Effective as of May 2018
We Care About Your Privacy
RKTPL , including its affiliates, is committed to respecting your privacy and to complying with applicable data privacy laws. This privacy statement (“Statement”) describes how we collect and use personal data where RKTPL is the data controller or where we refer to the applicability of this Statement. “Personal data” means information about you or another identifiable individual.
We may give you additional privacy information that is specific to a product or service in Supplements to this Statement and other notices you may see while using our products or services. If there is a difference between such notices and this Statement, the notices should be considered first.
Software on your device may access your information. Our products or services may contain links to other companies’ websites and services that have privacy notices of their own. RKTPL is not responsible for the privacy practices of others and we recommend you read their privacy notices.
This Statement does not apply to RKTPL licensed products and services (such as RKTPL branded phones and tablets). Please consult the relevant licensee’s own privacy policies regarding these products and services.
You are not required to provide personal data to RKTPL. However, if you choose not to provide your personal data to RKTPL, we may not be able to provide you with our products or services or all of their functionalities or to respond to queries you have.
What Information Do We Collect?
We collect your personal data and other information when you make a purchase, use or register into our products and services, take part in campaigns or research or otherwise interact with us. This includes the following categories:
- Product and service activations: RKTPL products and services may require electronic activation, where your device and application type, as well as unique device, application, network and subscription identifiers are sent to RKTPL.
- Use of products and services: When you access our services online, our web servers automatically create records of your visit. These records typically include IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information. Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected.
- Information you provide us with: When you create an account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, user names and passwords, feedback, information relating to your devices, age, gender, and language, bank account number, credit card details and other such financial information. We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data.
- Your transactions with us: We maintain records of your purchases, downloads, the content you have provided us with, your requests, agreements between you and RKTPL, the products and services provided to you, payment and delivery details, as well as your interactions with us. We may, in accordance with applicable law, record your communication with our customer care team or with other such contact points.
- Positioning and Location data: Location-based services establish location using satellite, mobile, Wi-Fi or other network based positioning methods. These technologies may involve sharing your location data and unique device and mobile, Wi-Fi or other network related identifiers with RKTPL. Our products may operate on multiple device platforms, applications and services which may also collect your location data. We do not use this information to identify you personally without your consent.
Why Do We Process Personal Data?
RKTPL may process your personal data for the following purposes. One or more purposes may apply simultaneously.
- Providing products and services: We may use your personal data in order to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and RKTPL, to ensure the functionality and security of our products and services, to identify you in order to provide the product or service as well as to prevent and investigate fraud and other misuses.
- Accounts: Some services may require an account to help you manage your content and preferences.
- Developing and managing products and services: We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular RKTPL product and/or service with other personal data that we may have about you, unless such personal data was collected for a different purpose.
- Communicating with you: We may use your personal data to communicate with you, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.
- Marketing, advertising and making recommendations: We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying RKTPL and third-party content.
RKTPL processes your personal data with your consent or as necessary to complete any transaction or provide any product or service you have requested or authorized. We may also process your personal data when required by law; to protect our customers; to maintain the security of our products and services; and to protect rights and property of RKTPL.
Do We Share Personal Data?
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.
- Your consent and social sharing services: We may share your personal data if we have your consent to do so. Some products and services may allow you to share your personal data with other users of the product or service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.
- RKTPL companies and authorized third parties: We may share your personal data with other RKTPL companies or authorized third parties who process personal data for RKTPL for the purposes described in this Statement. This may include for example billing through your network service provider or otherwise, delivery of your purchases, providing services including customer service, managing and analyzing consumer data, credit checks, conducting research and managing marketing and other such campaigns.We may conduct joint marketing and other communications with our authorized third-party partners. To avoid duplication of or unnecessary communications and to tailor the message to you we may need to match information that RKTPL has collected with information that the partner has collected where this is permitted by law.These RKTPL authorized third parties are not permitted to use your personal data for any other purposes. We require them to act consistently with this Statement and to use appropriate security measures to protect your personal data.
- International transfers of personal data: Our products and services may be provided using resources and servers located in various countries around the world. Therefore, your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection. In such cases we use measures to provide adequate protection for your personal data as required by applicable law, for example, by using standard agreements approved by relevant authorities (e.g. the European Commission) and by requiring the use of appropriate technical and organizational information security measures.
- Mandatory disclosures: We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend RKTPL’s legitimate interests, for example, in civil or criminal legal proceedings.
- Mergers and Acquisitions: If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.
How Do We Address the Privacy of Children?
RKTPL products and services are typically intended for general audiences. RKTPL does not knowingly collect information of children under the age of 13, or equivalent minimum age under applicable law, without the consent of their parents or guardians.
How Do We Address Data Quality?
We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data. We will only retain your personal data for as long as necessary to fulfill the purposes outlined in this Statement or otherwise communicated to you, unless a longer period is required by law.
We encourage you to access your personal data through your account from time to time to help us ensure that it is up to date.
What Steps Are Taken to Safeguard Personal Data?
Privacy and security are key considerations in the creation and delivery of our products and services. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our databases containing personal data to authorized persons having a justified need to access such information.
Our domains may include third party elements that set cookies on behalf of a third party, for example relating to third party social network.
What Are Your Rights?
You have the following rights regarding personal data that RKTPL processes about you:
- Access: You have a right to know what personal data we hold about you and to obtain a copy.
- Data portability: Subject to law, you have a right to obtain in machine readable format the personal data you have provided to RKTPL.
- Rectification and erasure: You have a right to have incomplete, incorrect, unnecessary or outdated personal data about you deleted or updated.
- Withdraw your consent: You have a right to withdraw your consent for RKTPL to process your personal data.
- Unsubscribe and object: You have a right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or we delete your personal data on other grounds. Even if you opt-out from marketing and other communications from New Delhi-110047
India, critical alerts may still be sent to you.
You may exercise your rights by managing your account and choices through our products and services or, if that is not possible, by contacting us. In some cases, if you withdraw your consent or wish us to delete or stop processing your personal data we may not be able to continue to provide the services to you.
If you are not satisfied with what we provide when you exercise your rights, you can let us know by contacting us. If you are still dissatisfied, you also have the right to lodge a complaint with a relevant supervisory authority.
Who Is the Controller of Your Personal Data?
RKTPL is the controller of your personal data.
In addition, the RKTPL affiliate providing the product or service may be a controller of your personal data. You may find the identity of the controller and its contact details by reviewing the terms and conditions of such a product or service or by using contact information provided in the applicable RKTPL websites.
In matters pertaining to RKTPL’s privacy practices you may also contact us or our Group Data Protection Officer at:
RK Telesystem Private Limited c/o Privacy
Mani Mahal, 5th Floor,
Kalbadevi Road, Marine Lines (E),
Mumbai – 400 002
Changes to This Privacy Statement
RKTPL may change this Statement at any time with or without notice. However, if this Statement is changed in a material, adverse way, RKTPL will post a notice advising of such change at the beginning of this Statement and on this site’s home page for 30 days. We recommend that you re-visit this Statement from time to time to learn of any such changes to this Statement.