2.1 “Panellists” means users of VTION Digital Application that voluntarily onboard themselves on the VTION Digital Application to provide their Personal Data for behavioural analysis in exchange for rewards like digital wallet cashbacks and other benefits.
2.2. “Personal Data” means any data about an individual who is identifiable by or in relation to such data;
2.3. “Third Parties” means and included third-party vendors and/or third party processors engaged by VTion during the course of its business and/or visitors to the Website.
3.1. This Privacy Policy applies to Vidhi Techinnovation Opportunities Network Private Limited (“VTION”, “we”, “us”, “our”).
5.1. This Privacy Policy applies to everyone who visits and/or uses our Website and/or the Apps, including Panellists and/or Third Parties (“collectively referred to as “Users”, “you”). This Privacy Policy does not extend to any websites or applications that may be accessed from the Website and/or Apps including, but not limited to any links we may provide to any other websites or applications.
5.2. We follow this Privacy Policy in accordance with the applicable laws, including but not limited to the (Indian) Digital Personal Data Protection Act, 2023. For some products, applications, services, or events, we may have additional privacy notices. These notices should be read together with this Privacy Policy.
5.4. All undefined terms used in this Privacy Policy shall have the meaning assigned to them in the Terms of Use.
6.1. We may collect, use, store and transfer different kinds of Personal Data about you including the below mentioned, which we have grouped together as follows:
6.1.1 Personal Data collected from Website visitors including prospective customers
6.1.2. Personal Data collected from Panellists
6.2. We also collect, use, and share aggregated insights, for analytics purposes. Aggregated insights are made up of information from many people, but it cannot be used to identify any one individual. For example, we might use aggregated insights to calculate the percentage of Users who visit a certain part of our Website.
7.1. We use different methods to collect Personal Data from and about you including through:
8.1. We will only collect and use your Personal Data when the applicable law allows us to. We will most commonly collect your Personal Data:
10.1. We will only use your Personal Data for the purposes for which we collected it. If we need to use your Personal Data for another purpose, we will tell you about it and explain why we are doing it. We may also ask for your permission, depending on the applicable laws.
10.2. Please note that we may process your Personal Data without your consent or knowledge where this is required or permitted by applicable laws.
11.1. We may share your Personal Data with the parties set out below in the following limited circumstances:
11.2. In any case, we require all third parties to respect the security of your Personal Data and to treat it in accordance with the applicable laws. 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. Further, we do not sell your Personal Data or share it with any third parties for any purpose not mentioned in this Privacy Policy.
14.1. All the Personal Data provided by you will be uploaded to secure servers in India that are controlled by us. We may also use third party processors to store Personal Data collected from you.
14.2. VTION treats all Personal Data it receives from you as confidential and does not use the Personal Data for any purpose other than in accordance with this Privacy Policy. We have security measures in place to protect your Personal Data from unauthorized access, use, or disclosure.
14.3. We regularly review our security measures to make sure they are keeping your Personal Data safe. However, no security measures are perfect.
14.4. We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
14.5. Typically, we determine the appropriate retention period for Personal Data by considering the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
14.6. We may also anonymise 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.
15.1. Some of our third party processors may be based outside India so their processing of your Personal Data will involve a transfer of Personal Data outside India.
15.2. When we transfer Personal Data from India, we will ensure such transfers follow relevant data protection laws, including the (Indian) Digital Personal Data Protection Act, 2023, and any rules made under it.
16.1. Under the (Indian) Digital Personal Data Protection Act. 2023, you have the following rights:
(a) Right to access information: You can ask us for the following information:
(b) Right to correction, completion, and erasure: You have the right to ask us to correct, complete, or erase your Personal Data. This means that you can ask us to:
(d) Right to nominate: You can choose someone to exercise your privacy rights on your behalf if you are unable to do so yourself. This could be because of death or an inability to exercise your rights due to unsoundness or mind or bodily infirmity.
(e) Right to appoint consent manager: You can choose to appoint a consent manager i.e., registered with the Data Protection Board of India to give, manage, review or withdraw consent on your behalf.
(f) Right to withdraw consent: You can withdraw your consent to us processing your Personal Data at any time. We will stop processing your Personal Data once you withdraw your consent. However, withdrawing your consent will not affect any processing that we did before you withdrew your consent. We may also be unable to provide you with certain products or services if you withdraw your consent. We will tell you if this is the case when you withdraw your consent.
16.3. If you wish to exercise any other rights set out above, please contact us on the address mentioned in paragraph 3 hereinabove.
16.4. We may need to request specific information from you to help us verify your identity. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
17.1. You also have the right to make a complaint at any time to the Data Protection Board of India, which is the supervisory authority for data protection in India.
17.2. You may contact the Data Protection Board of India through its official portal at https://dpb.gov.in or by following the procedure outlined therein for lodging complaints.
18.1. Our Platforms may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platforms, we encourage you to read the privacy policy of every website you visit.
19.1. Where we need to collect Personal Data by applicable laws, or under the terms of a contract we have with you, and you fail to provide that Personal Data when requested, we may not be able to deliver the functionalities of our Platforms or any part thereof.
20.1. In the event of any dispute arising out of or in connection with this Privacy Policy, including disputes relating to the interpretation, breach, or enforcement of this Privacy Policy, they shall be resolved in conjunction with the procedures and dispute resolution mechanisms set forth in the Terms of Use.
We implement robust technical and organizational measures to protect your Personal Data, including:
21.1. Our information security management system aligns with globally recognized standards.
21.2. Personal Data is anonymised and encrypted in transit and at rest using industry-standard protocols.
21.3. We conduct periodic internal and external audits to assess compliance and identify vulnerabilities.
21.4. Role-based access controls, multi-factor authentication, and continuous monitoring are enforced to prevent unauthorized access.
21.5. All third-party processors undergo security due diligence and contractual obligations to maintain equivalent protection.
21.6. Our applications follow secure development practices, including regular penetration testing and code reviews.
21.7. We maintain documented plans to ensure service resilience and data protection during unforeseen events.
22.1. We may change this Privacy Policy from time to time. We will place a prominent notice that will be visible to you as a User. You should check back here periodically to see if the Privacy Policy has been updated as we will always show the date of the latest modification of the Privacy Policy.
