Effective from: 2 September 2022
1. Collection of Personal Data
The following minimum personal data is collected when a user signs up for the Service or while the user uses the Services, through the application.
We may ask you for the Payment Details to process payments for the Services. We may ask You to provide certain additional information about yourself on a case to case basis.
Transactional Information: If you choose to avail of the Services through the App, We will also collect and store information about your transactions including transaction status, order history, number of transactions, details and your behaviour or preferences on the App.
Location-based Information: When and if you download and/or use the App through your mobile, We may receive information about your location, IP address, including a unique identifier number for your device. We may use this information to provide you with location-based Services including but not limited to search results and other personalized content. If you permit the App to access your location through the permission system used by your device operating system, We may also collect the precise location of your device when the App is running in the foreground or background. You can withdraw your consent at any time by disabling the location-tracking functions on your device. However, this may affect your experience of certain functionalities on the App. Your IP address is also used to help identify you and to gather broad demographic information.
2. Use of Personal Data
Crivly may use, combine and process your Personal Data for the following purposes (“Purposes”):
Providing Services and Features
Your Personal Data will be used to provide, personalise, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:
- provide you with Services across our various business verticals;
- engage you to provide Services;
- create, administer and update your account;
- verify your identity;
- verify your age (where necessary);
- enable features that personalise your App, such as lists of your favourite places and previous orders;
- make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;
- perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
- protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
- process and manage your rewards;
- enable communications between our users;
- process, manage or verify your eligibility for or application of promotions, rewards and subscriptions with Crivly;
- fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom Crivly is providing services on behalf of) for such services to be rendered.
We use Personal Data to resolve user support issues. For example, we may:
- investigate and address concerns;
- monitor and improve our user support responses;
- respond to questions, comments and feedback; and
- inform you about steps taken to resolve user support issues.
Research and Development and Security
We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services.
Marketing and Promotions
We may use your Personal Data to market Crivly and Crivly’s partners, sponsors and advertisers products, services, events or promotions. For example, we may:
- send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
- notify, invite and manage your participation in our events or activities.
If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message.
3. Provision of Personal Data
Crivly does not provide personal data to any third party without your consent or unless demanded by applicable laws.
Crivly shall provide no personal data to any third party without the user’s prior consent; provided, however, that Crivly provides the foregoing personal data to the third parties within a scope required to provide affiliated services to users, only upon user’s prior consent.
With our legal advisors and governmental authorities
We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:
- where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or
- where it is necessary for the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).
4. Security Precautions and Measures
Crivly has reasonable security measures and safeguards in place to protect your privacy and Personal Data from loss, misuse, unauthorized access, disclosure, destruction, and alteration, in compliance with applicable laws. Further, whenever you change or access your Account on the App or any information relating to it, We offer the use of a secure server. It is further clarified that you have and so long as you access and/or use the Platform (directly or indirectly) the obligation to ensure that you shall at all times take adequate physical, managerial, and technical safeguards, at your end, to preserve the integrity and security of your data which shall include and not be limited to your Personal Data.
You will be responsible for maintaining the confidentiality of the Account information and are fully responsible for all activities that occur under your Account. You agree to immediately notify Crivly of any unauthorized use of your Account information or any other breach of security. Crivly cannot and will not be liable for any loss or damage arising from your failure to comply with this provision. You may be held liable for losses incurred by Crivly or any other user of the App due to authorized or unauthorized use of your Account as a result of your failure in keeping your account data secure and confidential.
When payment information is being transmitted on or through the App, it will be protected by encryption technology. You expressly consent to the sharing of your information with third-party service providers, including payment gateways, to process payments and manage your payment-related information. Hence, the Company cannot guarantee that transmissions of your payment-related information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by the Company or the Company’s third-party service providers. The Company assumes no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond its control. You play an important role in keeping your Personal Information secure. You shall not share your Personal Information or other security information for your Account with anyone. The Company has undertaken reasonable measures to protect your rights of privacy with respect to your usage of the App-controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful disclosures of your Personal Information made by any third parties who are not subject to Our control.
- any security breaches on third-party websites or applications or for any actions of third parties that receive your Personal Information; or
5. Your Rights with Respect to Your Personal Data
In accordance with applicable laws and regulations, you may be entitled to:
- ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;
- request the correction and/or (in some cases) deletion of your Personal Data;
- in some cases, request the restriction of the processing of your Personal Data, or object to that processing;
- withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
- complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Data.
Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to process and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
6. Grievance Officer
We have appointed a grievance officer in accordance with the Information Technology Act, 2000 and the rules made thereunder, for the purpose of redressing any grievances or complaints you may have regarding the handling of your Personal Data. If you have any grievances, or complaints or concerns with respect to Crivly, the Content, or the Services, you can contact the designated Grievance Officer of Crivly at email@example.com.
For any inquiries, complaints, feedback or other matters related to Personal Data protection that arise while you use the Services, please contact us at firstname.lastname@example.org. Crivly will do its best to listen to you and promptly answer any questions you may have.