1. Introduction

This Privacy Policy describes how Cointab Software Private Limited collects and uses Personal Information about you through the use of our Websites and our products and services. Cointab Software Private Limited, its subsidiaries, and affiliates (“Cointab” or “We “) respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or which you may provide to us when you license or use our software, visit websites that we own and operate, including, but not limited to cointab.in, and other websites owned or operated by Cointab, including local websites in your country (collectively, our “websites”), attend or participate in a trade show, marketing event, or through an agreement entered into between Cointab and you and/or your employer. The Privacy Policy also describes how we collect, use, maintain, protect, and may disclose such information.

This policy applies to the information we collect:

• on our Websites
• in email, text, and other electronic messages between you and Cointab
• that you provide at marketing, trade shows, training registrations, and other similar events
• that you or your employer provide as part of an agreement between you or your employer and Cointab for our products and services

It does not apply to information collected by:

• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites.

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification, or if you subscribe to our product and services, through the notification section in your Cointab account. If you do not agree with this Privacy Policy, you should not use our websites, product and services, or any other sites or services that link to this Privacy Policy.

2. Information We Collect About You and How We Collect It
When you interact with us via our websites or any sites or services that link to this Privacy Policy or use our product or services, we may collect Personal Data and other information from you, as further described below.

We collect various information from different sources, including our Users.

1. Information Users Submit to Us

Information You Provide to Us

Users of our Service (“Users”) may provide a variety of information to us through the Service.

This includes:

• Users’ own contact information, such as name, email address, telephone number, etc.
• Users’ web enquiry or any interaction with us
• We may request and users may provide additional information when they set up an account with us
• If we provide a payment option, we may collect payment data
• Information that you or your employer provides as part of an agreement for our goods and services
• Records and copies of your correspondence (including email addresses), if you contact us for support
• You also may provide information to be published or displayed (hereinafter, “posted “) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”)

Information We Obtain From Other Sources

We may also obtain information from third party sources, such as data providers, or from public sources and methods, such as information available on public APIs and the internet.

We refer to all of the above information referred to in this Section 1 as “Service Information.”

2. Information We Collect Automatically
We also collect a variety of information from our Users, when they visit our website or use our Service. We refer to this information, which we describe below (in this Section 2), as “Website Information.”

First, if you visit our website (or open an email that we send you), we and third parties may use automated means to collect information about you, your computer or other device, and your use of the Service. These automated means include technologies such as cookies, Web server logs, Web beacons and JavaScript, as well as functionality that can collect data from a mobile device.

Cookies are files that websites and online services create and access on your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Service may use HTTP cookies, HTML5 cookies, Flash cookies and other types of local storage (such as browser-based or plugin-based local storage). If you use the Service, your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies or local storage you may not be able to use all of the features of our website or other websites.

In conjunction with the gathering of information through cookies and other automated means, Web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record information such as the address of the Web page that referred you to our Service and the IP address of the device you use to connect to the Internet. They also may log information about your interaction with our Service, such as which pages you visit. To control which Web servers collect information by automated means, we may place tags on our Web pages called “Web beacons,” which are files that link Web pages to particular Web servers and their cookies. We also may include Web beacons in e-mail messages. We or third parties also may send instructions to your device using JavaScript or other computer languages to store or gather the sorts of information described above and other details about your interactions with the Service.

If we provide a mobile app, we or third parties may collect information similar to the data mentioned above. In that case, we also may collect unique device identifiers (such as advertising IDs) and other mobile-specific types of information. For example, depending on your device and/or browser settings, we may collect your device’s geolocation.

3. How We Use Your Information
We use the Service Information that we collect about you or that you provide to us to render our Services to you including:

• to provide you with information, products, or services that you request from us
• to provide support to you
• to analyze how the Service is used

We use the Website Information to provide, improve, maintain and evaluate the Service, including:

• to understand or analyze how you use the Service and how we might improve or change them
• to verify your identity and establish your account
• to send you updates, emails, newsletters and other information that may be of interest to you

4. Data Security
We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.

5. Information About Children
Our products and services are not directed to individuals under 16. We do not knowingly collect personal information from children who are under 16 years of age for our own purposes. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 16 years has provided personal information to us, please write to privacy@cointab.in with the details, and we will take the necessary steps to delete the information we hold about that child.

6. Data Controller, Data Protection Officer, and Representative
Cointab Software Private Limited is the data controller of your Personal Data that you provide on the Websites. The specific Cointab affiliate company or subsidiary that you contract with or that collects your Personal Data is the data controller for your Personal Data when we obtain it from all other sources and Cointab Software Private Limited may be the co-controller under applicable international, federal, state, or local privacy laws, including the General Data Protection Regulation (“Applicable Privacy Laws “) for this data. Cointab or its Data Protection Officer may be contacted in any manner set forth below in the “Contact Information ” Section of this Privacy Policy.

7. Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests, to fulfill our obligations to you under our contract with you (or your employer), as required by law, and with your consent.

We have a lawful basis for each of our processing activities:

Legitimate Interests:
We will process your Personal Data as necessary for our legitimate interests to: facilitate communication between Cointab and you; improve our Websites, products, and services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote our business; to provide you with information that you request from us; and check your credit and perform risk assessments;

To Fulfill Our Obligations to You Under Our Contract:
We process your Personal Data in order to fulfill our obligations to you pursuant to our contract with you to deliver our goods and services to you.

As Required by Law:
We may also process your Personal Data when we are required to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal processes such as subpoenas when we have a good faith belief that such requests meet the applicable legal standards; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies, defend litigation, and manage complaints or claims

Consent:
By using our Websites or entering an agreement for Cointab to provide you our products and services, you consent to our collection, use, and sharing of your Personal Data as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Websites or enter into an agreement with Cointab.

8. Disclosure of Your Information
1. We may share the service information with the following parties:

• Companies that perform services for us, with us, or on our behalf, providers of technical infrastructure and technical and customer support, hosting providers, billing support and payment providers
  
  

2. We may share the website information with the following parties

• With companies that perform services for us, with us, or on our behalf, including without limitation advertising companies, providers of technical infrastructure and technical and customer support, hosting providers, billing support and payment providers, advertising, data enhancement and marketing partners, and e-mail service providers
• Without restriction when the information is aggregated, anonymized or de-identified

3. We may share both the service and website information:

• With other members of our evolving corporate family
• In connection with efforts to detect and address fraud, credit risk, security or technical issues
• Without restriction when the information is aggregated, anonymized or de-identified
• In connection with significant corporate events. For example, we may share or disclose information we have about you in the event we sell or transfer all or a portion of our business or assets — such as in connection with a merger, acquisition, reorganization, bankruptcy, dissolution or liquidation — or take steps such as due diligence in anticipation of any such event
• When we believe in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible unlawful activities or to comply with legal process or other legal requirements; when we deem disclosure appropriate in situations involving potential threats to the physical safety of any person, potential violations of our terms (such as our Terms of Service), or claims of violation of the rights of third parties; or when we deem disclosure appropriate to protect the rights, property and safety of us, our employees, users, or another person or entity
• In any other circumstance where we have appropriate consents or are otherwise permitted by law to share it

9. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Data you provide to us. We will only use your contact information to promote our own or third-party products and services. If you wish to change your choice, you may do so by responding to our messages or by logging into the Websites and adjusting your user preferences in your account profile. This opt-out does not apply to information provided to Cointab as a result of a product purchase, warranty registration, product service experience or other transactions.

10. Your Privacy Rights and Choices
You may have certain rights under Applicable Privacy Laws, including the right to access and update your Personal Data, restrict how it is used, withdraw your consent at any time, and the right to have us erase certain Personal Data about you.

Access and Update:
You can review and change your Personal Data by logging into the Websites and visiting the “Edit Profile” page. You may also request access or changes to the Personal Data by using contact information listed below.

Withdrawal of Consent:
To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.

Right to be Forgotten:
You have the right to request that we delete all of your Personal Data. Upon receiving such a request we will only delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies. If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Websites users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

Complaints:
You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

How You May Exercise Your Rights:
You may exercise any of the above rights by contacting us through any of the methods below and by filling the contact page of our Websites. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.

11. Locations and International Transfers
We may process your Personal Data outside of your home country, including India, the United States, the European Economic Area (EEA) and other countries where Cointab operates. We only do this when we are legally permitted to and when we have appropriate safeguards in place to protect your Personal Data.

We share your personal information and service data within Cointab and with third parties engaged by Cointab for the purposes described above. By accessing or using our products and services or otherwise providing personal information or service data to us, you understand that the processing, transfer, and storage of your personal information or Service Data may happen within India, the United States of America, the European Economic Area (EEA) and other countries where Cointab operates.

12. Data Retention Periods
We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

13. Contact Information
If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, you may contact us through the “Contact Us ” page on our Websites or via postal mail at:

Gaurav Bansal
Data Protection Officer
Cointab Software Private Limited
515, Palm Spring Centre, Link Road, Malad West, Mumbai – 400064
privacy@cointab.in