1.1 In order to enable us in providing you with the best in
class services, we require certain information be shared by you with
us. Bilo Trading may collect the following types of information:
- 1.1.1 “Personal
Information” which shall mean information
which could reasonably be used to identify you personally, which may
include, but not limited to the following:
- a. Basic details which you provide during the
registration process such as Name, Phone Number, Email Address,
Communication or Permanent Address.
- b. Photograph provided during registration or
during the profile update.
- c. Demographic details such as gender, city, PIN
code or nearest location.
- d. Usage logs/Server logs/Cookies which may contain
details of your personal or sensitive personal information.
- e. Service specific information or identifiers such
as IMSI, MSISDN, Customer ID etc.
- f. Device specific information or identifiers such
as IMEI, OS specific identifiers.
For the purpose of
this policy, sensitive personal data or information has been considered
as a part of Personal Information, which may include, but not limited
to the following:
- Passwords or authentication information for any of our
services or apps.
- 1.2
“Non-Personal Information” which
shall mean information that does not identify you or any other
individual, and includes session, web beacons and usage and transaction
data, aggregate log data and aggregate information. We use this
information to inter-alia deliver our web pages to you upon request, to
tailor our services to the interests of our users, to measure traffic
within our services, to improve the quality, functionality and
interactivity and let advertisers know the geographic locations from
where our users/ visitors come.
- 2. Use of Information
- 2.1 The information provided by you to
us is used for a number of purposes connected with our business
operations which may include the following:
- Verify your identity, access, privileges assigned
and relationship with us.
- Provisioning of products/services, testing or
improvement of services, recommending various products or services;
- Processing your requests, enquiries and complaints,
customer services and related activities;
- Analytics and reviews for improvement of our
services;
- Analytics and reviews for improvement of our
services;
- Improving your experience while using our services
by presenting advertising, products and offers tailored to you;
- Other usages that you may consent to;
- 2.2 We will strive to keep your
personal information confidential and will place reasonable security
controls to protect it. Your Personal Information will be kept
confidential as required under applicable laws.
- 2.3 However, any comments, messages,
blogs, scribbles etc. posted / uploaded / conveyed / communicated by
you on the public sections of the apps/website becomes published
content and is not considered personal information subject to this
Policy. You may request that such information be taken down and, we may
attempt to remove any such information if it is technically feasible to
do so and as per the applicable laws.
- 2.4 Further, with respect to
Non-Personal Information automatically collected and stored in files,
we shall use this information to understand and analyze trends, to
administer our services, to learn about user behavior on the apps and
while using our services, to gather demographic information about the
user base as a whole and to measure traffic patterns on our network and
apps. As Non-Personal Information does not personally identify you, we
may use and disclose Non-Personal Information at our discretion.
- 3. Sharing and Disclosure
- We do not sell or rent personal
information to any third party entities. We limit the
disclosure of the Personal Information to certain circumstances, as
provided below:
- Mergers or acquisitions: In a scenario
where we or our assets are merged or acquired by the other business
entity, or during restructuring of business or re-organization, we may
have to share information provided by you with the other business
entities. Rest assured, if such a transaction occurs the other business
entity or the newly combined business entity would be required to
follow this Privacy Policy.
- Partners: we engage a number of
vendors, consultants, contractors and take support of our group
companies or affiliates (hereon referred to as our Partners). Our
Partners provide a host of services including contact information
verification, payment processing, customer service, website hosting,
data analysis, infrastructure provision, IT services, and other similar
services. These Partners play a key role in seamless delivery of our
products and services to you. These Partners and their employees
operate under a contract and strict security & confidentiality
restrictions. We may provide our partners access to your information
through our systems or may share your Personal Information with them to
enable them to provide their services to you.
- Customer Initiated Sharing: Whenever
you request us to share your information with a third party website or
application, we
will provide a fresh notice and obtain consent from you regarding the
details of the information that will be shared, before sharing the
same. In such a case, Bilo Trading will not be in control of the
information
(shared with the third party website/application or data generated
based on your usage on that website/application) and Bilo Trading
privacy
policy will not be applicable for any such use, access etc. Any
processing, use, sharing of Information provided by you to such third
party website/application shall be as per the respective privacy policy
of such applications and websites . The customer shall read and provide
consent to the third partys privacy policy before requesting Bilo
Trading to
share the information.
- Government or judicial process: We may
share your Personal Information with the government / government
authorities or agencies and legal or judicial authorities for any
investigation or to comply with legal process or in response to a
request by any of these authorities or to enforce applicable terms and
conditions or to protect our, our users and Partners rights, privacy,
safety or property.
- Legal Reasons: The information
provided by you may be shared with our other entities and affiliates to
help in detecting and preventing identity theft, frauds and other
illegal activities; correlate or map related accounts to prevent misuse
of our products & services and to provide you our services.
- Protection of Bilo Trading: To protect
your
rights and/or those of our Partners, and to allow Bilo Trading to
pursue
available remedies or limit the damages that it may sustain in case of
unauthorised use / misuse of our products or the content thereon, by
third parties.
- 4. Storage, Retention and Security
- 4.1 We have adopted reasonable security practices and
procedures, in line with international standard IS/ISO/IEC 27001, to
include strategic, operational, managerial, technical, and physical
security controls to safeguard and protect your data and information.
We have implemented such measures, as stated above, to protect against
unauthorized access to and unlawful interception of Personal
Information. Additionally, we have adopted measures to ensure that your
personal information is accessible to our employees or partners
employees strictly on the need to know basis.
- 4.2 Our website, applications, portals, and network
equipment have industry standard security precautions in place to
protect the loss, misuse and alteration of information which is in our
environment. Whenever you change or access your account information, we
facilitate the use of secure systems. The information in our custody
and control is protected by adherence to reasonable security procedures
in order to safeguard against unauthorized access. We apply encryption
or other appropriate security controls to protect Personal Information
when stored or transmitted by us.
- 4.3 Your information or data will primarily be stored
in electronic form. However, certain data can also be stored in
physical form.
We may enter into
agreement with third parties to collect, store, process your
information or data but under full compliance with applicable laws.
These third parties may have their own security standards to safeguard
your information or data and we will require such third parties to
adopt reasonable security standards to safeguard your information /
data on commercially reasonable basis.
We have taken
appropriate steps for the security and protection of all our digital
platforms including internal applications, however, we shall not be
responsible for any breach of security or the disclosure of Personal
Information for reasons outside our control, such as hacking, social
engineering, cyber terrorism, espionage by third parties, or any events
by way of force majeure such as sabotage, fire, flood, explosion, acts
of God, civil commotion, strikes or industrial action of any kind,
riots, insurrection, war, acts of government.
- 5. Third Party Websites,
Applications and Services
Bilo Trading
Application/website may include links to other websites/applications.
Such websites/application are governed by their respective privacy
policies, which are beyond our control. Once you leave our servers (you
can tell where you are by checking the URL in the location bar on your
browser), use of any information you provide is governed by the privacy
policy of the operator of the website/application you are visiting.
That policy may differ from ours. If you can't find the privacy policy
of any of these websites/application via a link from the website's
homepage, you should contact the website/application directly for more
information.
Whenever you request
us to share your information with a third party website or application,
we will
provide a fresh notice and obtain consent from you regarding the
details of the information that will be shared, before sharing the
same. In such a case, Bilo Trading will not be in control of the
information
(shared with the third party website/application or data generated
based on your usage on that website/application) and Bilo Trading
privacy policy will not be applicable. The third party
website/application will handle the information according to their own
privacy policy. The customer shall read and provide consent to the
third party’s privacy policy before requesting Bilo Trading
to share
the information.
- 6. Access, Correction
and Deletion
We strive hard to
keep our records updated and accurate with your latest information. You
shall be responsible to ensure that the information or data you provide
from time to time is and shall be correct, current and updated and you
have all the rights, permissions and consent to provide such
information or data.
Based on technical
feasibility, we will provide you with the access to all your personal
and sensitive personal information that we maintain about you. We will
perform verification before providing you access to this information.
You may request
access, correction or updation, and deletion of the information by
contacting Bilo Trading or by visiting website
You may note that
deletion of certain information or withdrawal of consent may lead to
cancellation of your registration with us or your access to our
services. Additionally, we may not be able to process your request of
correction, updation or deletion, in case the same is not supported by
valid documents or data retention if required by the applicable law or
law enforcement requests or under any judicial proceedings or it is
extremely difficult to implement (such as requests related to backup
copies or if a new system is required to process the request or change
of technical design) or risks the privacy of other users.
- 7. Queries and complaints
We are committed to
protect your personal information collected and processed by us and
look forward to your continued support for the same. In case of any
feedback or concern regarding protection of your personal information,
you can contact us at support@bilotrading.com.
Alternatively, you may also direct your privacy-related feedback or
concerns to the Privacy Grievance Officer whose details are as
mentioned below:
If you have questions
or concerns about this Policy, please contact Bilo Trading at support@bilotrading.com.
Last Updated: 10 April 2018
Copyright © 2018, Bilo Trading LLC
All rights reserved.