LAST UPDATED May 31ST, 2021
PENN respects your privacy and is always committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
We primarily use the information we collect when you interact with the Sites in connection with your relationship with the Owner, your use of the Sites, and for sending you information from us or on behalf of third parties. Please review the “Information Collection” and “How We Use Your Information” sections for a full description of the information we collect and how we use that information. Note that we do not share your Personal Information (information that identifies you as a specific individual, such as your full name, email address or street address) with third parties for their marketing purposes without your consent; however, we may share your Personal Information under certain limited circumstances. For more information, please review the section below entitled “How We May Share the Information Collected.”
The Sites may contain content served by third parties, including videos and advertisements, and we work with third party service providers to serve the Owner advertisements elsewhere online. In connection with serving content and providing analytics and advertising services, third parties may collect certain information about your visits to this or other web sites and we may receive information regarding the use of the Sites and the effectiveness of our advertisements. We do not share Personal Information with these third parties, but the advertising networks, advertisers, ad agencies, analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you (such as your general interest in certain book genres).
Personal Information for the purposes of this Policy shall include, but not limited to, information regarding Your name, photograph, address, telephone number, date of birth, gender, e-mail address, financial information details, Facebook profile, contacts, etc.
- Collection of Personal Information, Other Information and Its Usage
1.2 Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature on the Site. We may automatically track certain information about you based upon your behaviour on our Site.
1.4 The information as collected will be retained by PENN in compliance of the applicable laws.
1.5 Information for the purposes of this Policy shall include, but shall not be limited to the following:
1.5.1 Personal information such as your name, photograph, address, telephone number, date of birth, gender, e-mail address, financial information details, Facebook profile, contacts, etc.
1.5.2 Contact Information such as e-mail address, telephone number
1.5.3 Profile Information such as your log-in and password details in connection with the account sign-in process, messages on our message boards, chat rooms or other message areas or leave feedback.
1.5.4 Financial Information If you transact with us (through making donations / contributions), we collect some additional information, such as a billing address, First 6 digits and last 4 digits of credit / debit card number, Bank Account information and IFSC code /SWIFT code.
1.5.5 Marketing and communication Information like If you send us personal correspondence, such as emails or letters, or if other Users or third parties send us correspondence about your activities or postings on the Site, we may collect such information into a file specific to you
1.5.6 Transaction Information such as Details of any requests or transactions made by you through the Site
1.5.7 Technical Information such as IP addresses, browser and operating system specifications, location, etc.
1.5.8 Usage Information such as information on how you use the platform.
We also collect, use and share Aggregated Information such as statistical data for various purposes. Aggregated Data may be derived from your personal data but is not considered as personal data in law as this data does not directly or indirectly reveal anything specific about your identity. For example, we may aggregate your Transaction Information to calculate the success rate of transaction on the Site.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data), nor do we collect any information about criminal convictions and offences related to you.
If you fail to provide us the personal data, We would not be able to provide you with parts or entire service offered by PENN and its platform
- How we collect this Personal Information
We use various methods to collect data from and about you including through:
You may give us your personal and contact information by using the Platform. This includes personal data you provide when you:
- Creating an account on the platform for fundraising or donating
- Subscribe to our newletters
- Request updates to be sent to you
- Feedback, Survey, competition, etc
As you use our platform, PENN may automatically collect data points about your browsing choices, patterns, etc. This data is collected via cookies, logs or similar technology. The session timeout on PENN ’s platform is 14 days.
- Third Party Sources
We may receive various personal information from third party sources/sites such as
- Technical Information from
– Google Analytics
– Advertising platforms such as Facebook, Taboola, Criteo, Columbia, Outbrain, Google
– Search engines such as Google, Yahoo, Bing
- Contact, Financial and Transactional Information such as payment gateways such as Stripe, Razorpay, PayU, Citrus, Billdesk, PayTM, UPI payment systems including Yes Bank, PhonePe, PayTM, WhatsApp Pay, Google Pay, BHIM, etc..
- Personal and Contact information from platforms such as Facebook and Google
- Use of Demographic / Profile Data / Your Information
We use personal information to provide the services you request. To the extent we use your personal information to market to you, we will provide you the ability to opt-out of such uses. We use your personal information to resolve disputes; troubleshoot problems; help promote a safe service; collect money; measure consumer interest in our products and services, inform you about online and offline offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our terms and conditions; and as otherwise described to you at the time of collection. In our efforts to continually improve our product and service offerings, we collect and analyse demographic and profile data about our users’ activity on our Website.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are wherever appropriate.
- Disclosing your Personal Information
We may have to share your personal information with third parties set out below for the purposes set out in the table above.
- Internal Third Parties
- External Third Parties
- Third parties with whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in full accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes or usage and only permit them to process your personal data for specified purposes and in accordance with instructions given by us.
5.1 The Site allows a contributor to make an “anonymous” contribution to a campaign, even after registering through email or the Facebook login. By choosing to be anonymous, the Site does not publish the contributor’s name or image on a campaign’s contributor section and also does not provide the contributor’s name to the campaigner, except for the phone number and billing/shipping addresses for the purpose of rewards delivery. PENN knows about your identity when you register, but does not reveal it to anyone.
- Review of Information / Account Deactivation / Removal of Information
6.1 If at any time a user wishes to review the information provided to us at the time of registering with us or at any time thereafter, you may do so by signing into your account and amending the same.
6.2 We provide all Users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our campaigner, and from us in general, after setting up an account. All Users are also given the option of cancelling their user accounts and bringing to our attention their desire to discontinue the use of our services. If you want to remove your contact information from this Site and our newsletters, please send us an email at email@example.com. Even if user opts-out, PENN reserves the right to notify you about your existing account.
USERS IN EUROPE
- Access. You have the right to request a copy of the information we are processing about you.
- Rectification. You have the right to have incomplete or inaccurate information that we process about you rectified.
- Deletion. You have the right to request that we delete information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to restrict our processing of your information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
- Portability. You have the right to obtain information we hold about you in a structured, electronic format, and to transmit such data to another data controller, where this is (a) information that you have provided to us, and (b) if we are processing that data solely on the basis of your consent or to perform a contract with you.
- Objection. Where the legal basis for processing your information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
- Withdrawing consent. If you have consented to our processing of your information, you have the right to withdraw your consent at any time, free of charge. This includes where you wish to opt out from marketing messages.
You can make a request to exercise any of these rights in relation to your information by sending the request to us at firstname.lastname@example.org or addressed to the Grievance Officer mentioned in this policy. For your own privacy and security, at our discretion, we may require you to provide your identity before providing the requested information. Please note that we may take up to 30 days to fulfil such requests.
8.1 We have adopted reasonable security practices and procedures to ensure that the personal information collected is secure. Your personal information is held on secure servers. You agree that such measures are secured and adequate when you register with us/create an account.
8.2 While we will endeavor to take all reasonable and appropriate steps to keep secure any information which we hold about you and prevent unauthorized access, you acknowledge that the internet is not 100% secure and that we cannot provide any absolute assurance regarding the security of your personal information. We will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information caused by us in relation to your personal information.
“Force Majeure Event” shall mean any event that is beyond the reasonable control of us and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided beyond reasonable control of us), power or electricity failure or unavailability of adequate power or electricity.
- Link to Third Party Site
9.1 Links to third-party advertisements, third-party websites or any third party electronic communication service may be provided on the Site which are operated by third parties and are not controlled by, or affiliated to, or associated with, us unless expressly specified on the Site.
- Data Retention
10.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
10.2 To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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 requirements.
10.3 In some circumstances we may anonymize or obfuscate your personal data (so that it can no longer be associated with you) for research or statistical purposes. In this case we may use this information indefinitely without further notice to you.
- Grievance Officer
Mr. Sridhar V S
Penn – Prevention and Empowerment of Women
- Changes to this Policy
- Effective Date
This policy was updated and became immediately effective on May 31st, 2021