A. Who we are?
We are Ascendas Flexoffice India Private Limited, ("Ascendas" or "We" or "Our" or "Us"). We are a Company incorporated under the Companies Act 2013, having Our registered office at 3rd Floor, Discoverer Building, International Tech Park Bangalore, Whitefield Road, Bangalore 560 066 and own and operate the Application.
B. What is the purpose of this policy?
8. If You are accessing or using the Application from any location outside India, You do so at Your own risk, and will be solely liable for compliance with any local laws, as may be applicable.
9. In the event of a change in the law applicable to data protection in India, You hereby expressly consent to Our continued use, storage, collection and disclosure of Your Information, including Personal Data, to the fullest extent permitted under such applicable law. We may reach out to You for obtaining additional consents and approvals as required under the amended law and You will be required to comply with such requests. Should You choose to not provide Us with such additional consents and approvals, We may have to discontinue provision of Our Application, App Services and/or Our business offerings to You.
C. What Information do we collect?
1. "Personal Information” is defined under the SPDI Rules to mean any information that relates to a natural person which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. Ascendas collects information about You, when You use Our Application. Personal Information which We may collect ("Personal Data”) includes:
- Email address
- Mailing address
- Telephone number(s)
- Date of birth
- Usage and Preferences
We will collect Personal Data in accordance with the IT Act and SPDI Rules.
2. We may collect and store certain information automatically when You use the Application. Examples include Your operating system and platform, a unique reference number linked to the data You enter on Our system, login details, cookie number and Your activity on Our Application, including the pages You visited, the searches You made, and the services You accessed.
2. A cookie is a small file of letters and numbers that We store on the hard drive of Your Mobile Device or within the Application.
3. You can block or deactivate cookies in Your Mobile Device settings. This may prevent You from taking full advantage of Our Application.
4. We use log-in cookies in order to remember You when You have logged in for a seamless experience, and to help ensure the security and authenticity of registered users.
5. We use session cookies to track Your movements from page to page and in order to store Your selected inputs so that You are not constantly asked for the same information.
6. These cookies may track things such as how long You spend on the Application and the pages that You visit so We can enhance Our Application.
E. The Purposes for which We collect, use or disclose Your Personal Data
1. Ascendas will/may collect, use, disclose and/or process Personal Data that You provide to Us, for one or more of the following purposes:
(a) administering, facilitating, processing and/or dealing in any matters relating to Your use of the Application;
(b) providing the App Services to You;
(c) monitoring, processing and/or tracking Your use of the Application in order to provide You with a seamless experience, facilitating or administering Your use of the Application, and/or to assist Us in improving Your experience in using the Application;
(d) administering, facilitating, processing and/or dealing in any transactions or activities carried out by You on the Application;
(e) carrying out Your instructions or requests, or responding to any enquiry given by (or purported to be given by) You or on Your behalf;
(f) opening or continuation of accounts and establishing or providing You with any services that You access;
(g) contacting You or communicating with You and/or Your authorized representatives, employees, or staff, via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing Your use of the Application. You acknowledge and agree that such communication by Us could be by way of the mailing of correspondence, documents or notices to You, which could involve disclosure of certain Personal Data about You to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(h) managing Our administrative and business operations, and complying with Our internal policies and procedures;
(i) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations applicable to Us (whether Indian or foreign), the requirements or guidelines of governmental authorities which We determine are applicable to Us (whether Indian or foreign), and/or Our risk management procedures that may be required by applicable law (whether Indian or foreign) or that may have been put in place by Us;
(j) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
(k) complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to Us or Our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on Us or Our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of India or elsewhere), with which We or Our affiliates/associated companies are expected to comply;
(l) complying with or as required by any request or direction of any governmental authority (whether Indian or foreign) which We are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that We may/will disclose Personal Data to the aforementioned parties upon their request or direction;
(m) for legal purposes (including but not limited to enforcement of contractual obligations, obtaining legal advice and dispute resolution);
(n) processing of invoices and payments;
(o) enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments);
(p) conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve Our services and facilities in order to enhance any continued interaction between Yourself and Us connected or in relation to the Application, or to improve any of Our products or services;
(q) storing, hosting, backing up (whether for disaster recovery or otherwise) of Your Personal Data, whether within or outside India;
(r) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of Ascendas;
(s) disclosing and transferring Your Information, including Personal Data, to a third party who acquires, or may potentially acquire, Our business, whether such acquisition is by way of a merger, consolidation or purchase of all or a substantial portion of Our assets; and
(t) processing Your Personal Data for purposes which are reasonably related to any of the purposes stated above, including disclosure to and processing by any third party outsourced service providers and/or Our marketing partners.
(the purposes set out at paragraphs 1 to 3 of this Clause E shall be collectively referred to as the "Purposes”).
2. Ascendas may/will need to disclose Your Personal Data to third parties, whether located within or outside India, for one or more of the above Purposes, as such third parties, would be processing Your Personal Data for one or more of the above Purposes. In this regard, You hereby acknowledge, agree and consent that We are permitted to disclose Your Personal Data to such third parties (whether located within or outside India) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process Your Personal Data for one or more of the above Purposes. In the event that You are acting on behalf of an Organisation, You represent, warrant and undertake that You have obtained the consent of the relevant individuals whose Personal Data is provided to Us. Without limiting the generality of the foregoing or of paragraph 1, such third parties include:
(a) Our associated or affiliated organisations or related corporations;
(b) any of Our agents, contractors or third party service providers that process or will be processing Your Personal Data on Our behalf including but not limited to those which provide administrative or other services to Us such as mailing houses, telecommunication companies, information technology companies and data centres; and
(c) third parties to whom disclosure by Ascendas is for one or more of the Purposes and such third parties would in turn be collecting and processing Your Personal Data for one or more of the Purposes.
For the purposes of this clause, "Organisation” means a company, partnership, association or other entity, organisation or body corporate.
3. We may share Your Personal Data with any member of Our group, which means Our subsidiaries, Our ultimate holding company and its subsidiaries from time to time for one or more of the Purposes.
4. We may collect, use, disclose or process Your Personal Data for other purposes that do not appear above. However, We will notify You of such other purpose at the time of obtaining Your consent, unless processing of Your Personal Data without Your consent is permitted by the IT Act, SPDI Rules or any other applicable law.
5. We may/will also be collecting Your Personal Data from sources other than Yourself, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such Personal Data for one or more of the above Purposes. We may combine information We receive from other sources with information You give to Us and information We collect about You. We may use this information and the combined information for the Purposes set out above (depending on the types of information We receive).
F. How do we store data?
1. Security is a high priority. We take appropriate actions to protect Personal Data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as We use for Our own proprietary information. All information You provide to Us is stored on Our secure servers. Where We have given You (or where You have chosen) a password which enables You to access certain parts of the Application, You are responsible for keeping this password confidential. You agree not to share the password with anyone.
2. We cannot accept liability for loss of Personal Data due to causes beyond Our control or omissions of other users or third parties who may misuse Your Personal Data which they collect from the Application.
3. We will put in place measures such that Your Personal Data in Our possession or under Our control is destroyed and / or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
1. You have the right to ask Us not to use Your Personal Data for marketing purposes. Please let Us know if You want to withdraw Your consent by contacting Our Grievance Officer at the address set out in Clause K below. Please be aware that once We receive confirmation that You wish to withdraw Your consent for marketing or promotional materials/communication, it may take up to 30 (thirty) working days for Your withdrawal to be reflected in Our systems. Therefore, You may still receive marketing or promotional materials/communication during this period of time. Please note that even if You withdraw Your consent for the receipt of marketing or promotional materials, We may still contact You for other purposes in relation to the products and/or services that You apply for with Us.
2. You have the right to access and / or correct any Personal Data that We hold about You. This right can be exercised at any time by contacting Our Grievance Officer at the address set out in Clause K below. We will need enough information from You in order to ascertain Your identity as well as the nature of Your request, so as to be able to deal with Your request. We may charge a fee in order to process this.
3. For a request to access Personal Data, once We have sufficient information from You to deal with the request, We will seek to provide You with the relevant Personal Data within 30 days. Where We are unable to respond to You within the said 30 (thirty) days, We will notify You of the soonest possible time within which We can provide You with the information requested.
4. For a request to correct Personal Data, once We have sufficient information from You to deal with the request, We will correct Your Personal Data within 30 (thirty) days. Where We are unable to do so within the said 30 (thirty) days, We will notify You of the soonest practicable time within which We can make the correction.
5. We hold and deal with Your data in accordance with the IT Act and SPDI Rules.
H. Complaint Process
1. If You have any complaint or grievance regarding about how We are handling Your Personal Data or about how We are complying with the IT Act and SPDI Rules, We welcome You to contact Us with Your complaint or grievance.
2. Please contact Us with Your complaint or grievance by contacting Our Grievance Officer at the address set out in Clause K below.
3. Where You are sending a letter in which You are submitting a complaint, Your indication at the subject header that it is an IT Act or SPDI Rules complaint would assist Us in attending to Your complaint speedily by passing it on to the relevant staff in Our organisation to handle. For example, You could insert the subject header as "SPDI Rules Complaint”.
4. We strive to deal with any complaint or grievance that You may have speedily and fairly.
You agree and undertake to indemnify Ascendas in any suit or dispute by any third party arising out of disclosure of information by You to third parties through Our Application and Your use of the Application. Ascendas assumes no liability for any actions of third parties with regard to Your Personal Data which You may have disclosed to such third parties.
2. For the avoidance of doubt, in the event that Indian personal data protection law permits an organisation such as Ours to collect, use or disclose Your Personal Data without Your consent, such permission granted by the law shall continue to apply.
3. If You, at any time, have any queries on this policy or any other queries in relation to how We may manage, protect and/or process Personal Data, please do not hesitate to contact Our Grievance Officer at:
Ascendas Flexoffice India Private Limited
3rd Floor, Discoverer Building, International Tech Park Bangalore, Whitefield Road
Bengaluru, Karnataka, India 560 066