Privacy Policy
This Privacy Policy statement is made by My
Safe Box Solutions LLP (referred as “MSBS”, "we", "us" or
"our").
MSBS’s Privacy Commitment
We ask for only the least amount of
information necessary, gathering only what we believe is essential for doing
business, or for the specific transaction at hand. We let customers know the
information we have on them and allow them to opt out of specific engagements.
But, by far, our biggest commitment is that we do not make money from
advertising revenue—never have, never will—even from the free editions of our
products. This means we avoid the fundamental conflict of interest between
gathering customer information and fueling advertising revenue, and the
unavoidable compromises in customer privacy that it brings.
The goal of this policy is to make explicit the
information we gather, how we will use it, and how we will not. This policy is
unfortunately longer than we would like, but we must unambiguously address all
the relevant cases. We will try and keep the language simple and direct as much
as possible.
Scope of this Privacy Policy
This Privacy Policy applies to MSBS
websites only. It also applies to the products and services provided by MSBS
through these websites, our mobile applications, and applications posted by
MSBS on MSBS’s online marketplace and in other third-party online marketplaces.
This Privacy Policy does not apply to any of our websites, products or services
that have a separate privacy policy.
This Privacy Policy is divided into three
parts:
Part I –
Information MSBS collects and controls
This part deals with how MSBS collects and uses
information about website visitors, potential customers, users of MSBS's
products and services, and others who contact MSBS through forms or email
addresses published on or linked to our websites.
Part II –
Information that MSBS processes on your behalf
This part deals with how MSBS handles data that
you entrust to MSBS when you use our products and services, or when you share
any personal or confidential information with us while requesting customer
support.
Part III –
General
This part deals with topics that are relevant to
both Parts I and II, and other general topics such as MSBS's security
commitments and how we will inform you when we change this Privacy Policy.
Part I – Information MSBS
collects and controls
What information MSBS collects
We collect information about you only if we need
the information for some legitimate purpose. MSBS will have information about
you only if (a) you have provided the information yourself, (b) MSBS has
automatically collected the information, or (c) MSBS has obtained the
information from a third party. Below we describe the various scenarios that
fall under each of those three categories and the information collected in each
one.
Information that you provide us
i. Account
signup: When you sign up for an account to
access one or more of our services, we ask for information like your name,
contact number, email address etc. to complete the account signup process.
You will be required to use your email ID/phone
number as your username. You may also provide us with more information such as
your photo, time zone and language, but we don’t require that information to
sign up for an account. In order to complete the sign up, you will be sent an
OTP
(One Time Password) on your email id/phone number for authenticating and
accessing the created account.
ii. Event registrations and other
form
submissions: We
record information that you submit when you (i)
register for any event, including webinars or seminars, (ii) subscribe to our
newsletter or any other mailing list, (iii) submit a form in order to download
any product, whitepaper, or other materials, (iv) participate in contests or
respond to surveys, or (v) submit a form to request customer support, get a
quote or to contact MSBS for any other purpose.
iii. Payment processing: When
you choose to opt for a paid plan with us, we ask you to provide your name,
contact information, and credit card information or other payment account
information. When you submit your card information, we store the name and
address of the cardholder, the expiry date and the last four digits of the
credit card number. We do not store the actual credit card number. For quick
processing of future payments, if you have given us your approval, we may store
your credit card information or other payment information in an encrypted
format in the secured servers of our Payment Gateway Service Providers.
iv. Testimonials: When you authorize us to post
testimonials about our products and services on websites, we may include your
name and other personal information in the testimonial. You will be given an
opportunity to review and approve the testimonial before we post it. If you
wish to update or delete your testimonial, you can contact us at “operations@myesafebox.com”.
v. Interactions with MSBS : We may record, analyze and use your
interactions with us, including email, telephone, and chat conversations with
our sales and customer support professionals, for improving our interactions
with you and other customers.
Information that we collect automatically
i. Information from browsers,
devices and
server :
When you visit our websites, we collect information that web browsers, mobile
devices and servers make available, such as the internet protocol address,
browser type, language preference, time zone, referring URL, date and time of
access, operating system, mobile device manufacturer and mobile network
information. We include these in our log files to understand more about
visitors to our websites.
ii. Information
from cookies and tracking technologies: We use temporary and permanent cookies
to identify users of our services and to enhance user experience. We embed
unique identifiers in our downloadable products to track usage of the products.
We also use cookies, beacons, tags, scripts, and other similar technologies to
identify visitors, track website navigation, gather demographic information
about visitors and users, understand email campaign effectiveness and for
targeted visitor and user engagement by tracking your activities on our
websites. We mostly use first-party cookies and do not use third-party cookies
or other third-party tracking technologies on our websites for non-essential or
intrusive tracking. You can learn more about the cookies used on our websites.
We also use first-party Local Storage Objects (LSOs) such as HTML5 to store
content information and preferences to provide certain features.
iii. Information from application
logs and mobile
analytics: We collect information about your use of our products, services and
mobile applications from application logs and in-house usage analytics tools,
and use it to understand how your use and needs can improve our products. This
information includes clicks, scrolls, features accessed, access time and
frequency, errors generated, performance data, storage utilized, user settings
and configurations, and devices used to access and their locations.
Information that we collect from third parties
i. Signups
using federated authentication service providers: You can log in to MSBS Services using supported
federated authentication service providers such as LinkedIn, Microsoft and
Google. These services will authenticate your identity and give you the option
to share certain personal information with us, such as your name and email
address. The feature may be made available over time.
ii. Referrals: If someone has referred any of our
products or services to you through any of our referral programs, that person
may have provided us your name, email address and other personal information.
You may contact us at “operations@myesafebox.com” to
request that we remove your information from our database. If you provide us
information about another person, or if another person gives us your
information, we will only use that information for the specific reason for
which it was provided to us.
iii. Information from our
reselling partners and
service providers: If you contact any of our reselling partners, or
otherwise express interest in any of our products or services to them, the
reselling partner may pass your name, email address, company name and other
information to MSBS. If you register for or attend an event that is sponsored
by MSBS, the event organizer may share your information with us. MSBS may also
receive information about you from review sites if you comment on any review of
our products and services, and from other third-party service providers that we
engage for marketing our products and services.
iv. Information from social media
sites and
other publicly available sources: When you provide feedback or reviews about our
products, interact, or engage with us on marketplaces, review sites or social
media sites such as Facebook, Twitter, LinkedIn and Instagram through posts,
comments, questions and other interactions, we may collect such publicly
available
information, including profile information, to allow us to connect with you,
improve our products, better understand user reactions and issues, or to
reproduce and publish your feedback on our websites. We must tell you that once
collected, this information may remain with us even if you delete it from these
sites. MSBS may also add and update information about you, from other publicly
available sources.
Purposes for
using information
In addition to the purposes mentioned
above, we may use your information for the following purposes:
·
To
communicate with you (such as through email) about products that you have
downloaded and services that you have signed up for, changes to this Privacy
Policy, changes to the Terms of Service, or important notices;
·
To
keep you posted on new products and services, upcoming events, offers,
promotions and other information that we think will be of interest to you;
·
To
ask you to participate in surveys, or to solicit feedback on our products and
services;
·
To
set up and maintain your account, and to do all other things required for
providing our services;
·
To
understand how users use our products and services, to monitor and prevent
problems, and to improve our products and services;
·
To
provide customer support, and to analyze and improve our interactions with
customers;
·
To
detect and prevent fraudulent transactions and other illegal activities, to
report spam, and to protect the rights and interests of MSBS, MSBS’s users,
third parties and the public;
·
To
update, expand and analyze our records, identify new customers, and provide
products and services that may be of interest to you;
·
To
analyze trends, administer our websites, and track visitor navigations on our
websites to understand what visitors are looking for and to better help them;
·
To
monitor and improve marketing campaigns and make suggestions relevant to the
user.
Legal bases
for collecting and using information
Legal processing bases applicable to MSBS: Our legal basis for information
collection and use depends on the personal information concerned and the
context in which we collect it. Most of our information collection and
processing activities are typically based on (i)
contractual necessity, (ii) one or more legitimate interests of MSBS or a third
party that are not overridden by your data protection interests, or (iii) your
consent. Sometimes, we may be legally required to collect your information, or
may need your personal information to protect your vital interests or those of
another person.
Withdrawal of consent: Where we rely on your consent as the
legal basis, you have the right to withdraw your consent at any time, but this
will not affect any processing that has already taken place.
Legitimate interests notice: Where we rely on legitimate interests as
the legal basis and those legitimate interests are not specified above, we will
clearly explain to you what those legitimate interests are at the time that we
collect your information.
Your choice in
information use
Opt out of non-essential electronic communications: You may opt out of receiving newsletters
and other non-essential messages by using the ‘unsubscribe’ function included
in all such messages. However, you will continue to receive essential notices
and emails such as account notification emails (password change, renewal
reminders, etc.), security incident alerts, security and privacy update
notifications, and essential transactional and payment related emails.
Disable cookies: You can disable browser cookies before
visiting our websites. However, if you do so, you may not be able to use
certain features of the websites properly.
Optional information: You can choose not to provide optional
profile information such as your photo. You can also delete or change your
optional profile information. You can always choose not to fill in
non-mandatory fields when you submit any form linked to our websites.
Who we share
your information with
We do not sell
any personal information. We share your information only in the ways that are
described in this Privacy Policy, and only with parties who adopt appropriate
confidentiality and security measures.
Employees and independent contractors: Employees and independent contractors of
relevant MSBS group entities have access to the information covered in Part I
on a need-to-know basis. We require all employees and independent contractors
of MSBS group entities to follow this Privacy Policy for personal information
that we share with them.
Third-party service providers: We may need to share your personal
information and aggregated or de-identified information with third-party
service providers that we engage, such as marketing and advertising partners,
event organizers, web analytics providers and payment processors. These service
providers are authorized to use your personal information only as necessary to
provide these services to us.
Domain registrars: When you register a domain through MSBS
from domain name registrars, we share your name and contact information such as
your physical address, email address and phone number with them as per the
ICANN domain registration rules.
Reselling partners: We may share your personal information
with our authorized reselling partners in your region, solely for the purpose
of contacting you about products that you have downloaded or services that you
have signed up for. We will give you an option to opt out of continuing to work
with that partner.
Marketplace application developers: When you install or purchase any
application developed using MSBS's APIs that is posted on MSBS’s online
marketplace, your name and email address will be shared with the developer of
the application, so they may engage with you directly as the provider of that
application or service. MSBS does not control the use of your personal
information by the developers, which will be based on their own privacy
policies.
Other case: Other scenarios in which we may share
the same information covered under Parts I and II are described in Part III.
Your rights
with respect to information we hold about you as a controller
You have the following rights with
respect to information that MSBS holds about you. MSBS undertakes to provide
you the same rights no matter where you choose to live.
Right to access: You have the right to access (and obtain
a copy of, if required) the categories of personal information that we hold
about you, including the information's source, purpose and period of
processing, and the persons to whom the information is shared.
Right to rectification: You have the right to update the
information we hold about you or to rectify any inaccuracies. Based on the
purpose for which we use your information, you can instruct us to add
supplemental information about you in our database.
Right to erasure: You have the right to request that we
delete your personal information in certain circumstances, such as when it is
no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing: You may also have the right to request
to restrict the use of your information in certain circumstances, such as when
you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your
information to a third party in a structured, commonly used and
machine-readable format, in circumstances where the information is processed
with your consent or by automated means.
Right to object: You have the right to object to the use
of your information in certain circumstances, such as the use of your personal
information for direct marketing.
Right to complain: You have the right to complain to the
appropriate supervisory authority if you have any grievance against the way we
collect, use or share your information. This right may not be available to you
if there is no supervisory authority dealing with data protection in your
country.
Retention of information
We retain your personal information for as long
as it is required for the purposes stated in this Privacy Policy. Sometimes, we
may retain your information for longer periods as permitted or required by law,
such as to maintain suppression lists, prevent abuse, if required in connection
with a legal claim or proceeding, to enforce our agreements, for tax,
accounting, or to comply with other legal obligations. When we no longer have a
legitimate need to process your information, we will delete or anonymize your
information from our active databases. We will also securely store the
information and isolate it from further processing on backup discs until
deletion is possible.
Part II – Information that MSBS processes on your behalf
Information entrusted to MSBS and purpose
Information provided in connection with services: You may entrust information that you control,
to MSBS in connection with use of our services or for requesting technical
support for our products. This includes information that you have stored for
use of primary and secondary user or data that you hold and use on behalf of
another person for a specific purpose, to whom you provide services (if you are
a processor). The data may either be stored on our servers when you use our
services, or transferred or shared to us as part of a request for technical
support or other services.
Information from mobile devices: When you elect to allow it, some of our
mobile applications have access to the camera, microphone, call history,
contact information, photo library, files and other information stored on your
mobile device. Our applications require such access to provide their services.
Similarly, when you elect to provide access, location-based information is also
collected for purposes including, but not limited to, locating nearby contacts
or setting location-based reminders. This information will be exclusively shared
with our mapping providers and will be used only for mapping user locations.
You may disable the mobile applications' access to this information at any time
by editing the settings on your mobile device. The data stored on your mobile
device and their location information to which the mobile applications have
access will be used in the context of the mobile application, and transferred
to and associated with your account in the corresponding services (in which
case the data will be stored on our servers) or products (in which case the
data will remain with you unless you share it with us).
(All the information entrusted to MSBS is
collectively termed “service data”)
Ownership and
control of your service data
We recognize that you own your service data. We provide
you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service
data
through supported third-party integrations, and (iii) request export or
deletion of your service data.
How we
use service data
We process your service data when you provide us
instructions through the various modules of our services.
Push
notifications
If you have enabled notification on our desktop
and mobile applications, we will push notifications through a push notification
provider such as Apple Push Notification Service, Google Cloud Messaging or
Windows Push Notification Services. You can manage your push notification
preferences or deactivate these notifications by turning off notifications in
the application or device settings.
Who we share
service data with
MSBS group and
third party sub-processors: In order to provide services and technical
support for our products, the contracting entity within the MSBS group engages
other group and third party entities.
Employees
and independent contractors :
We may provide access to your service data to our employees and individuals who
are independent contractors of the MSBS group entities involved in providing
the services (collectively our “employees”) so that they can (i) identify,
analyze and resolve errors, (ii) manually
verify emails reported as spam to improve spam detection, or (iii) manually
verify scanned images that you submit to us to verify the accuracy of optical
character recognition. We ensure that access by our employees to your service
data is restricted to specific individuals, and is logged and audited. Our
employees will also have access to data that you knowingly share with us for
technical support or to import data into our products or services. We
communicate our privacy and security guidelines to our employees and strictly
enforce privacy safeguards within the MSBS group.
Collaborators
and other users: Some of
our products or services allow you to collaborate with other users or third
parties. Initiating collaboration may enable other collaborators to view some
or all of your profile information. For example, when you edit a document that
you have provided access to other persons.
Third-party
integrations you have enabled: Most of our products and services support
integrations with third-party products and services. If you choose to enable any third-party
integrations, you may be allowing the third party to access your service data
and personal information about you. We encourage you to review the privacy
practices of the third-party services and products before you enable
integrations with them.
Other cases:
Other scenarios in which we may share information that are common to
information covered under Parts I and II are described in Part III.
Retention of
information
We hold the data in your account as long as you
choose to use MSBS Services. Once you terminate your MSBS user account, your
data will eventually get deleted from active database during the next clean-up
that occurs once in 6 months. The data deleted from active database will be
deleted from backups after 3 months.
Data subject
requests
If you believe that we store, use or process your
information on behalf of one of our customers, please contact the customer if
you would like to access, rectify, erase, restrict or object to processing, or
export your personal data. We will extend our support to our customer in
responding to your request within a reasonable timeframe.
Part III – General
Children’s personal information
Our products and services are not directed to
individuals under 16. MSBS does not knowingly collect personal information from
children who are under 16 years of age for its own purposes. If we become aware
that a child under 16 has provided us with personal information, we will take
steps to delete such information. If you believe that a child under 16 years
has provided personal information to us, please write to
“operations@myesafebox.com” with
the details, and we will take the necessary steps to delete the information we
hold about that child. However, using our products, you can collect/store
information about individuals who may be children. If you process information
relating to children, you acknowledge and agree that you will be responsible
for complying with the applicable laws and regulations related to protection of
such personal information.
How secure is your information
At MSBS, we take data security very seriously. We
have taken steps to implement appropriate administrative, technical &
physical safeguards to prevent unauthorized access, use, modification,
disclosure or destruction of the information you entrust to us. If you have any
concerns regarding the security of your data, we encourage you to write to us
at operations@myesafebox.com with any questions.
Data Protection Officer
We have appointed a Data Protection Officer to
oversee our management of your personal information in accordance with this
Privacy Policy. If you have any questions or concerns about our privacy
practices with respect to your personal information, you can reach out to our
Data Protection Officer by sending an email to operations@myesafebox.com or by writing to: Data Protection
Officer, E-702, Richmond Grand,100 FT RING Road, Makarba,
Ahmedabad - 380055, Gujarat.
Locations and international transfers
We share your personal information and service
data within the MSBS Group and with third parties engaged by MSBS Group for the
purposes described above. By accessing or using our products and services or
otherwise providing personal information or service data to us, you understand
that the processing, transfer, and storage of your personal information or
Service Data within India where MSBS operates. Such transfers are subject to
appropriate data protection agreements. You can write to operations@myesafebox.com for
obtaining a copy of the agreements on the basis of which we transfer your data
within MSBS Group and with the third parties engaged by us.
Automation and Artificial Intelligence
In order to provide enhanced productivity and
predictive capabilities to our users, we employ a variety of technologies such
as regex parsing, template matching, artificial intelligence and machine
learning. In keeping with MSBS's promise not to exploit your data in a way that
is not respectful of your privacy and confidentiality expectations, we make
only the following limited use of service data for these technologies: (i)
using anonymized crops of service data to improve
accuracy of the algorithms; and (ii) using your organization's data for
developing models specific for your organization. Our automation and artificial
intelligence technologies are mostly powered by our own organization's data
such as internal communications, communications with customers and internal
documents as well as free and paid external sources.
Do Not Track (DNT) requests
Some internet browsers have enabled 'Do Not
Track' (DNT) features, which send out a signal (called the DNT signal) to the
websites that you visit indicating that you don't wish to be tracked.
Currently, there is no standard that governs what websites can or should do
when they receive these signals. For now, we do not take action in response to
these signals.
External links on our websites
Some pages of our websites may contain links to
websites that are not linked to this Privacy Policy. If you submit your
personal information to any of these third-party sites, your personal
information is governed by their privacy policies. As a safety measure, we
recommend that you not share any personal information with these third parties
unless you've checked their privacy policies and assured yourself of their
privacy practices.
Blogs and forums
We offer publicly accessible blogs and forums on
our websites. Please be aware that any information you provide on these blogs
and forums may be used to contact you with unsolicited messages. We urge you to
be cautious in disclosing personal information in our blogs and forums. MSBS is
not responsible for the personal information you elect to disclose publicly.
Your posts and certain profile information may remain even after you terminate
your account with MSBS. To request the removal of your information from our
blogs and forums, you can contact us at operations@myesafebox.com.
Social media widgets
Our websites include social media widgets such as
Facebook "like" buttons and Twitter "tweet" buttons that
let you share articles and other information. These widgets may collect
information such as your IP address and the pages you navigate in the website,
and may set a cookie to enable the widgets to function properly. Your
interactions with these widgets are governed by the privacy policies of the
companies providing them.
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose
your personal information and service data to comply with any applicable law,
regulation, legal process or governmental request, including to meet national
security requirements.
Enforcement of our rights
We may disclose personal information and service
data to a third party if we believe that such disclosure is necessary for
preventing fraud, spam filtering, investigating any suspected illegal activity,
enforcing our agreements or policies, or protecting the safety of our users.
Business Transfers
We do not intend to sell our business. However,
in the unlikely event that we sell our business or get acquired or merged, we
will ensure that the acquiring entity is legally bound to honor our commitments
to you. We will notify you via email or through a prominent notice on our
website of any change in ownership or in the uses of your personal information
and service data. We will also notify you about any choices you may have
regarding your personal information and service data.
Compliance with this Privacy Policy
We make every effort, including periodic reviews,
to ensure that personal information you provide is used in conformity with this
Privacy Policy. If you have any concerns about our adherence to this Privacy
Policy or the manner in which your personal information is used, kindly write
to us operations@myesafebox.com.
We'll contact you, and if required,
coordinate with the appropriate regulatory authorities to effectively address
your concerns.
Notification of changes
We may modify the Privacy Policy at any time,
upon notifying you through a service announcement or by sending an email to
your primary email address. If we make significant changes to the Privacy
Policy that affect your rights, you will be provided with at least 30 days'
advance notice of the changes by email to your primary email address. However,
if you have not verified your email address, you may miss important
notifications that we send through email. If you think that the updated Privacy
Policy affects your rights with respect to your use of our products or
services, you may terminate your use by sending us an email within 30 days.
Your continued use after the effective date of changes to the Privacy Policy
will
be deemed to be your agreement to the modified Privacy Policy. You will not
receive email notification of minor changes to the Privacy Policy. If you are
concerned about how your personal information is used, you should check back on
our website periodically.