be liable for any loss Data and/or damage as a consequence of your negligence with respect to your account’s login credentials.
6.6. The countries to which we transfer your Data may not have the same data protection laws as the country in which you initially provided such Data. If we transfer any Data provided by you, to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of Applicable Law; and (ii) we will protect the transferred Data in accordance with this Policy.
6.7. In the event of a breach, we undertake to inform you of the same via the e-mail ID provided by you within 72 (Seventy Two) hours of such breach or earlier, if possible.
7.1. We store Data of Users for as long as required to fulfill its purpose. Upon the fulfillment of its purpose, we purge such Data. However, we shall retain any Data of Users where permissible and/or required under the Applicable Law.
7.2. Any encrypted, anonymized and/ or aggregated Data may be retained by us for the purposes of backup, archiving, prevention of fraud and abuse, analytics, to improve our Services, Platform or for such other reasons that we deem necessary to retain the same.
7.3. Notwithstanding anything contained hereinbefore, we shall retain and use the Data Processed as necessary to resolve disputes, enforce our agreements and comply with legal obligations for such a period thereafter as required under the Applicable Law for the time being in force.
8.1. As a User of our Services, you shall be entitled to certain rights depending upon the jurisdiction you are based out of. If you are subjected to the provisions of the General Data Protection Regulation (“GDPR”), you shall be permitted to exercise the following rights (“GDPR Rights”):
8.1.1. Right of access:
You shall have the right to obtain from us confirmation as to whether or not your Data is being Processed, and, where that is the case, an electronic copy of such Data (additional copies may be demanded upon payment of an administrative charge) and the following information:
8.1.1.1. The purposes of the Processing;
8.1.1.2. The categories of Data concerned;
8.1.1.3. The recipients or categories of recipients to whom the Data have been or will be disclosed, in particular recipients in third countries or international organizations;
8.1.1.4. Where possible, the envisaged period for which the Data will be Processed, or, if not possible, the criteria used to determine that period;
8.1.1.5. Where the Data is not collected from you, any available information as to their source;
8.1.1.6. In the event of automated decision-making, including profiling, you shall have the right to know any meaningful information about the logic involved, the significance and the envisaged consequences of such Processing of your Data.
8.1.1.7. If your Data is transferred to a third country or to an international organization, you shall have the right to be informed of the appropriate safeguards undertaken for the security of such Data.
8.1.2. Right of rectification:
You shall have the right to request us for the correction of your inaccurate Data Processed by us. In order to keep your details up to date, we request you personally edit your details. We do not warrant the accuracy of your Data and thus it is your responsibility to inform us and rectify any inaccuracies in your Data.
Where you have exercised this right to rectify any inaccurate or false Data of yours, we shall accordingly inform all third parties receiving your Data from us about the rectification made.
8.1.3. Right of erasure:
You shall have the right to direct us to delete permanently any Data of yours, provided that such deletion falls under one of the following grounds:
8.1.3.1. The Data is no longer necessary in relation to the purposes for which they were collected or otherwise Processed
8.1.3.2. You withdraw consent on the basis of which the Processing is undertaken by us;
8.1.3.3. You exercise your right to object as provided herein below and there are no overriding legitimate grounds for the Processing,
You shall have the right to object, on grounds relating to your particular situation, at any time, to the Processing of your Data, including profiling in the event Processing of your Data is undertaken for any of the following reasons:
8.1.3.4. Your Data has been unlawfully Processed;
8.1.3.5. Your Data has to be erased in compliance with a legal obligation under Applicable Laws;
Kindly refer to the link provided hereinbelow for information on the restrictions under GDPR to availing this right.
8.1.4. Right of limitation of Processing:
You shall have the right to direct us to restrict the Processing of your Data in the event of one of the following cases:
8.1.4.1. The accuracy of your Data is contested by you. Such Data shall, with the exception of storage, only be Processed in the following cases:
8.1.4.2. Where the Processing is unlawful and you exercise the right herein instead of erasure of the Data;
8.1.4.3. We no longer need the Data for the purposes of the Processing, but such Data is required by you for the establishment, exercise or defense of legal claims;
8.1.4.4. You have exercised your right to object (provided hereinbelow), pending the verification of whether our legitimate grounds of Processing override your right to object.
In the event the restriction on Processing has been lifted, we shall inform you before Processing your Data.
8.1.5. Right of transmission of the Data:
Where you have explicitly consented the Processing of your Data and such Processing is undertaken using automated means, you shall have the right to receive such Data in a conventional, structured and machine-readable form and further have the right to transmit such Data to a different controller directly through us (if feasible). The right herein shall be without prejudice to the right of erasure and shall not be executed where Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
8.1.6. Right of retracting one’s authorization:
If the Processing of Data is based on an authorization basis, you have the right to retract your authorization at any given time. You can do so by cancelling your account, or contacting our grievance protection officer. You hereby accept that upon retraction of your authorization, your access to our Platform and Services may be restricted or terminated.
8.1.7. Right of objection:
You shall have the right to object, on grounds relating to your particular situation, at any time, to the Processing of your Data, including profiling in the event Processing of your Data is undertaken for any of the following reasons:
8.1.7.1. For a task carried out in the public interest;
8.1.7.2. For the exercise of official authority;
8.1.7.3. For their legitimate interests;
8.1.7.4. For scientific or historical research, or statistical purposes; or
8.1.7.5. For direct marketing purposes.
We shall no longer Process your Data, unless we have compelling legitimate grounds for such Processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
If you wish to object to Processing of your Data for direct marketing purposes, you may do so by using the link on the homepage or settings on our Platform.
8.1.8. For more information on GDPR Rights, kindly visit https://gdpr-info.eu/
8.2. If you are subject to the provisions of the California Consumer Privacy Act (“CCPA”), you shall be entitled to the following rights (“CCPA Rights”) (Kindly note that you shall be entitled to exercise those GDPR Rights, which are available under the CCPA as well) :
8.2.1. Right to opt out of the sale of Data to third parties:
You shall be entitled to opt-out of the sale of your Data to third parties. In order to do so, kindly use the link on the homepage or in the settings (as the case may be) of our Platform.
8.2.2. Right against non-discrimination:
You are entitled to not be discriminated against, with respect to the denial of Services, price discrimination or a different level or quality of Services (as the case may be) because of your decision to exercise your rights under the CCPA
8.2.3. If you are eligible to exercise the rights provided under CCPA, you may do so by either contacting the grievance protection officer via the details provided herein or exercise the rights by sending us an email at aekamapp1@gmail.com
8.2.4. For more information on CCPA Rights, kindly visit
8.3. If you are subject to the provisions of the Australian Privacy Principles under the Australian Privacy Act, 1988 (“APP”), you shall be entitled to the following rights (“APP Rights”) (Kindly note that you shall be entitled to exercise those GDPR and CCPA Rights, which are available under the APP as well):
8.3.1. Right to access our Policy:
You shall have the right to request from us, our Policy in a particular form, in which case we shall take reasonable steps to you a copy in that form.
8.3.2. Right to anonymity and pseudonymity:
You shall have the option to not identify yourself, or use a pseudonym when availing our Services, unless;
8.3.2.1. We are required or authorized by or under Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or
8.3.2.2. It is impracticable for us to deal with your non-identification or pseudonymity.
8.3.3. Right and limitations to access:
8.3.3.1. Similar to the right to access provided under the GDPR Rights, you shall have the right to seek access to your Data. However, under the APP Rights, this access shall be denied by us if any of the following conditions are fulfilled:
8.3.3.2. Where you have been denied access to your Data as a consequence of one or more of the conditions hereinabove being applicable to such request, we shall be obliged to provide a written notice that sets out:
8.3.4. Right and limitation to rectification:
8.3.4.1. Similar to the right to rectification provided under the GDPR Rights, you shall have the right to seek rectification of your Data. However, under the APP Rights, this right may be denied by us, in which event, we are obliged to give you a written notice that sets out:
8.3.4.2. In the event we deny you the right to rectify your Data, you may, alternatively, direct us to associate a statement with such Data, informing any party to whom the Data is disclosed, regarding its inaccuracy and/or irrelevancy. Upon receiving such directive, we shall be obliged to take such steps as are reasonable to associate the statement in such a way that will make the statement apparent to the third parties to whom your Data is disclosed.
8.3.5. For more information on APP Rights, kindly visit
https://www.legislation.gov.au/Details/C2021C00452
9.1. Cookies are small text files that are stored on the device you use to access our Platform. These cookies allow for a better user experience by saving your language and other preferences by Processing Data on how our Platform was accessed. We Process cookie information and Data to improve the Platform's general performance.
9.2. Data that may be collected by cookies and web beacons when you use the Platform and/or Platform may include, without limitation:
9.2.1. web pages you visit;
9.2.2. date and time of your visit to or use of the Platform;
9.2.3. usage and activity Data related to the Platform;
9.2.4. websites you visit before or after visiting the Platform;
9.2.5. browser type;
9.2.6. Internet Protocol (IP) address used to connect your computer or mobile device to the Internet; and
9.2.7. your computer or mobile device and connection information, such as your browser type and version, operating system, and platform.
9.3. Types of cookies used:
To improve our Services and Platform and in turn your experience on the same, we Process the following cookies:
9.3.1. Strictly necessary cookies:
These cookies are essential in order to enable you to fully access the Platform and to use the linked features. These cookies do not identify you as an individual. By refusing to accept these cookies, several features within the Platform will be (partially) disrupted.
9.3.2. Functionality cookies:
These cookies enhance the Platform's user-friendliness by remembering your choices (e.g. language preference). These ensure that certain settings are customized upon your request. If you refuse to accept these cookies, this may affect the Platform's performance and functionality and can limit your access to the Platform's content.
9.3.3. Performance/Analytical cookies:
These cookies collect Data about a Platform's use, such as the number of visitors, the time visitors spend on certain pages and possible error messages. These cookies do not identify you as an individual but help us to improve your browsing experience.
9.4. Manage your cookie Data:
You can restrict functionality and performance/analytical cookie Data by changing your browser or application settings accordingly.
10.1. In the event you wish to stop such disclosure to third party advertisers and/or markets, kindly visit our Platform’s homepage or settings (as the case may be) and opt out from the sale of your Data by using the link provided.
10.2. You hereby understand that we do not control or dictate the content received and/or displayed to you by third party advertisers and marketers and thus are neither liable nor responsible for the same. Any complaints, queries, requests and/or communications regarding the same should be directed to the third party advertisers and marketers.
11.1. The User hereby understands that the Platform may contain some links to third party websites and/or services that are not owned or controlled by us, including but not limited to the payment Processing service by the designated third party payment Processor. Notwithstanding anything contained hereinabove, the User specifically agrees that they shall be bound by the terms and conditions and privacy policy of such third-parties and we shall in no manner whatsoever be held liable for these policies or any loss that you may incur as a result of such policies implemented by such third-parties.
11.2. The User also understands that their payment information and credentials used to avail our marketplace Services are directly provided to the designated third party payment Processors without our involvement. Such payment data is thus subject to the privacy policy of the third party payment processor.
12.1. We hereby represent and warrant that:
12.1.1. We have Processed your Data in accordance with your instruction and/or the Applicable Law.
12.1.2. All Data collected from you has been Processed for a legitimate business purpose.
12.1.3. We have taken such steps (if any) as reasonably required to ensure that your Data is accurate, up‑to‑date and complete.
12.2. You, the User, upon the usage of our Platform and/or Services hereby warrants that:
12.2.1. You have voluntarily consented to the Processing of your Data by us and third parties listed herein.
12.2.2. You have read and understood the terms of this Policy and hereby understand your rights, obligations and usage of your Data.
12.2.3. You have voluntarily set preferences provided for on the homepage or in the settings of our Platform and shall undertake all reasonable efforts to inform any changes in the same, either through the mechanisms on the Platform and/or contact information provided below.
12.2.4. You shall update and correct, as and when required, your Data and not hold us, our associates, affiliates, employee and/or directors liable for any loss and/or damage as a consequence of any inaccuracy or error in your Data.
13.1. The Policy may be amended from time to time. We shall notify you of the same via displaying a message on the Platform.
13.2. We will not require your consent to change, amend or modify this Policy and your continuing to access the Platform will constitute your consent to such new terms and conditions of this Policy.
14.1. The Data that you provide to us, and store, publish and share through the Platform as a part of the Service, will continue to belong to you. We shall not have access to such Data, nor have any rights of ownership, assignment, transfer etc., in respect of such Data.
14.2. However, you hereby grant us a worldwide, sub-licensable, transferable, absolute and royalty-free right to store electronically, use, publish and modify any content you publically publish on our Platform.
15.1. The Platform is not intended for Users younger than the age of 18. We do not knowingly Process Data from Users under the age of 18 without verifiable parental consent. If we become aware that a User, under the age of 18 has submitted any Data without verifiable parental consent, we will remove his or her Data from our files.
15.2. If you believe we have Processed any Data of a person below the prescribed age limit, you may contact us via the contact details provided herein under this Policy and such Data shall be removed accordingly.
16. Contact:
If you have any questions about this Policy, or our Processing of the Data we collect from you in connection with the Platform, email us at: aekamapp1@gmail.com
17. Grievance data officer:
If you have any grievances or find any discrepancies, please contact us through the details given below and we shall make every effort to resolve your concerns expeditiously:
Name of grievance officer:
Email Address:
Contact Number:
18. CCPA ‘Lookback’ disclosures:
Kindly note that this disclosure is made under the CCPA and for the sole benefit of Users, to whom the CCPA applies.
18.1. Pursuant to Sections 1798.130(a)(5)(B) and 130(a)(5)(C) of the CCPA, we are mandated to disclose the categories of Data that has been collected, sold and disclosed (for business purposes) in the immediately preceding 12 (Twelve) month period. In light of the same, please find below the list of categories of Data that has been collected, sold and disclosed (for business purposes) by us in the last 12 (Twelve) months:
18.2. In order to ascertain to which third parties, we have disclosed your Data, kindly refer to the section titled “third party disclosures”.
© 2021 Aekam ALL RIGHTS RESERVED