Privacy Policy

We, [Local Digital Services Private Limited] (“we”, “eLocals”, “us”, “our”) are an [online services provider that provides a one-stop destination that simplifies business operations and links manufacturers, distributors, wholesalers and retailers (collectively, “Businesses”), retailers/merchants (“Merchants” and prospective retail customers (“Consumers”) facilitating inventory management as well as sales through our mobile applications <<insert name of mobile application in bold>>, <<insert name of mobile application in bold>>, and <<insert name of mobile application in bold>> (collectively, the “Mobile Applications”) as well as through our website 27.06.2017 (the “Website”).] The Website and Mobile Applications are referred to as the “Platform”. Businesses, Merchants and Consumers are collectively referred to as the “Users” “you” and “your” and such reference includes the Users irrespective of whether any transaction is consummated by the Users on the Platform. [Company to confirm the details of business and bracketed portion and see if it can be fleshed out further.]
At eLocals one of our main priorities is the privacy of our Users. This privacy policy sets out the information practices of our Platform including the type of information that is collected, how the information is collected, how the information is used and with whom it is shared (“Privacy Policy”). This Privacy Policy is published in accordance with the provisions of the Information Technology Act, 2000 and the rules made thereunder. We request you to go through this Privacy Policy and the Terms of Use [insert hyperlink] carefully before you decide to peruse or use the Platform. This Privacy Policy is subject to amendment from time to time, please keep yourself updated on the same.
If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us at <<insert email id>>.
Please note that this Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in eLocals. This policy is not applicable to any information collected offline or via channels other than this website.
Consent
BY USING THE PLATFORM, SERVICES, THE WEBISTE, THE MOBILE APPLICATION OR ANY PART THEREOF OR BY OTHERWISE SHARING WITH US YOUR INFORMATION, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. YOU ALSO EXPRESSLY CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW) IN THE MANNER PRESCRIBED UNDER THIS PRIVACY POLICY AND FURTHER SIGNIFY YOUR AGREEMENT TO THIS PRIVACY POLICY AND THE TERMS OF USE (AVAILABLE AT [INSERT THE HYPERLINK] IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT SUBSCRIBE TO THE SERVICES, USE THE PLATFORM IN ANY MANNER AND DO NOT SHARE ANY OF YOUR INFORMATION.

DEFINITIONS
“Force Majeure Event” shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, pandemic, lock-down, civil commotion, strikes or industrial action or any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to your mobile or storage device, crashes, breach of security and encryption.
“Sensitive Personal Data or Information” includes data about or relating to a natural person who is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of the identity of such natural person, whether online or offline, or any combination of such features with any other information, and shall include any inference drawn from such data for the purpose of profiling.
provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2000 or any other law for the time being in force shall not be regarded as sensitive personal data or information.
Information we collect
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information especially if such personal information includes Sensitive Personal Data or Information.
We may collect and process Sensitive Personal Data or Information provided by you in the following forms:

Information provided by you at registration such as your name, age, address, email id and phone number. Providing additional information beyond what is required at the time of registration is entirely optional and can be altered or removed by you at any time;

Information that you provide directly to us via email or electronic communication;

Information that you provide to us over telephone. We may make and keep a record of such information shared by you; and

Information that you provide to us in physical form whether sent through post or courier or handed over to our representatives in person.
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
When you register for an account on the Platform, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.
Every computer/mobile device connected to the internet is given a domain name and a set of numbers that serve as that computer's Internet Protocol or “IP” address. When you request a page from any page within the Platform, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed the Application.
How we use your information
We use the information we collect in various ways, including, but not limited, to:
Provide, operate, and maintain the Platform;
To fulfill the requests you raise on the Platform;
Improve, personalize, and expand the Platform and customize the content you see on the Platform;
Understand and analyze how you use the Platform in order to show you relevant content;
Develop new products, services, features, and functionality;
Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Platform, and for marketing and promotional purposes, with your consent;
Send you relevant emails should you sign up for promotional content, and emails in the ordinary course of the requests raised by you on the Platform; and
Find and prevent fraud.
Log Files
eLocals follows a standard procedure of using log files. These files log visitors when they visit the Platform. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable or Sensitive Personal Data or Information. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the Platform, and gathering demographic data.
Cookies and Web Beacons
Like any other website, the Platform uses 'cookies'. Cookies are small pieces of information saved by your browser. Cookies are used to record various aspects of your visit and assist us to provide you with uninterrupted service. Cookies may be set in your browser by us when you access the Platform or may be set in when you visit Third Party apps or websites. This anonymous information is maintained distinctly and is not linked to the Sensitive Personal Data or Information that you submit to us. We use cookies collected to:
Authenticate your login information;
Enable our security features;
Show you advertising; and
Improve and develop the features of the Platform.
Please feel free to change your browser settings if you do not wish to accept cookies. However, please note that changing your browser setting may affect your experience on the Platform.
For more general information on cookies, please read "What Are Cookies" from Cookie Consent.
Advertising Partners Privacy Policies
You may consult this list to find the privacy policy for each of the advertising partners of eLocals on the Platform.
eLocals Third-party ad servers or ad networks use technologies like cookies, JavaScript, or web beacons that are used in their respective advertisements and links that appear on the Platform, which are sent directly to your browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.
Note that eLocals has no access to or control over these cookies that are used by third-party advertisers.
Third Party Privacy Policies
The Privacy Policy does not apply to other advertisers or websites. Thus, you are advised to consult the respective privacy policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.
SHARING OF INFORMATION
To the extent necessary to provide you the services on the Platform as well as services requested by you through the Platform, we may provide your Sensitive Personal Data or Information to the following Third Parties without notice to you:
Supply Partners, who work on behalf of or with us to provide you with such services, to help us communicate with you or to maintain the Platform, on a 'need to know' basis;

Governmental authorities, in such manner as permitted or required by applicable law; and

another business entity, should we plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur, that other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to your Sensitive Personal Data or Information

By using the Platform you expressly consent to us sharing such information as described above.
LINK TO THIRD PARTY APPS AND WEBSITES

The Platform and any other communication sent to you may also contain/display third party advertisements and links to other websites, applications or products and services. You agree and acknowledge that these websites and applications are operated by third parties and are not controlled by, or affiliated to, or associated with us, unless expressly specified. We are not responsible for any form of transmission, whatsoever, received by you from any such third party. Accordingly, we do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites or applications, nor do we control or guarantee the accuracy, integrity, or quality of, without limitation, the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites or applications. The inclusion or exclusion does not imply any endorsement by us of such websites, applications, the third party, or the information on such websites or such applications. The information provided by you to such third party websites or applications shall be governed in accordance with the privacy policies of such websites or applications and it is recommended that you review the privacy policy on any such websites and applications prior to using such websites or applications.
These third party websites and applications and advertisers may use technology to send advertisements directly to your browser. In such cases, the third party websites, applications or advertisers automatically receive your IP address. They may also use cookies, JavaScript, web beacons and other technologies to measure the effectiveness of their advertisements and to personalize advertising content. We do not have access to or control over cookies or other features that such third party websites and applications and advertisers may use, and the information practices of these third party websites and applications and advertisers are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices.

SECURITY OF INFORMATION
We strive to ensure the security, integrity and privacy of your Sensitive Personal Data or Information and to protect your Sensitive Personal Data or Information against unauthorized access, alteration, disclosure or destruction. The Platform has stringent security measures (physical, electronic and managerial) in place to protect against the loss, misuse, and alteration of the Sensitive Personal Data or Information under our control. You shall have a right to view and modify the contents of your profile on the Platform. Whenever you change or access your account information, we offer the use of a secure server. The Platform servers are accessible only to authorized personnel and your information is shared with our employees and authorized personnel on a 'need to know' basis, to complete the transaction and to provide the services requested through the Platform.
We are not responsible for any breach of security or for any actions of any third parties that receive your Personal Information and Sensitive Personal Data or Information. The services are also linked to third party sites and we are not/shall not be responsible for the privacy practices or the content of such sites.
Notwithstanding anything contained in this Privacy Policy or elsewhere, we shall not be held responsible for any loss, damage or misuse of your Sensitive Personal Data or Information, if such loss, damage or misuse is attributable to a Force Majeure Event.
DATA RETENTION
Your information will be retained with eLocals and/or its affiliates and/or agents as long as your account is active. If you wish to cancel your account or request that the eLocals no longer uses your information, you may contact eLocals at [•] or send an email to [insert email id]. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements or for other business purposes.
CCPA Privacy Rights (Do Not Sell My Personal Information) [Company to confirm if CCPA is required, this would not be necessary in case the Platform is only intended for use in India.]
Under the CCPA, among other rights, California consumers have the right to:
Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business delete any personal data about the consumer that a business has collected.
Request that a business that sells a consumer's personal data, not sell the consumer's personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
GDPR Data Protection Rights [Company to confirm if GDPR provisions are required, this would not be necessary in case the Platform is only intended for use in India and not by EU subjects.]
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
Children's Information
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
eLocals does not knowingly collect any Sensitive Personal Data or Information from children under the age of 18. If you think that your child provided this kind of information on our website, you should contact us immediately and we will do our best efforts to promptly remove such information from our records.
USER PRIVACY RIGHTS
If you are an Indian resident, you have the following rights and we commit to provide you with the same:
You have the right to get confirmation and access to your Sensitive Personal Data or Information that is with us along with other supporting information.
You have the right to ask us to rectify your Sensitive Personal Data or Information that is with us that you think is inaccurate. You also have the right to ask us to update your Sensitive Personal Data or Information that you think is incomplete or out-of-date.
You have the right to withdraw your consent provided to us for processing and sharing of your Sensitive Personal Data or Information. Upon your request of such withdrawal, we shall promptly return/delete/de-identify (as may be feasible) all your Sensitive Personal Data or Information belonging with us. However, we shall no longer be able to provide you our products/services upon withdrawal of such consent by you.
You may request a readable copy of the Sensitive Personal Data or Information you have provided us. If you would like a copy, do get in touch with us at 27.06.2017.
NOTIFICATION OF CHANGES
We may update this Privacy Policy at any time, with or without advance notice. In the event, there are significant changes in the way we treat your Personal Information, or in the Privacy Policy document itself, we will display a notice on the Platform so that you may review the changed terms prior to continuing to use the Platform. As always, if you object to any of the changes to our terms, and you no longer wish to use the Platform, you may contact [•], to deactivate your account. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.
Using our services or accessing the Platform after a notice of changes has been sent to you shall constitute your consent to the changed terms.
ADDRESS FOR PRIVACY QUESTIONS
Should you have questions about the Privacy Policy or our information collection, use and disclosure practices, you may contact us at the address: [•]. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of your personal information. Except where required by law, we cannot ensure a response to questions or comments regarding topics unrelated to this Privacy Policy or our privacy practices.
GRIEVANCE OFFICER
In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer of the Company are provided below:
27.06.2017
[insert designation]
Contact Number: 27.06.2017
Email Id: 27.06.2017