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Privacy & Cookie Policy

Nirvaan Policy

Privacy Policy

(Last updated on [03 - 06-22])

NIRVAAN (“us”, “we”, or “our”) owns and operates the https://www.nirvaan.org.in/ website (hereinafter referred to as the “Service”).

 

This page describes our privacy policies and procedures along with guidance on how we store, collect, manage and use the Data obtained from any person who accesses our website whether registered or not and or is a receiver, (hereinafter referred to as “Customer” or “you”/ “your”) of Services.

 

It is to be noted that the Terms and Conditions along with this Policy including Refund and Cancel policy, FAQ’s etc., displayed on the Website, collectively form the “Agreement”. The capitalized terms unless defined herein shall have the same meaning assigned to them under the Terms and Conditions provided on the Website.

We use your data to provide and improve the Service. By using or signing-up/subscribing to the Services provided on the Website, the Customer agree to be bound by the terms of the Agreement and more specifically the collection, use and disclosure of information and data of the Customer, which is in accordance with this Policy.

NIRVAAN may, from time to time, make changes to this Policy with or without notifying the Customer of those changes. Please note that, the Customer continued use of the Services after the changes pertaining to this Policy have been posted, shall constitute acceptance of those changes.

Further, if the Customer has any questions about this Policy or Practices, the Customer shall not hesitate to contact our team at [.].

  1. Definitions

  1. Data: is the information of a natural person that others can use to identify, locate or contact you, including but not limited to your name, email address, postal address and phone numbers (collectively “Personally Identifiable Information” or “PII”). Specifically, the Website may collect the following list of PII in connection with your use of the Services:

  • ‘Identity Data’ such as name of the Customer, their social media profiles, username, real name, alias, postal address, unique personal identifier, online identifier, ‘Internet Protocol’ address (“IP Address”), email address, account name

  • ‘Personal Data’ in case of Customers, such as age, gender, nationality and place of residence.

  • ‘Contact Data’ such as email address, social media address, telephone number and any other contact information you provide to NIRVAAN.

  • ‘Transaction Data’, in case of Customers, such as details about payments, modes of payment and details regarding the subscribed services through the Website.

  • ‘Profile Data’ such as the username and password, searches made by you, preferences, user-generated content, feedback and survey responses.

  • ‘Sensitive Information’ such as password, financial Data such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history, biometric information.

  • ‘Usage Data’ data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • Similar networking activities such as the browsing history, search history, information on your interaction with the Website or advertisement.

 

The abovementioned list of the PII to be collected by NIRVAAN is non-exhaustive and may or may not include other information of similar nature as may be required by NIRVAAN.

 

  1. Cookies: Cookies is a small bit of record-keeping information stored on the Client’s computer or mobile device.

  2. Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

  3. Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

  4. Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data i.e. the client.

 

  1. Information collected

We collect several different types of information for various purposes to provide and improve our Service to you that you voluntarily provide to NIRVAAN during your interaction or subscription with the Services. In this regards, we at NIRVAAN collect all types of PII (as defined above). In addition to the PII listed above, the E-Platforms may also collect:

 

a)         Generic geographic location, such as the city in which you are located;

b)         Operating System; and

c)         IP Address.

 

NIRVAAN may or may not include other information of similar nature as may be required by NIRVAAN.

 

It is made expressly clear that, the elements forming part of the compilation of the Customers’ data relating to age, ethnicity, gender etc., whether directly compiled or implied, is made with the purposes of inclusion and not to create any bias or discrimination of any nature whatsoever against any individual Customer.

 

NIRVAAN uses the geo-location services on the devices used to access or use the Services at any time, through your device settings. NIRVAAN collects geo-location and proximity of your device, for which the location services will have to be enabled on your device (e.g., GPS-based functionality on mobile devices used to access the Website) and NIRVAAN may use that information to customize the interactions with location-based information and features.[SM1]  You can enable or disable location services when you use our Service at any time by way of your device settings.

 

NIRVAAN will solely retain its data sourced from the Services provided on the website and not the information/data shared directly by the Customers with NIRVAAN, provided to avail the Services. Please note that, as far as the data shared by the Customers with NIRVAAN is concerned, NIRVAAN will not be or act as the data owners or data controllers of such data.

 

NIRVAAN may collect different types of personal and other information based on your use of our Services, including contact information, billing information, viewing and other technical information about your use of our Services. Such information may be collected when (i) you provide information to NIRVAAN with the intent to subscribe or interact with NIRVAAN about its Services offered; (ii) collected automatically when you visit the website or use our Services. NIRVAAN may collect/store your calls and SMSs and content thereof, received or initiated using the Services, including but not limited to, details of the phone numbers that interact with your account, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, call recordings and information which it may automatically receive and record on its server logs from your internet browser, including but not limited to, your IP Address, Cookie information and details of the web pages you request. In order to sign-up/access/subscribe for our services, you are required to share the information for the effective performance of the Services.

 

NIRVAAN also engages in the collection of Your PII for the purpose of business development exercise. NIRVAAN adheres to reasonable security measures when processing your PII for such purposes.

 

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. NIRVAAN may also collect certain types of information automatically, including through the use of Cookies (defined as above), web beacons and other similar tracking technologies. These tracking technologies allow NIRVAAN to personalize your experience with the Services and keep track of certain online behavior in order to help NIRVAAN determine the things that you find most interesting. Information contained in a Cookie may be linked to your PII for this purpose. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies: We use Session Cookies to operate our Service.

  • Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

  • Security Cookies: We use Security Cookies for security purposes.

  • Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

 

NIRVAAN’s intention in collecting your PII is to provide you with the best customer experience possible by communicating with you regarding Service updates, offers and promotions, delivering, advertising that may be of best interest to you, addressing network and security issues, investigating or taking action regarding illegal activities or violations of our Terms and Conditions or other policies, as may be laid out on the Website from time to time. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

  1. Use of Data

NIRVAAN uses the collected data for various purposes:

  • To provide, operate, maintain and improve our Service (includes sharing information with third parties to provide such Services).

  • To notify you about changes to our Service e.g., when you subscribe to our Services, NIRVAAN will send you administrative or account-related information to keep you updated about our Services, inform you of relevant security issues or updates or provide other transaction-related information to you. NIRVAAN processes your contact information to send you such communications.

  • To allow you to participate in interactive features of our Service when you choose to do so.

  • To provide customer support and related services.

  • To gather analysis or valuable information so that we can improve our Service.

  • To actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms, agreements or policies; enforce our agreements with third parties and partners; and as applicable.

  • To detect, prevent and address technical and security issues including to combat spam, malware, malicious activities or security risks, improve and enforce our security measures and to monitor and verify your identity so that unauthorized users do not access your account.

  • To provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

  • For testing, research, analysis and product/service development.

  • To protect the rights or property of the Customers or NIRVAAN.

  • To maintain legal and regulatory compliance.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by NIRVAAN is among the assets transferred.

 

  1. Transfer of Data

 

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. NIRVAAN shall ensure appropriate measures are implemented to ensure that your personal information remains protected and secure when it is transferred outside of your home country in accordance with applicable data protection and privacy laws.

 

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. NIRVAAN will ensure appropriate measures are implemented to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

  1. Disclosure of Data

 

​NIRVAAN maintains information about you in our business records while you remain an active user or subscriber of our Services and has implemented encryption or other appropriate security controls to protect PII when stored or transmitted by us. We may provide PII to third parties to the extent and in the manner as stated in this Policy.

 

Please see below the disclosures:

  • NIRVAAN uses certain trusted third parties to help NIRVAAN provide, analyse and improve the Services (including but not limited to data storage, maintenance services, database management, web analytics, security, payment processing and improvement of the Service’s features).

  • NIRVAAN may disclose files stored in your account and other information about you to third parties when we have a good faith to belief that disclosure is reasonably necessary to: (a) comply with a law, regulation or legal requests including to meet national security or law enforcement requirements; (b) prevent fraud or abuse of NIRVAAN or its Customers; or (d) protect NIRVAAN’s property rights.

  • If we are involved in a merger, acquisition or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but NIRVAAN will notify you of the Terms and Conditions or by posting a prominent notice on the Website of any change in control or use of your PII.

 

  1. Legal Requirements[SM2] 

NIRVAAN may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation;

  • To protect and defend the rights or property of NIRVAAN;

  • To prevent or investigate possible wrongdoing in connection with the Service

  • To protect the personal safety of users of the Service or the public

  • To protect against legal liability

 

  1. Security, Integrity and Retention of Data

  • NIRVAAN will protect the Customer’s PII from unauthorized access, use or disclosure. Whenever the Customers change or access their account information, NIRVAAN offers the use of a secure server. Once your information is in NIRVAANs possession, NIRVAAN adheres to strict security guidelines, protecting it against unauthorized access. NIRVAAN has implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, NIRVAAN uses firewalls, encryption technology and other automated software designed to protect against fraud and identity theft.

 

  • Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. All decisions which are made in the course of our business processes involve human intervention. We do not therefore, expect to make any decisions about you using automated means.

 

  • NIRVAAN will ensure, to the best of its ability, the security of the Customer’s Sensitive Personal Data or Information (“SPDI”) provided by the Customers, as the case may be.

 

  • NIRVAAN also protects the Customer’s privacy by seeking to minimize the amount of sensitive data that NIRVAAN stores on our servers in the first place. You may also contact NIRVAAN anytime with your questions or concerns.

 

  • NIRVAAN will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. NIRVAAN will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

 

  • You acknowledge that all information, data, text, software, documents, messages, or other materials (“Content”), whether publicly posted or privately transmitted, are the sole responsibility of the person from whom such Content originated, and that You, and not NIRVAAN, is entirely responsible for all Content that you upload, post, email, transmit or otherwise make available via the Services. You understand that by using the Services, you may be exposed to Content that is offensive, indecent or objectionable. Under no circumstances will the NIRVAAN or its parent, holding, subsidiary or related companies, affiliates, officers, agents or employees, as the case may be, be liable in any way for any Content or any loss or damage, no matter the cause of the loss or damage, of any kind incurred as a result of the use of the Services.

  

  1. Data Protection under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), NIRVAAN legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. NIRVAAN may process your Personal Data because:

  • We need to perform a contract with you

  • You have given us permission to do so

  • The processing is in our legitimate interests and it is not overridden by your rights

  • For payment processing purposes

  • To comply with the law

 

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. NIRVAAN aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. Please reach out to us at [.] if you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems.

In certain circumstances, you have the following data protection rights:

  • The right to be informed. NIRVAAN shall keep you informed regarding the manner in which we are going to use your Data. The same is ensured by means of this Policy.

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

  • The right to object to direct marketing and a right to object to our processing of your Personal Data.

  • The right of restriction. You have the right to request that we restrict the processing of your personal information.

  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

  • The right to withdraw consent. You also have the right to withdraw your consent at any time where NIRVAAN relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

  1.  “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

 

We do not support Do Not Track (“”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

  1. Service Providers

 

The Customers by accessing/signing-up/subscribing, as the case may be, to the Services grants /his/her/its irrevocable consent to NIRVAAN to share the Customer’s PII to third party sites which will operate as a ‘helpdesk’ and provide services to the Customers. We may employ such entities to facilitate our Service, provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

  1. Analytics

To help us better understand your use of the Services, we may use third-party web analytics on our Services, such as Google Analytics. Such third-party may track and report website traffic which will help us track and monitor the use of our Service. This data is shared with other services of such third party. The third party may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

 

  1. Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

  • Google AdSense & DoubleClick Cookie: Google, as a third-party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

 

  1. Behavioural Remarketing[SM3] 

NIRVAAN uses remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

  • Google AdWords: Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

  • Twitter: Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

  • Facebook: Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

 

  1. Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. The said information is provided directly to our third-party payment processors whose use of your personal information in the manner as provided under their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Indicative list of payment processors we work:[SM4] 

 

  1. Links to Other Sites

This Policy describes the treatment of information provided, collected or retained by NIRVAAN. This Policy applies to NIRVAAN’s Services displayed on the Website, but not to the website maintained by other companies or organizations to which the Website may provide links to. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. NIRVAAN is therefore, not responsible for the content or activities provided or created on such third-party sites.

 

  1. Children’s Privacy

 

The Website does not use the Services to knowingly solicit data from or market to children under the age of 18 (eighteen) years. NIRVAAN requests that such individuals do not provide PII through the Services. If a parent or guardian becomes aware that his or her child has provided NIRVAAN with information without their consent, he or she should promptly contact NIRVAAN and we will take reasonable steps to ensure that such information is deleted from NIRVAAN’s files.

  1. Your Controls:

 

  • You can review and correct your PII collected by NIRVAAN. NIRVAAN reserve the right to correct the information found to be inaccurate. Customers may verify that appropriate corrections have been made. However, it may be noted that the NIRVAAN, its employees, subsidiaries, affiliates and third parties shall not be responsible for the accuracy and/or authenticity of the information supplied by you. NIRVAAN hereby disclaims any and all liability arising out of or in connection with the accuracy and/or authenticity of the information.

 

  • NIRVAAN processes and stores service data on behalf of the Customers. NIRVAAN has no direct relationship with any of the Customers. Therefore, NIRVAAN is exempted from any responsibility consequential to the business relations established between the Customers by using of the Services made available by us.

 

  • You hereby acknowledge and agree that, in case you withdraw your consent to NIRVAAN to use and disclose of your PII as provided for in this Policy, such action on your end will result in the termination of the Agreement and consequently effect in deactivation of the Customer’s account to the Services, restricting your right to access the Services made available by NIRVAAN.

 

  1. Changes to this Privacy Policy

We may update our Privacy Policy from time to time to use your previously collected PII in a manner materially different from that stated in this Policy at the time of collection or to carry out any other amendments to the Policy. [FLA5] You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective from the date of the last revision as mentioned on this page.

 

  1. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at nirvaan963@gmail.com.

 [SM1]Nirvaan may retain or delete this basis whether they collect such information or not.

 [SM2]This is fine. However the below given clause may be substituted for more coverage.

 

In certain circumstances, NIRVAAN may be required to disclose your PII in response to lawful requests by public authorities, including to meet national security and law enforcement requirements. NIRVAAN may disclose your PII in response to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims. NIRVAAN may also share such information if we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Services or as otherwise required by law.

 

 [SM3]Nirvaan can reconsider this clause and indicate only the name of the party, and a line stating that privacy policy can be accessed from website of such third party.

 [SM4]Better way is to just state names and state that their privacy policies can be accessed on their website. Because its possible the link may change (not likely) but yet.

 [FLA5]Omitted as its creating unnecessary burden on Company.

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