1. Introduction

1. 1.1 This Privacy Policy covers information Adsto Media House collects from the User from the website www.adsto.in
2. (a) This Privacy Policy should be read in conjunction with the Terms of Use (“Terms”) made available on the Website. Personal Information of a User(s) is collected if the User(s) registers himself/herself on the Website, accesses the Website, or takes any action on the Website. The terms 'Personal Information, 'Sensitive Personal Data', and 'Information' shall have the meaning ascribed to them under the applicable laws in India.
3. (b) Your use of our Services offered on the Website by checking the "I Agree" or "Agree "or "I Accept" or "Accept" tabs/ buttons on the Website as a part of the registration process or otherwise or by accessing this Website, You consent to the Company's collection, storage, processing and transfer of your Personal Information or Sensitive Personal Data or Information in accordance with this Privacy Policy, agree and undertake to abide, be bound by and adhere to this Privacy Policy and the Terms that are accessible on this Website and any other terms which govern the Website and if You do not agree to this Privacy Policy, You are not entitled to avail of / use the Services and any use thereafter shall be unauthorized.
4. 1.2 The Company respects your privacy and values the trust you place in us by providing personal information as required, and this Privacy Policy sets out the policies and practices in relation to the collection, use, disclosure, and protection of the personal information of the Users of the Website.
5. 1.3 All capitalized terms and terms used in the Terms which are also used herein below shall be ascribed the same meaning as set out in the Terms, unless repugnant to the context herein or otherwise have been specifically defined herein.

2. Applicability of Privacy Policy

This Privacy Policy shall be applicable only to the use and disclosure of information on the Website. This Privacy Policy does not apply to information collected by or through any other medium, collected offline or by any other person and/or entity other than the Website or any other website/app/ API's which might be present on the Website for example, if you click on a link of another website displayed on the Website, it may direct you to the other website or application in which case this Privacy Policy shall not be applicable.

3. User Information

1. 3.1 The Company may collect several types of information about its Users. Some of this information may be given voluntarily by the User while availing Services offered on the Website and/ or [while registering oneself on the Website]; and while some information may be collected automatically when the User is surfing the Website.
   While collecting information directly from the person concerned, the Company or any person on its behalf (whether group companies, lawyers, chartered accountants etc.) will take such steps as are, in the circumstances, reasonable to ensure that the person concerned is having the knowledge of — (a) the fact that the information is being collected; (b) the purpose for which the information is being collected; (c) the intended recipients of the information and (d) the name and address of — (i) the agency that is collecting the information; and (ii) the agency that will retain the information.
2. 3.2 Information provided voluntarily

   It may be noted that the Company may require you to voluntarily provide information about yourself in the following events:

   • (a) when you fill out a form/ application to avail of the Services provided by the Company on the Website;
   • (b) when you communicate with the Company or make a request on the Website; via e-mail, phone or SMS;
   • (c) to evaluate your eligibility for certain types of offers and services;
   • (d) to perform analytics and conduct customer research, including general market research or surveying our customers' needs and opinions on specific issues, generating sales and traffic patterns, and to analyze advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis (if legally permissible);
   • (e) when you choose to provide reviews or ratings, account settings, (including preferences set in the "Account" section of our Website), or otherwise provide information to the Company through our service or elsewhere; and
3. 3.3 In any of the aforesaid events, you may be required to provide the following information:
   • (a) Your name;
   • (b) Date of birth;
   • (c) Contact details including postal address, pin code, email address, phone number, and residency status;
   • (d) Personal details such as age, sexual orientation, marital status, occupation, interests if any etc.;
   • (e) Details of talent, skills;
   • (f) Work experience; and
   • (g) Income.
4. 3.4 You may note that it is possible that we may collect personal information about You from other Users of our Services and our business partners, if any. However, any such information shall not be considered to be sensitive, if it is freely available in the public domain, or under (Indian) Right to Information Act, 2005 or under any other applicable law for the time being in force.
5. 3.5 The Company may also use the Personal Information or Sensitive Personal Data or Information provided by You for content recommendations, transactional emails or to provide You with information, direct marketing, online and offline advertising and other materials regarding services and other offers from time to time.he Company may also use the Personal Information or Sensitive Personal Data or Information provided by You for content recommendations, transactional emails or to provide You with information, direct marketing, online and offline advertising and other materials regarding services and other offers from time to time.
6. 3.6 Information retrieved/collected automatically

   The Company may collect a variety of technical, navigational and other non-personal information about you such as your types of browsers, usage patterns, geo-location of a browser, address of your server from where the Website is being accessed, [tabs and pages of the Website visited or URLs visited after use or access to the Website etc. when you visit the Website], through the following:

   • (a) Cookies : The Website may assign a 'cookie' to you, encrypting your information, which may be saved on your computer's hard drive while you visit the Website. This will help adjust and track your preferential information every time you visit the Website thereafter. You may note that this Privacy Policy includes 'cookies' that are placed by the Website and does not cover any 'cookie' that may be placed by any third-party website/ app. The internet browser may allow you to not store any cookies on your computer; however you may note that, in such an event your navigation through the Website or access to certain features/ services of the Website may be restricted.
   • (b) Beacons/Bugs : A beacon is a picture file used to keep track of your navigation through a single website or a series of websites. The Company may use such web beacons to study and analyze the usage of the Website.
   • (c) Usage Details : (c)The Website may also collect details regarding your visits to and navigation through the Website such as your location data, geo-locations other resources that you access etc.

4. Eligibility, use and information

1. 4.1 You are eligible to register and avail the Services provided on the Website only if you are an Eligible Person.

5 Consent given by User

You hereby expressly grant your consent to the Company through the Website to collect, possess, receive, upload, store, deal with, handle and/or use, share, disclose and transfer the Personal Information and/or Sensitive Personal Data or Information to such persons and for such lawful purposes as contained in this Privacy Policy. Further, you also hereby grant your consent to enable the Website and/or its independent service providers to collect non-personal data by placing cookies, etc. Once the personal information and/or sensitive personal data are collected, the Company shall have the right to use the same for the purposes for which the same were collected.

6 Purposes for collection and usage of information

1. 6.1 Our primary purposes in collecting information including Personal Information or Sensitive Personal Data or Information from You is to allow You to use the Website and various features on or in relation to the Website for the Services provided by the Company, its affiliates, its service providers, its business partners; to record Your information and details as permitted and required under applicable laws, statutory direction or judiciary orders; to serve various promotion materials and advertising materials to You; and such other uses as provided in the Terms and this Privacy Policy.
2. 6.2 Personal and non-personal information collected by us, will be used by the Company in handling general enquiries concerning its services and products, in providing better User interface, making your visit to the Website more User-friendly and without limiting the foregoing, for the following purposes:
   • (a) Registering your account with the Website;
   • (b) enabling access of the Website and use of the Services available to Users;
   • (c) addressing questions, doubts, queries raised, clarifications and information sought and for addressing technical issues which arise on the Website;
   • (d) designing or identifying services, data, information or related products for Users;
   • (e) marketing (including direct marketing) of products/services, send information, materials and offers from the Company;
   • (f) meeting the requirements to make disclosure under any law binding on the Website, the Company, its directors, associates or employees, under and for the purposes of complying with any directions or guidelines issued by regulatory or other authorities with which the Website or the Company or any associated entity is expected to comply;
   • (g) in connection with any exchange of information and verification and authentication of the information that may be provided by the User, to evaluate the eligibility of the User or minor (as the case may be) for certain types of offers, products and services that may be of interest to you and analyse advertising effectiveness;
   • (h) to send you alerts, notices, letters, response to request and other customer support queries and/or any other communication which may be relevant and vital to the usage of the Website by you;
   • (i) to enable the Company as well as third parties to provide itself or procure from third parties customised information, services, offers and advertisements etc;
   • (j) to third party contractors that provide services to the Website;
   • (k) to internally analyse the performance of the Website, Company’s internal technical systems and data;
   • (l) to gather demographic data to research, analyse and understand trends and behavioural patterns, to measure and understand the effectiveness of any of the aspects of the Services provided by the Company on the Website, to troubleshoot any problems, track your movement, gather broad demographic information for aggregate use and to comply with the applicable law;
   • (m) to sell sample data to consulting firms or any third party assisting the Company make inferences and analysis;
   • (n) to alert you about potential software compatibility issues and/or for improvement of the Website;
   • (o) to monitor and administer daily operations and functions of the Website;
   • (p) to enforce the “Terms” of this Website;
   • (q) for all other purposes as may be disclosed when you provide personally identifiable information/sensitive personal data;
   • (r) all other incidental and associated purposes relating to the above and any other purpose which a User may from time to time agree;
   • (s) to determine your general geographic location, provide localized content, provide you with customized and personalized viewing recommendations of the projects which the Company thinks will be of interest to You;
   • (t) to prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing our terms (such as determining free trial eligibility); and
   • (u) to analyze and understand our Users, improve our service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery.

7. Disclosure of Personal Information

1. 7.1 The Company may disclose/ transfer and/or exchange your personal information including your personal data to and/ or with all such persons and/or entities, as may be required for the aforesaid lawful purposes, including but not limited to:
   • (a) any of its directors, associates or employees, or any of its affiliates;
   • (b) any agent, contractor or third party service provider who provides administrative, advertising and marketing agencies, telecommunications, computer, financial intermediary or other services to the Company in connection with the Website or the operation of the Company’s business and Services through the Website;
   • (c) any other person under a duty of confidentiality, including any member which has undertaken to keep such information confidential;
   • (d) any actual or proposed assignee of the Company or participant or sub-participant or transferee of the Company’s rights in respect of the information of the User;
   • (e) to any third party when you choose to avail certain Services/ facilities offered on the Website. In such an event, the Company does not take any responsibility for any misuse or unwarranted disclosure of such information that may be made to such third party;
   • (f) any person to whom the Company is under an obligation to make disclosure under and for the purposes of any guidelines issued by regulatory or other authorities;
   • (g) as may be required by law or court order or administrative/ government agency or in a situation of national emergency or when the Company believes that an information disclosure is required to protect the Company’s rights or those of the Company’s/ Website’s Users or any other aspect of the Website and to comply with the legal process without any restrictions;
   • (h) in any event where the Company has reason to believe that you are in violation of any applicable law, rule or regulation, or interfering with the rights of any other person;
   • (i) to any potential investor or purchaser of any interest in the Company or Website or any associated entity or in its business in connection with any potential re- organisation, merger or disposal; and
   • (j) any lawyer or other professionals for the preparation of any document or professional advice regarding the above.
2. 7.2 The Company will endeavour to ensure that the third party receiving any personal information does not disclose it further and shall observe the same level of data protection as is ensured by the Company in respect of the Website and in consonance with this Privacy Policy.
3. 7.3 Notwithstanding anything contained elsewhere, any Personal Information including Sensitive Data may be disclosed by the Company to any third party by an order/ direction under the law for the time being in force, without any consent or other obligation. For instance, Personal Information may be released to an officer making the request if he provides a warrant or a court order requiring such disclosure.
4. 7.4 Where a government agency makes a request to obtain information for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences, the Company may share the personal information without obtaining any prior consent of the User. The Company will be utilising the services of third party service providers such as technical service providers to create and support the Website, third party advertising company etc. The Company may publish or share your non-personal information in order to promote the Website with the Company’s affiliates, various third parties and Company’s service providers without your consent. You are informed that the Company’s third party service providers may utilise information relating to your usage of the Website in order to provide customised services, offers and advertisements to you.

8 Verification of Information

In the event that you choose to avail any service or facility that may be offered through the Website or put in a request or query with respect to the same, you shall have to register yourself with us and/ or provide personal information about yourself. You may note that the Company may (through its agents/ service providers) contact You either through e- mail, fax, telephone or personal visits for verification/ confirmation of the same.

9 Option to withhold / withdraw

Prior to collection of the Personal Information (including Sensitive Personal Data), the Website may give you an option to withhold the data/ information sought. Further, you may withdraw the consent given to the Company on the Website, by communicating to the Company in writing. However, such withholding of information or withdrawal of consent may result in the Company being unable to provide the Services and facilities and the Company reserves its right to take appropriate action with respect to any obligations or in relation to any contract under which such Personal Information was sought. It being clarified that such withdrawal of consent shall not affect the permission granted prior to such withdrawal and hence the Company shall not be liable for sharing personal information (as stated herein) in any manner whatsoever.

10 Accuracy of and Access to Personal Information

1. 10.1 The Company will not be responsible for the accuracy or authenticity of the Personal Information (including Sensitive Personal Data), if any that is provided by you. It is the responsibility of the User to notify the Company through the Website of any changes to their Personal Information. To attain this end, the User may request the Website for reasonable access to, and correction of, their Personal Information collected by the Website by emailing their request/clarification at contact@adsto.in. The Company makes good efforts to provide its Users with reasonable access to their respective Personal Information and shall ensure that any Personal Information found to be inaccurate and brought to the notice of the Company by the User is rectified or amended as feasible. The Company may however before processing such requests, ask the User to identify themselves and the information /data requested to be modified by them in order to avoid repetitive and/or illegitimate requests. The Company shall not be responsible for any delay in updating such information.
2. 10.2 In the event a User requests the Company to delete his/her Personal Information and/or his account, the Company shall ensure that such Personal Information/ user account is deleted within reasonable time period of receiving such a request. The Company may however before processing such requests, ask the User to identify themselves and the information /data requested to be deleted by them in order to avoid any illegitimate/bogus requests. Once the Personal Information/ user account is deleted, all data in respect thereof shall cease to be accessible to the User, and the Company may thereafter send an email to such User apprising him/her of such deletion. The User may contact the Company by emailing their request on contact@adsto.in
3. 10.3 It is clarified that, after the deletion of the Personal Information/ User account, the Company shall maintain records of the same for a period of 90 (ninety) days after which the same shall be deleted therefrom. It is clarified that even though the Company may maintain records of deleted data for 90 (ninety) days, once the Personal Information/ user account of a particular User has been deleted upon his/her request, the same shall not be retrievable by the User in any manner whatsoever and at any time thereafter.
4. 10.4 The Company may, however, withhold or may not be able to provide information to you for valid reasons including if it:
   • (a) contains references to another User(s);
   • (b) is subject to legal/ contractual privilege or cannot be disclosed for other legal reasons;
   • (c) contains confidential commercial/ business information of the Company or other Users of the Website;
   • (d) is not maintained by the Company;
   • (e) was created in the course of a dispute resolution process;
   • (f) could threaten the life or security of another individual/ entity;
   • (g) was disclosed under a court order or was disclosed to a government institution as part of an investigation.

11. Links to Third Party websites/ apps/ API’s

1. 11.1 The Website may display links of third party websites/ apps/ API’s such as any other websites/ apps etc. with an option of sharing information on such other websites/ apps. You may note that such links to third party websites/ apps are not an endorsement of such third parties, their websites/apps and/or their services. We do not take any responsibility for their privacy policy, terms of use, content, services provided by such third party websites/ apps. They may place independent cookies on your computer or independently contact you, for which the Company or Website shall not be held responsible or liable in any manner whatsoever. We encourage you to read individual terms of use and privacy policy or such similar terms, as the case maybe, of each of these websites/ apps/ API’s before using them and/or disclosing your personal information.

12. Publication

The dealing, handling and/ or using of any Personal Information (including that of Sensitive Personal Data) for any lawful purpose by the Website, including for the purposes and in the manner outlined above shall not constitute ‘publication’, in any manner whatsoever.

You hereby consent that the Company can upload on the Website testimonials, responses and comments that you may write.

13. Reasonable Security Practices & Procedures & Data Security

1. 13.1 The Company takes appropriate security measures to protect against unauthorized use, access, alteration and destruction of data; however, the Company does not guarantee that the information provided by You to the Website shall not be intercepted while being transferred over the internet. Access to all Users is password protected.
2. 13.1 The Company takes appropriate security measures to protect against unauthorized use, access, alteration and destruction of data; however, the Company does not guarantee that the information provided by You to the Website shall not be intercepted while being transferred over the internet. Access to all Users is password protected.
3. 13.2 You are responsible for maintaining the confidentiality of your login ID and password and shall not reveal the same to any third party. In the event you believe that your User information has been stolen or compromised, you must contact us immediately at contact@adsto.in. We shall endeavor to block your account or provide restricted access upon being informed of such an event in order to protect your identity and information. However, we shall not be responsible for any unauthorized use/access to your account or disclosure of any personal information by virtue of such an event.
4. 13.3 The Company understands the importance of data security and the Company wants the User experience with the Company to be as safe as possible. The Company has implemented reasonable safeguards and precautions to protect Your Personal Information or Sensitive Personal Data or Information, including technical and organizational measures against unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss, both in an online and offline context.
5. 13.4 The Company has adopted reasonable and best security practices and procedures and the Company maintains technical and organizational security measures and procedures to protect the security of Your Personal Information or Sensitive Personal Data or Information, which are consistent with measures used by other similar websites/ apps.
6. 13.5 Please understand that, while the Company strives to protect Your Personal Information or Sensitive Personal Data or Information against potential risks and exposures, there is no absolute security in the online sphere. Hence, the Company asks you to support our IT security efforts by not disclosing any of Your Personal Information or Sensitive Personal Data or Information data on the Website that is particularly sensitive or not required in the specific context. Furthermore, You can help the Company in protecting your personal data by signing off when You finish using login-protected areas of the Website.

14. Operation of this Website

1. 14.1 This Website may be operated from India as well as outside India. In the event you are located in any place other than in India, you shall ensure that you comply with the applicable laws in India as well as the local laws or regulations of the territory from which you access the Website or the facilities and services provided by the Website.
2. 14.2 The Company may transfer information that may be collected by the Company about You, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If You are located in any European Union country or United States or other regions with laws governing data collection and use that may differ from Indian laws, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as Your jurisdiction.

15. Amendments/ Changes to Privacy Policy

1. 15.1 This Privacy Policy may be revised from time to time at the sole discretion of the Company without any advance intimation to you. Your continued use of the Website following such revision or modification shall constitute your acceptance of the revised Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices and keep yourself informed about the updated Privacy Policies.

16. Complaints

In the event that you are unhappy and or have a grievance with respect to (i) any service/ product or facility that is provided on the Website; and (ii) any other activity that may take place on the Website, or if you have any questions, comments, concerns or feedback regarding this Privacy Policy and/or this Website, you may bring the same to the notice of our Grievance Officer, whose details are given below and/or lodge a complaint with us. We shall ensure that we take all the necessary steps to address your questions, comments, and concerns to the best of our abilities.

Name: Mr. Shivanand M. Lalwani
Address: Mumbai
Email address: shivanand@adsto.in
Contact number: +91 98337 49180

17. Contact us

For general queries and communication you may also contact us at the same address mentioned in Clause 16 above.