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DATED: October 14, 2024
a.This Privacy Statement is issued on behalf of OCEAN PAINTS PRIVATE LIMITED. When we mention "Organization", "we", "us" or "our" in this Privacy Statement, we are referring to the relevant entity within OCEAN PAINTS PRIVATE LIMITED responsible for handling your data.
b.We are dedicated to safeguarding and respecting your privacy and maintaining the confidence and trust of our clients. This privacy statement ("Privacy Statement") elucidates how your personal details are gathered, why they are collected and how they are kept secure. We are committed to fulfilling obligations under all applicable global data privacy regulations, including the General Data Protection Regulation (‘GDPR’), the California Consumer Privacy Act (‘CCPA’), the Virginia Consumer Data Protection Act (‘VCDPA’), the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) (and any provincial substantially similar law as applicable).
a.Personal Information refers to any data about you, regardless of its veracity, where your identity is evident or can reasonably be determined from that information. When anonymous information is directly or indirectly linked with personal information, the resulting data is also regarded as Personal Information. Anonymous information implies data that does not directly or indirectly identify and cannot reasonably be utilized to identify an individual. Aggregate information denotes data about groups or categories of customers that does not identify and cannot reasonably be used to identify an individual customer.
b.We gather two fundamental types of information – Personal Information and anonymous information， and we may utilize personal and anonymous information to create a third type of data, aggregate information.
c.We collect:
Contact particulars such as your first name and last name, email address, residential location and mobile or other telephone numbers;
Personal details such as gender, age, age bracket or your image; account login credentials, including your username, password and pictures associated with your profile;
Information transmitted bilaterally or within a small group using email, postal mail or other communication methods;
Information we obtain from a third party, such as a site or platform provider, regarding your utilization of or interest in our services;
Location data including location information provided by a mobile or other device interacting with one of our Websites, or associated with your IP address, where we are permitted by law to process this information;
Activity, technical and device information about your usage of our Game, such as the content you view, the time and duration of your visit on our Game, how frequently you utilize our services, how you initially learned about our Game, your preferences and information about your interaction with the content offered through our Game, your hardware model, device type, other unique device identifiers, operating system version, browser type and IP address; and
Sensitive data such as biometric information, geolocation, driver's licenses and financial details to comply with our legal and regulatory aims.
a.When you interact with our Game, we strive to make that experience straightforward and useful. We and our partners utilize industry-standard identifiers, such as cookies or other comparable technologies.
b.Our Game might employ technologies to enhance your experience. These technologies are small files that are placed on your computer, tablet, mobile phone or other devices when you visit a website. They enable us to record certain pieces of information whenever you visit or interact with the Game. Usage information may comprise, in part, browser type, operating system, device type, an estimate of your geographical location associated with your IP address, the location of your mobile device, the page served, the time, referring URLs and other information typically transmitted in HTTP requests. This statistical data provides us with information about your utilization of the services, such as general engagement with a page, the kind of content on that page and how long you remain on that page. Usage information is generally non-identifying but if the Organization associates it with you as a specific and identifiable person, the Organization will treat it as Personal Information.
c.The following are instances of these types of technologies:
APIs. APIs function by enabling different types of software to communicate with one another. They make life a great deal easier for programmers and offer a better experience for end users.
Cookies. These are small text files placed in your device browsers to store your preferences. Most browsers permit you to block and delete cookies. However, if you do that, the service might not function properly.
Event tagging. Event tagging enables us to track actions that occur on the Game such as application installations and purchase events. By tracking these events we can view analytics, measure ad performance, and build audiences for ad targeting.
Mobile device identifiers. We may share the advertising identifier associated with your mobile device or tablet (such as the Apple IDFA and Google Advertising ID) with advertisers. It is used to identify your device for internet-based advertising. For instructions for using the advertising choice mechanisms provided by the most popular mobile operating systems, visit the NAI’s Mobile Choices page here.
Pixel tags/web beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Game that gathers information about your engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted upon or forwarded.
a.We gather information in various ways, as set forth below. You confirm that any contact information you provide is true and accurate.
b.Information you directly supply to us including when you visit our Game, register on the Game, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make accessible on our Game.
c.In addition to collecting information via our Game, we collect information from you by telephone, video or in correspondence (including email, live chat, mail, text message or social media). All telephone or video calls between you and Organization representatives may be recorded for training, quality control and compliance purposes and by continuing with any such call you consent to it being recorded.
d.We also collect information about your utilization of our products and services through a variety of technologies that are present when you visit our Websites, including the Game, or use our applications on third party sites or platforms (whether or not you are logged in or registered) including cookies, flash cookies, pixels, tags and application programming interfaces (“API”).
e.Please see the section titled “Personal Data Collected via Technology” below for further details. Analytics tools are also employed by us to collect information, including when you visit our Game or use our applications or services on third party sites or platforms.
f.Finally, we also utilize trusted sources to update or supplement the information you provided, or we have collected, including in order to verify or validate information (for example, postal address, documentation and names).
a.We utilize the information collected to operate our Game and to provide our products and services, to respond to your inquiries and to fulfill all applicable regulatory requirements.
b.In accordance with applicable laws and any options made available to you, the Organization may collect and use your information for the following specific purposes:
To provide and manage the services you request - This includes, for instance, processing your registration, setting up and taking care of your account, including checks made to prevent fraud.
To enhance customer service and our services - Information you provide assists us in responding to your customer service requests more effectively; we may use the feedback you provide to improve our products and services.
To personalize user experience - We may use information that has been aggregated to understand how our users as a group utilize the services and resources provided on our Game.
To contact you about our services including marketing - For example by email, live chat, telephone, text message, mail or social media..
To comply with our legal and regulatory obligations - We may use information we collect about you for regulatory obligations (including the detection, investigation and prevention of activity that violates our terms and conditions or that may be illegal).
To offer alternative dispute resolution services - We may provide information we collect about you to our service provider partner for the specific purpose of resolving any disputes that have not been satisfactorily resolved through our internal processes.
To conduct market research and analysis – to analyze how you interact with our products and services; to monitor and analyze usage and activity trends; and for other research, analytical and statistical purposes.
c.We do not utilize automated decision making within the definition of global data protection laws.
d.We may collaborate with a third party service provider to either display advertising on our Game or any application accessible via our Game or to manage our advertising on other websites. Our third party service provider may use technologies such as cookies to gather information about your activities on our Game and other websites in order to provide you advertising based on your browsing activities and interests.
a.If we process your personal information for the purpose of direct advertising, you have the right to object at any time to this processing; this also applies to profiling, where appropriate, insofar as it is associated with such direct advertising.
b.You may opt out of receiving commercial messages from us by following the instructions contained in those messages or by contacting Customer Support. In the event of your objection to processing for the purpose of direct advertising, we will no longer process your personal information for these purposes.
c.We recognize that by law and subject to certain conditions, you have several rights regarding the personal information we hold about you. These rights include the right to access the personal information we hold about you, the right to object to the processing of your data, the right to update and correct the information we hold about you, and the right to request the deletion of the personal information we hold about you in some circumstances.
d.We will not discriminate against you (e.g., through denying products and services or providing a different level or quality of goods or services) for exercising any of the rights granted to you.
e.If you would like to use an agent authorized in accordance with applicable law to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise those rights on your behalf.
a.We have implemented physical, electronic and operational procedures to safeguard the information that we collect. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Game. Our security measures are regularly reviewed and updated to keep pace with technological advancements.
b.We use reasonable means to protect your personal information from misuse, interference, or loss, as well as any unauthorized access, modification or disclosure.
c.If we believe that a notifiable data breach has occurred, we will comply with the legislative requirements to notify you of the data breach and any steps taken by the Organization to contain and investigate the data breach.
a.We will keep your information for a period of time to reasonably fulfill the purposes specified in this Privacy Statement, unless a longer retention period is required by law.
b.We will take reasonable steps to destroy or permanently de-identify any Personal Information where:
we no longer need the Personal Information for any purpose for which the Personal Information was collected or for a related purpose; and
we are not required by law, a regulator or a court/tribunal order, to retain the Personal Information.
a.We do not sell, trade, or lease your personal information. However, there are circumstances when we share your personal data with the following categories of third parties:
Affiliates – other companies within the Organization;
Service providers – other companies who provide services to you on our behalf; and
Third parties that interact with us in connection with the services we perform.
If data will be shared with a third party, we require them to maintain the same level of protection over your data as we provide directly to you and to only perform services on our behalf. In simple terms, they are prohibited from using your personal information for purposes other than those requested by us or required by law.
b.We only share information with third parties in limited circumstances including the following:
when you permit us to share your information with third parties;
when providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;
in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, when ordered to do so by any regulatory body and/or under any legal provision contained in the governing law of a particular jurisdiction;
when instructing and authorizing the financial institution with which a user’s account is held to disclose any information as may be requested by a regulator in respect of the user’s account;
to enforce our terms and conditions set out on our Game, to protect our rights and property and the rights and property of our customers and third parties, to detect fraud or other illegal activities, and to comply with law or legal processes; and
to perform customer due diligence including ID verification.
a.This Privacy Statement may be updated from time to time to reflect changes in the way we operate or the way our work is regulated. We will notify you of significant changes and, where required by law, will obtain your consent. Notice may be by the posting of such changes on our Game or by other means in accordance with applicable laws.
b.Any changes to the Privacy Statement will become effective when the updated statement is posted on our Game.
c.We encourage you to frequently check this page for any changes to stay informed about how we are helping to safeguard the personal information we collect.
d.This Privacy Statement, in effect as of the last modified date stated below, supersedes and replaces any and all Privacy Statements previously in effect.
a.If you have specific inquiries regarding your personal information or how we use it, please contact our Data Protection Officer directly by email at [email protected].
b. We are committed to protecting and honoring your privacy and upholding the confidence and faith of our clients.