PRIVACY POLICY
1. PURPOSE
This Privacy Policy (hereinafter referred to as “Policy”) belongs to Careleavers Inner Circle Forum, a company registered under the Companies Act, 2013 and having its corporate office at Office no. 05, MIIC, MNIT, JLN Marg, Jaipur, Rajasthan, India- 302017 (“CLIC” or “Company” or “we” or “us” or “our”).
This Policy outlines the privacy terms, outlining our approach towards our customer(s) and/or potential customer(s) (hereinafter individually referred to as “Customer” and collectively as “Customers” or “User” You”, “Your”, “Yourself”) who are willing to utilize our website available at ‘www.clicforum.org’ (“Platform”).
This Policy also outlines the policies and procedures of the collection, use, disclosure and protection of information shared by the Customer (hereinafter referred to as “User Data”). The information is primarily collected while the Customer intends to use / uses our Platform and is applicable, without limitation, to those including Customers.
The Company is committed to ensure that privacy of the Customer is always protected. The Company may ask the Customer to provide certain information for identification while accessing the Platform. The Customer can be assured that the User Data will only be used in accordance with this Policy.
By accessing the Platform and utilising the Platform, the Customer agree and consent to the collection, transfer, use, storage, disclosure and sharing of information as described and collected by the Company in accordance with this Policy.
The Company and the Customers are hereinafter individually referred to as the “Party” and collectively as the “Parties”.
2. GENERAL PROVISIONS AND MODIFICATION TO THIS POLICY
2.1 Unless otherwise mutually agreed between the Parties, the entire engagement between the Parties with respect to privacy shall be governed in accordance with the terms of this Policy.
2.2 CLIC at its sole discretion has the right to make changes, modify, amend, or update this Policy from time to time with or without any prior notification to the Customers and the amended terms and conditions of the Policy shall be effective immediately after such initiation. The User has the right to accept/ reject to such amendments made in the Policy. However, if the User continues to access the Platform of the Company, it will signify unconditional acceptance of the amended terms and conditions. Further, the User shall also be bound by any amendment made by the Company to this Policy from time to time.
3. COLLECTION AND USE OF USER DATA
3.1 User Data means and includes any and all information that can be linked to a specific individual or to identify any individual or any entity, such as name, address, mailing address, telephone number, email ID, password, and any such other information that may have been voluntarily provided by the User in connection with accessing the Platform of the Company.
3.2 The Company shall ask the User to provide only such User Data which is for lawful purpose, in accordance to the Indian laws and is necessary to be collected by the Company in relation for accessing the Platform.
4. USER DECLARATIONS
4.1 You, as a User, understand and have the knowledge that Information is being collected.
4.2 You, as a User, understand and have the knowledge of the purpose for which Your Information is being collected and displayed on Our Platform.
4.3 You, as a User, understand and have the knowledge of the intended recipients of the Information.
4.4 You, as a User, understand that You have the option not to provide the data or Information sought to be collected by Us.
4.5 You, as a User, understand that You have an option (while availing the Our Platform or accessing the Platform or otherwise) to withdraw Your consent given earlier to Us and You understand and accept that such withdrawal of Your consent shall be sent in writing and in such an event We shall have the right, at Our discretion, to not provide the Platform for which the information was derived / collected.
4.6 You, as a User, have read and understood this Policy and all other policies governing the usage of the Platform.
4.7 By agreeing to the terms of this Policy, You, as a User, hereby give Your explicit consent and agree to Our processing of Your Information for the purposes given herein.
5. CHOICE AVAILABLE TO YOU REGARDING COLLECTION, USE AND DISTRIBUTION OF YOUR INFORMATION
5.1 Sharing Your Information (as defined below) is entirely voluntary. You need not register with Us, however, if you do not register with us, You may not have access to Our Platform.
5.2 Further, if You register with Us, and upon Your request We will remove/block Your Information from Our database. However, Your Information may remain stored in archive on Our servers even after You temporarily disable Your Account. You may lose access to Our Platform pursuant to the cancellation of Your registration or upon permanent termination of Your Account.
5.3 You have the right to temporarily disable Your Account or permanently terminate Your Account at any time by contacting Us at ‘ Hello@clicforum.org’. Further, please note that the disablement of Your Account is not a withdrawal of Your consent to process and store Your Information (as defined under Our Privacy Policy). The Information provided by You may still be available on the Platform during the Disablement Period until and unless You explicitly withdraw Your consent to process and store Your Information by writing to us at Girish@clicforum.org. In the event that You choose to permanently terminate Your Account or do not revive Your Account during the Disablement Period, You will permanently lose access to Your Account and any and all information thereof. Further, We delete Your Account and all information relating to You or Your Account in perpetuity.
5.4 If We plan to use Your Information for any commercial purposes, We will notify You at the time of using your Information for any commercial purposes and allow You to opt-out of having Your Information used for those purposes.
6. USE OF INFORMATION
6.1 You agree, acknowledge and expressly consent our use of the Information. We collect the User Data and use the User Data are in the manner (including but not limited to) as follows:
6.1.1 Ensuring the Platform are presented in the most efficient manner for Your use;
6.1.2 Provide, operate, and maintain Our Platform;
6.1.3 Administration of Our Platform and business;
6.1.4 Improve, personalize, and expand Our Platform;
6.1.5 Understand and analyse how You use Our Platform;
6.1.6 Develop new products, Platform, features, and functionality;
6.1.7 Communicate with You for customer service, or to provide You with updates and other Information relating to the Service, and for marketing and promotional purposes;
6.1.8 Send You non-marketing commercial communications;
6.1.9 Send You email notifications that You have specifically requested;
6.1.10 Process Your transactions;
6.1.11 Marketing and promotion of Our Platform;
6.1.12 Send You text messages and push notifications;
6.1.13 Find and prevent fraud;
6.1.14 For compliance purposes, including enforcing Our Terms of Use, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency;
6.1.15 Deal with enquiries and complaints made by or about You relating to Our Platform;
6.1.16 Verify compliance with the terms and conditions governing the use of Our Platform.
6.2 In light of the aforementioned, You acknowledge and agree that You have the knowledge that the Your Information is being collected. Further, You acknowledge and agree that You have knowledge for the purpose of collection of the Information and its usage thereof, including without limitations, the above-mentioned methods of using the Information.
6.3 If You post information on Our Platform on behalf of any other Person and/ or relating to any other User of Our Platform, You do so at Your own risk. By doing so, You consent to their use of such information including transmitting it to others on Our Platform. Please be aware that We cannot control the actions of other users of the Platform with whom You may choose to share information with.
6.4 CLIC adheres to this Policy while using the Information You supply. If You give Us any Information for a particular reason, We will use it in connection with and limited to such particular reason. For instance, if You email Us any issue, we’ll use the Personal Information (i.e., Your email address) to get back to You and see if we can fix Your concern.
6.5 In some cases, We may also have a legal obligation to collect certain additional Information from You or may otherwise need such additional Information to protect Your vital interests or those of another person.
6.6 If We ask You to provide additional Information to comply with a legal requirement or to perform a contract with You, We will make this clear at the relevant time and advise You whether the provision of such Information is mandatory or not (as well as of the possible consequences if You do not provide such Information).
7. DISCLOSURE AND RETENTION OF USER DATA
The User Data may only be used for the purpose(s) for which the Company has collected the same or for which, required consent has been obtained by the Company from the User.
The User Data may only be retained for such periods of time as it is required to fulfil the purpose for which it was obtained. The Company does not sell, intends to sell, share, rent or trade the User Data collected from the User.
We hereby represents that We do not sell or involve Ourselves in businesses related to selling any information. The exceptions are listed as follows:
7.1 Business Transfers: Your Information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of Our business assets.
7.2 Service Requirements: The employees, business associates and any other third parties shall be provided information as provided by You for the fulfilment of the business objective of CLIC. We may use the information as provide by You internally, for the purposes of Our internal training, data analytics, research, analysis, to troubleshoot, to identify trends, usage, activity patterns and areas for integration and improvement of Platform and other business-related purposes, subject to not directly disclosing any of Your Information.
7.3 Requirement under applicable law: The Information may be disclosed to any Person, if such disclosure is required for a lawful purpose connected with a function or activity of Platform. This may include but is not limited to – (i) satisfying any applicable law, regulation, legal process, or governmental request; (ii) enforcing this Policy, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to Your requests; or (v) protect Our rights, property or safety of Our users and the public. Information may be disclosed, where the disclosure is necessary for compliance of a legal obligation under applicable law.
7.4 The information may also be disclosed to any person, authority if need be to help investigate, prevent or take action regarding unlawful and illegal activities, suspected fraud, including cyber incidents potential threat, punishment of offences and to the safety or security of any person, violations of CLIC’s terms of use or to defend against legal claims.
7.5 Disclosure of User Data :
The Company collects, uses, processes, stores, discloses and/or transfer the User Data in compliance with the applicable laws. The Company may use/ disclose User Data for the following:
i. to perform the general business activity of the Company;
ii. provide an enhanced user experience through research and development of new products/ Platform on the Platform;
iii. for internal business purposes;
iv. make suggestions and recommendations to the User about the Platform that may be of User interest (by using your v. email address and mobile number or by SMS);
vi. for purposes disclosed at the time the User provides information or as otherwise set forth in this Policy;
vii. wherever the Company needs to comply with a legal or regulatory obligation; and/or wherever the Company may deemed fit.
7.6 Third Party Disclosures :
The Company may share User Data with such entities or individuals and in such manner as detailed below:
i. Certain aspects of the business operations of the Company may be provided to the User in association with third parties who qualify as our business partners, and the Company may share the User Data with such business partners in association for fulfilment of the business operations. If the User chooses to access the Platform, the User provides unconditional and complete consent to providing such User Data to our business partners and shall also be governed by the privacy policy of such third parties.
ii. The Company may disclose User Data to law enforcement authorities, regulators, governmental or public bodies and other relevant third parties to comply with any legal or regulatory requirements. The Company may also disclose User Data, if the Company determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. The Company may also disclose User Data if it determines that disclosure is reasonably necessary to enforce terms and conditions of the Company or protect its operations or its Users.
iii. The Company may choose to sell, transfer, or merge parts of our business or our assets, alternatively, we may seek to acquire other businesses or merge with them. If a change happens to the business, then the new owners may have access to or use User Data in the same way as set out in this Policy.
iv. Further, we may share User Data, with our parent, subsidiaries and affiliates for internal reasons, including business and operational purposes.
7.7 Retention of User Data :
The Company shall only retain User Data for as long as necessary to fulfil the purposes the User Data was collected for, including for the purposes of satisfying any legal, accounting, or reporting requirements, resolve disputes, conclude any activities related to cancellation of an account, investigate, or prevent fraud and other inappropriate activity, to enforce our agreements and for other business reasons.
The Company may or will retain User Data for as long as the User’s account is active on the Platform after signing up and accordingly the User accesses the Platform of the Company.
7.8 Retention Period of User Data
The Company at its sole discretion determines appropriate retention period for User Data, it may consider the amount, nature, and sensitivity of the User Data, the potential risk of harm from unauthorised use or disclosure of User Data, the purposes for which the Company processes the User Data and whether the Company may or can achieve those purposes through other means, and the applicable legal requirements.
8. SECURITY
8.1 We aim to protect Your Information against unauthorised access, unlawful alteration, disclosure, or destruction. Similarly, when You register and/or create Your Account on Our Platform, We store your Credentials, on Our Platform and/ or in a third-party cloud storage, or back-end cloud storage, in an encrypted format. We also aim to maintain its security, integrity, and privacy. To protect data and to aid in preventing unauthorised access, We put in place the necessary physical, electronic, and managerial safeguards in addition to safeguards as laid down under applicable laws. As no method of data transmission or protection is 100% safe, We cannot guarantee perfect security. Additionally, We are not liable for any security lapses or the deeds of any Third Parties who obtain Your Information, due to uncontrollable internal and external factors.
8.2 Password protection is a crucial component of the security of Your Information. You must take care not to reveal Your Account login information to any other parties and must keep Your login information, including Your password, private. You are ultimately in charge of protecting the confidentiality of Your Account login details, even though We will use our best efforts to ensure the highest level of security for Your information. If You suspect that someone else knows Your password, or You discover unauthorised use of Your Account, or You become aware of any other security lapses, kindly let Us know right away.
8.3 We restrict access to Information to those: (i) Third Parties who We need to fulfil their obligations under this Policy, the Terms of Use and any other agreements concluded with Us; (ii) who have received the necessary and ongoing training on how to process, handle, and care for Information; (iii) who store and/ or process the Information in an encrypted format; and (iv) who are subject to confidentiality obligations as required by applicable law. We take measures to make sure that entities who have access to the Information are trustworthy, capable, regularly trained, and we further ensure that these entities adopt reasonable security safeguards as per applicable laws. All Our rules and practices match the applicable guidelines issued and in line with the control, and adulteration of data as well as operational, managerial and technical procedures.
8.4 We cannot guarantee security in transfers and transactions of Your Information to Us through the means of the internet. We suggest that You shall ensure to take adequate safety practices to protect Your Information, as transfer of information on and through the internet is not fully secured. Any unauthorized use of Your Information or any suspicious activity on Your account is not Our responsibility and cannot be held against Us. By utilizing Our Platform, You acknowledge and accept that We are not responsible for any disclosure of Your Information caused by transmission mistakes or unauthorized acts of third parties.
8.5 We retain Your Information, until it is no longer necessary to fulfil the purpose it is being used for, or as required by applicable law (for example, to provide You with a service which You have requested or to comply with applicable legal, tax, or accounting requirements), or until you specifically withdraw your consent, or ask Us to delete such Information. After completion of the purpose for processing Your Information and / or in circumstance when We do not require to process Your Information, We will either delete, aggregated such Information, or anonymize it (so that it can no longer be associated with or identify a user, in which case CLIC can further process the information) or, if this is not possible (for example, because Your Information has been stored in backup archives), then We will securely store Your Information and isolate it from any further processing until deletion is possible. Further, We also consider the extent, nature and sensitivity of the Information and our legal obligations with respect to the data.
8.6 We conduct internal testing and audits of Our privacy precautions on a periodic basis.
8.7 Although we will endeavour to safeguard the confidentiality of your sensitive personal identifiable information, transmissions made by means of the internet cannot be made absolutely secure. No such measures are competent enough to safeguard your personal information in a complete 100% way. Hence, you are also encouraged to take steps to prevent Your personal information from being misused by logging off after using a shared computer, choosing a robust password, not sharing the password with anyone and changing it periodically. We in no way can or are to be held responsible for the unauthorized use of Your personal information or for any suspicious activity on Your account. By using our Platform, you agree that we will have no liability for disclosure of Your information due to errors in transmission or unauthorized acts of third parties.
9. EXCLUSIONS
9.1 Any Information that We collect other than the Information collected through the Platform is not covered by this Policy. Any Unsolicited Information (as defined below) that You send to Us by any unauthorised method, is not covered by this Policy. This includes, but is not limited to, information submitted informally (collectively, “Unsolicited Information”) or posted in any public parts of the Platform, such as reviews given by an eEmployer or the cCandidate on the Platform, as the case may be. All Unsolicited Information will be regarded as non-confidential, and We may be allowed to distribute, disclose, and utilise it without any restriction or credit.
9.2 Further, in the below circumstances, We may process your data in accordance with the DPDP Act, 2023, and for a lawful purpose, however, We will not require your consent for the same (even if the same has been already obtained from You):
9.3 If the processing of Information is for the purpose mentioned in this Policy or Terms of Use, for which You have voluntarily provided the Information to CLIC, and in respect of such information You have not indicated to Us that You do not consent to the use of Your Information;
9.4 If the processing of Information is for responding to a medical emergency involving threat or immediate threat to Your life or any other individual;
9.5 When We process and / or disclose the Information in special circumstances such as compliance with subpoenas, court orders, requests/order from legal authorities or law enforcement agencies requiring such disclosure;
9.6 Pursuant to Section 17 of the DPDP Act, 2023, Chapter II (except Section 8[1] and 8[5]), Chapter III, and Section 16 of the DPDP Act, 2023 shall not be applicable in the below circumstances, and CLIC is well-within its right to process and/ or disclose such Information:
9.7 If the processing of Information is necessary for enforcing any legal right or claim;
9.8 If the Information is processed in the interest of prevention, detection, investigation or prosecution of any offence or contravention of any law for the time being in force in India;
9.9 When We process Information of individuals not situated within the territory of India, pursuant to a contract entered by Us with any Person situated outside the territory of India;
9.10 When the processing of Information is necessary for a scheme of compromise or arrangement or merger or amalgamation of two or more companies or a reconstruction by way of demerger or otherwise of a company, or transfer of undertaking of one or more company to another company, or involving division of one or more companies, approved by a court or tribunal or other authority competent to do so by any law for the time being in force; and
9.11 When the processing is for the purpose of ascertaining the financial information and assets and liabilities of any Person who has defaulted in payment due on account of a loan or advance taken from a financial institution, subject to such processing being in accordance with the provisions regarding disclosure of information or data in any other law for the time being in force.
10. ACCESS TO USER DATA AND CHANGES TO USER DATA
The User may inquire as to the nature of User Data stored or its processing by the Company. Additionally, the User will have the right to review their User Data and make corrections or updates, request data blocking where applicable or to object, for legitimate reasons, to the processing of the User Data. The User may also have the right to withdraw your consent, if necessary, to the collection, use, retention, and disclosure of User Data, subject to acceptance of such withdrawal by the Company
11. DATA SECURITY
The Company adheres to the highest regards and concern for the privacy of the User(s) and hence takes all possible and reasonable measures to store and secure the User Data and any other information so collected by the Company from the Users. The Company uses a variety of physical, technical, and administrative measures to safeguard User Data in its possession against any loss, theft, and unauthorized use, disclosure, and modification to the User Data.
The Company on its own, systematically evaluates the security risks, considering the impact of threats and vulnerabilities of the User Data However, it also acknowledges that the transfer of any and all data through the internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorised third parties.
The Users shall also note that if the User allows any third person/ party to access its account (including other third person/ party to setup account under its personal information), then the third person/ party may be able to access, modify, amend and disclose the User Data. In the occurrence of any such event(s) the Company shall not be liable for any breach or liability on its behalf.
12. COOKIES
12.1 We use cookies and other tracking technologies. ‘Cookie’ is a packet of information stored on a browser by a server so it can be later read back. Similarly, when You return to the website or application or access it through another website, they recognise these cookies and therefore the device You are accessing Our Platform from. Cookies are used to store User preferences, their experiences of the Platform, so as to help Us understand the nature of usage of the services and generally improve Our services to You. Some cookies and other technologies may serve to recall Information previously indicated by a User. Most browsers allow You to control cookies, including whether or not to accept them and how to remove them.
12.2 You may set most browsers to notify You if You receive a cookie, or You may choose to block cookies with Your browser, however, please note that if You choose to erase or block Your cookies, You will need to re-enter Your original User ID and password to gain access to certain parts of the Platform.
12.3 Our use of cookies and other tracking technologies allows Us to improve Our Platform and Your experience with the Platform.
13. RIGHTS OF USERS
13.1 You fully accept and agree that Your Information may be processed in United States of America (or any other local or foreign jurisdiction as per Our requirements) if You are using Our Services. Laws governing privacy and data security may differ from or be less strict than those in force in Your jurisdiction. You hereby give Your explicit approval for this Policy to be followed in the processing of your Information.
13.2 We value openness and are dedicated to upholding all of Our User’s privacy rights. Each User of Our Services has the following rights:
13.2.1. The Right to Access: You have the right to request copies and/or obtain access of Your Information to the extent as laid down below from CLIC:
i. a summary of the Information which is being processed by CLIC and the processing activities undertaken by CLIC with respect to such Information;
ii. the identities of all other data fiduciaries (as defined under applicable laws) and data processors (as defined under applicable laws) with whom the Information has been shared by CLIC, along with a description of the Information so shared; and
iii. any other information related to Your personal data and its processing, as prescribed under applicable laws.
However, We will not be obligated or required to share information contained in clause (ii) or clause (iii) of this sub-clause 14.2.1, where such sharing is pursuant to a request made in writing by such other data fiduciary (as defined under applicable laws) for the purpose of prevention or detection or investigation of offences or cyber incidents, or for prosecution or punishment of offences.
13.2.2. The Right to Rectification: In the event of any inaccurate or incomplete Information, You have the right to rectification, completion, or updating of the Information, as the case may be.
13.2.3. The Right to Erasure: Subject to certain conditions or for compliance with any law for the time being in force, upon Your request, We shall erase any Information as provided by You.
13.2.4. The Right to Withdraw: You have the right to withdraw Your consent to processing of Your data at any time. Please be advised that the same may result in the restriction of the complete Services and access to Our Platform.
13.2.5. The Right to Notification: You have the right to be notified regarding any rectification or erasure of Information or restriction of processing unless this proves impossible or involves disproportionate effort.
13.2.6. The Right to Opt-in: You have the right to give explicit consent for the processing of Your Information or the right to withdraw Your consent at any time.
13.2.7. The Right to Nominate: You have the right to nominate, any other individual, who shall, in the event of Your death or incapacity, exercise Your rights in accordance with the law.
13.2.8. The Right to grievance redressal: You shall have the right to have readily available means of grievance redressal provided by CLIC regarding the performance of Our obligations in relation to the Information or the exercise of Your rights under applicable law.
13.3 If You choose to exercise any of the above rights, We will respond within 30 days. Please send any requests to Hello@clicforum.org
13.4 You are recognized to exercise Your rights as per the applicable law of Your respective jurisdiction.
13.5 The aforesaid rights are exercisable upon sending an intimation to the Grievance officer specified below.
14. NO IMPLIED WAIVER
Failure of the User to exercise or enforce any right under this Policy upon one or more occasions shall not constitute a waiver of the right to exercise or enforce the same or any other right on another occasion.
15. SEVERABILITY
If any of the term(s) of this Policy is nullified of made void by a written statement by the Company, the remaining conditions as far as possible shall remain in full force as applicable.
16. ACCEPTANCE
The User has read and understands this Policy and agrees that User’s access to website shall constitute User’s acceptance of the terms and conditions of this Policy only.
17. CHANGE IN LAWS
Change in laws states occurrence of any of the following event during and/or after User’s sign up on the Platform:
a)The enactment of any new Indian laws;
b) The repeal, modification or re-enactment of any existing Indian Laws;
c) The commencement of any Indian Laws, which has not entered effect until the date of access;
18. JURISDICTION
This Policy and all the terms of this Policy to User are subject to all the applicable laws and regulations of India. Any actions or proceedings by the User against the Company shall only be brought in the courts of Jaipur Rajasthan.
19. ENTIRE UNDERSTANDING
This Policy constitutes the entire understanding between the Company and the User in relation to the terms this Policy shall supersede any prior understanding or representation of any kind preceding the date of this Policy.
This Policy shall be read with the general terms and conditions for Customers, cancellation and refund policy (“Ancillary Documents”). If there exists any contradiction between the terms of this Policy and that of the Ancillary Documents in relation to User Data its access and usage, the terms of this Policy shall prevail, unless otherwise express in writing by the Company.
20. GRIEVANCE REDRESSAL
If there are any complaints or issues with regards to terms specified in this Policy, please contact us at Hello@clicforum.org. We will make every effort to resolve User’s issue in a timely and satisfactory manner.
If the User is not satisfied with the resolution provided by the Company, the same may be escalated to Our Grievance Officer, Mr. Girish Mehta at Girish@clicforum.org Our Grievance Officer will review the issue and work with the User to find a resolution.
