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Privacy | Terra Origin

Privacy Policy

Objective and Scope

Neocortex Life Sciences Private Limited (“we”, “us”, “our”, “Neocortex”) values the trust placed in us by data subject (“you”, “your”, “user”, “consumer”) and therefore, we assure that we follow the highest standards of privacy guidelines to protect the information shared by you with us.

This privacy policy describes the usage of information provided or collected by Neocortex and/or its subsidiary (ies) and/or affiliate(s) (collectively referred to as the "Company"), which operates various websites/ Mobile Apps & other services including but not limited to delivery of information and content via any mobile or internet connected device or otherwise (collectively the "Services"). We follow this privacy policy in accordance with applicable laws in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain services or regions. Those terms are to be read in combination and are part and parcel of this policy.

Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications like social media login) the information we collect through those third-party sites linked with our applications are covered by this privacy policy, and the information the third-party site or platform collects or may collect is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

Please read this privacy policy carefully to understand our policies and practices regarding your Personal Data and how we will treat it. This Policy applies to individuals who interact with Neocortex services as consumers. This Policy explains how your Personal Data is collected, used, and disclosed by Neocortex India Limited. It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data are used.

 

This Policy covers both our online and offline data collection activities, including Personal Data that We collect through our various channels such as websites, apps, third party social networks, Consumer Engagement Service, points of sale and events. Please note that We might aggregate personal data from different sources (website, offline event). As part of this, We combine Personal Data that were originally collected by different Neocortex entities or Neocortex partners. 

 

If you do not provide necessary Personal Data to us We may not be able to provide you with our goods and/or services. This Policy can change from time to time.

This Privacy Policy should be read in conjunction and together with the Terms of Use applicable to the Neocortex

User Consent

By using Neocortex Website (for example, when you register for an account, communicate with us, on our sites or applications or through social media), you agree to provide consent to our collection, use and sharing of your personal information as described in this policy. In some cases, particularly if you reside in a country governed by a data protection regulation, we may ask you to provide explicit consent to access our services before proceeding for further operations.

If you are a traveller visiting various countries around the world and avail the Platform’s services, then we will determine your location using your IP address  and in the event IP detection fails, we will consider the last cached location as your current location to provide you services and the consents obtained at the time of registration in that location will be valid for processing of your personal information. We use third party service providers to help us determine your location to provide you with appropriate content and services on our Platform.

Upon implementation of GDPR, existing user in order to receive full scale services as provided will be required to opted in, subscribe and consent for provision of services, failure to subscribe will deny the use the access and full use of the services provided by Neocortex.

This Privacy Policy provides important information in the following areas:

 

  1. SOURCES OF PERSONAL DATA

 

‘Personally Identifiable Information’ or ‘PII’ is defined as any information that identifies (whether directly or indirectly) to a particular individual or natural person, such as the individual’s name, postal address, email address, mobile number and any other specific identifier indicating to that particular person. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

This Policy applies to Personal Data that We collect from or about you, through the methods described below, from the following sources:

 

  • Neocortex websites. Consumer-directed websites operated by or for Neocortex, including sites that We operate under our own domains/URLs and mini-sites that We run on third party social networks such as Facebook ("Websites").
  • Neocortex mobile sites/apps. Consumer-directed mobile sites or applications operated by or for Neocortex, such as smartphone apps.
  • E-mail, text and other electronic messages. Interactions with electronic communications between you and Neocortex.
  • Offline registration forms. Printed or digital registration and similar forms that We collect via, for example, postal mail, in-store demos, contests and other promotions, or events.
  • Advertising interactions. Interactions with our advertisements (e.g., if you interact with on one of our ads on a third party website, we may receive information about that interaction).
  • Data We create. In the course of our interactions with you, we may create Personal Data about you (e.g. records of your purchases from our websites).
  • Information collected automatically while browsing/navigating through the website:
  • Third  party data aggregators, Neocortex promotional partners, public sources and data received when we acquire other companies

 

The above information may also be captured by keeping cookies on our websites by our affiliates for the purposes mentioned in this document elsewhere.

  1. PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Depending on how you interact with Neocortex (online, offline, over the phone, etc.), We collect various types of information from you, as described below:

  • Personal contact information. This includes any information you provide to Us that would allow Us to contact you, such as your name, postal address, e-mail address, social network details, or phone number.
  • Account login information. Any information that is required to give you access to your specific account profile. Examples include your login ID/email address, screen name, password in unrecoverable form, and/or security question and answer.
  • Demographic information & interests. Any information that describes your demographic or behavioural characteristics. Examples include your date of birth, age or age range, gender, geographic location (e.g. postcode/zip code), favourite products, hobbies and interests, and household or lifestyle information.We may reference other sources of demographic and other information to provide you with more targeted communications and promotions. We use various third-party analytics service providers, among others, to track the user behaviour on our website. They are used to support display advertising towards helping us gain understanding of our users' Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out or opt-in by giving a consent at to serve you advertisements when you visit our website or applications.

 

  • Information from computer/mobile device. Any information about the computer system or other technological device that you use to access one of our Websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a Neocortex website or app via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone's unique device ID, advertising ID, geo-location, and other similar mobile device data.
  • Websites/communication usage information. As you navigate through and interact with our Websites or newsletters, We use automatic data collection technologies to collect certain information about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is also collected through the use of third party tracking for analytics and advertising purposes. You have the right to object to the use of such technologies.
  • Cookies The Website uses cookies and other similar technologies which are necessary to its functioning. Some of these cookies are essential for us to provide you more information. Please refer our cookies policy.
  • Log File Information We automatically collect limited information about your computer's connection to the Internet, mobile number, including your IP address, whenever you visit our website(s), application or services. Your IP address is a number that lets computers attached to the Internet and recognize where you send data – For e.g. pages you viewed. We automatically receive and log information from your browser, including your IP address, your computer's name, your operating system, browser type and version, CPU speed, and connection speed. We may also collect log information from your device, including your location, IP address, your device's name, device's serial number or unique identification number (e.g. UDID on your iOS device), your device operating system, browser type and version, application version, operator name, screen size, CPU speed, and connection speed etc.
  • Inferred Information through usage and log data We may track certain information about you based upon the pages viewed by you on our website. We use this information for conducting internal research on our users' demographics, devices, interests, and behaviour to better understand, protect and serve our users.



  • Clear GIFs We may use "clear GIFs" (Web Beacons) to track the online usage patterns of our users in an anonymous manner, without personally identifying the user. We may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by them . We use this information to inter-alia deliver our web pages to you upon request, to tailor our website/Application or Services to suit the interests of our users, to measure traffic, to improve the quality, functionality and interactivity and to let the advertisers know the geographic locations from where our visitors come.

Web beacons (also known as "web bugs") are small strings of code that deliver a graphic image on a web page or in an email for the purpose of transferring data back to Us. The information collected via web beacons will include information such as IP address, as well as information about how you respond to an email campaign (e.g. at what time the email was opened, which links you click on in the email, etc.). We will use web beacons on our Websites or include them in e-mails that We send to you. We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, advertising, email auditing and reporting, and personalisation.

 

  • Market research & consumer feedback. Any information that you voluntarily share with Us about your experience of using our products and services.

 

  • Consumer-generated content. Any content that you create and then share with us on third party social networks or by uploading it to one of our Websites or apps, including the use of third party social network apps such as Facebook. Examples include photos, videos, personal stories, or other similar media or content. Where permitted, We collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement, and third party social networking. 

 

  • Information we collect from third parties: We may receive information about you from other online sources. We may add it to our account information system and treat it in accordance with this policy. If you provide information to the platform provider or other partner to whom we provide services, your account information including PII may be passed on to us. We may obtain updated contact information(s) from third parties in order to correct our records and fulfil the Services or to communicate with you or share the information with any third party

 

  • Third party social network information. Any information that you share publicly on a third party social network or information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with Us. Examples include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third party social network to share. We receive your third party social network profile information (or parts of it) every time you download or interact with a Neocortex web application on a third party social network such as Facebook, every time you use a social networking feature that is integrated within a Neocortex site (such as Facebook Connect) or every time you interact with Us through a third party social network. To learn more about how your information from a third party social network is obtained by Neocortex, or to opt-out of sharing such social network information, please visit the website of the relevant third party social network.

 

  • Payment and Financial information. Any information that We need in order to fulfil an order, or that you use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). In any case, We or our payment processing provider(s) handle payment and financial information in a manner compliant with applicable laws, regulations, and security standards such as PCI DSS.

 

  • Subscription or Paid service information When you chose any subscription or paid service, we or our payment gateway provider may collect your personal information such as address or billing information, including your credit/debit card number and expiration date etc. The subscriptions or paid Services may be on auto renewal mode unless cancelled. If at any point you do not wish to auto-renew your subscription, you may cancel your subscription before the end of the subscription term or contact us on our support e-mail.

*In case of sharing or referring the subscription to another user then the personal information of the referrer will only be used for the purpose for which it has been shared. Other than the purpose, We won’t provide or process the referrals personal information for analytics, direct marketing etc. without prior consent provided by the referral to receive such services from us.

  • Transactional and Billing Information Based on your purchase of a subscription or paid service, our payment gateway partner may collect information, including but not limited to, your credit/debit card details or other bank account details along with your billing address. This information is stored by the payment gateway partner. For instance, the Services will be using third party payment gateway partners to process and facilitate the payment of your subscription fee to the Services for providing you access to the subscription; such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to providing them with information about you or entering into any transactions with them. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them.

We may receive financial or transactional information (for e.g., transaction ID, order ID etc.) from third party vendors in case of payments, for reconciliation and validation of transactions and also for the purpose of resolutions of complaints (in case of failed transactions and refunds).

  • Calls to Customer Care . Communications with a Customer care can be recorded or listened into, in accordance with applicable laws, for local operational needs (e.g. for quality or training purposes). Payment card details are not recorded. Where required by law, you will be informed about such recording at the beginning of your call.

 

  • Sensitive Personal Data. We do not seek to collect or otherwise process sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on your prior express consent for any processing which is voluntary (e.g. for marketing purposes). If we process your sensitive personal data for other purposes, we rely on the compliance with applicable law.

 

  1. PERSONAL DATA OF CHILDREN

Neocortex does not knowingly solicit or collect personal data from children below the age of 18 (Eighteen Years). Neocortex does not knowingly permit any person who is under 18 years of age to register with the services or to provide any other personally identifying information. If Neocortex becomes aware that any personally identifiable information of persons less than 18 years of age has been collected on the Neocortex without verified parental consent, then Neocortex will take the appropriate steps to delete any such information and notify the parent. However, we consider it the responsibility of parents to monitor their children’s use of our services. Nevertheless, it is our policy not to collect and process any personal information from children below 18 years of age or offer to send any promotional materials to persons in that category. Neocortex does not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided Neocortex with personal information without their prior consent, please contact our customer support team to ensure that the personal information is removed from the Neocortex.

 

 

 

 

 

 

 

 

  1. USES MADE OF YOUR PERSONAL DATA

The following paragraphs describe the various purposes for which We collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.

We will only collect and process personal data about you where we have lawful basis. Lawful basis on which we would process your personal information includes obtaining explicit consent from you for processing your personal information or processing for “legitimate interests” where processing is necessary by us to provide you with services (For e.g. processing your information by our group companies/affiliates).

We may also use your information:

  1. To evaluate your interest for various services, offers;
  2. To perform analytics and conduct customer research, to determine your interest, for identifying content that generate sales and to analyze traffic patterns. If you choose to post messages on social media accounts, message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

We use information to provide, analyze, administer, enhance and personalize our service and marketing efforts, to process your registration, to provide you services, and to communicate with you related to below mentioned points. For example, we use information to:

  • Analyse and understand our audience, improve our service (including our user interface experiences), recommendation algorithms and delivery which may require sharing personal information with our group companies and affiliates or third-party service providers.
  • To help advertisers understand our audience and confirm the value of advertising on our websites or Applications (however it is usually in the form of aggregated statistics on traffic to various pages within our site) and to provide you relevant ads.
  • To help advertisers understand our audience and confirm the value of advertising on our websites or Applications (however it is usually in the form of aggregated statistics on traffic to various pages within our site) and to provide you relevant ads
  • Notify you about changes in terms of service or privacy policy.
  • Allow you to participate in interactive features offered through our Services.
  • Sharing with our customer support team to resolve your queries/concerns related to your rights or services provided to you.
  • to fulfil obligations under contract. This includes providing our Services to you; to communicate with you about your use of our Services; to obtain and process payment from you and to fulfil your orders for Services and any obligations on us relating to those services;
  • for the purpose for which you specifically provided the information to us, including, to respond to your inquiries, to provide any information that you request, to address technical support tickets, and to provide customer service support;
  • to make our Services and communications more relevant to you, including generating customer profiles, delivering customized content to you, to offer location customization, personalized help and instructions, and to otherwise tailor your experiences while using our Sites or our Services;
  • to better understand how customers and other third parties access and use our Sites and Services, both on an aggregated and individualized basis;
  • to administer, monitor, improve and customize our Sites and Services, for our internal operations, including troubleshooting, network management and network optimisation, research and analytical purposes, so that we can provide our customers with a better customer experience;
  • to investigate, prevent or take action regarding illegal activities, fraud, threats to our property or personnel and violations of our Terms of Use and/or applicable law and also to meet our legal and regulatory obligations;
  • to notify you about our new product releases and service development, alerts, events, updates prices, terms, special offers and associated campaigns and promotions (including via newsletters). Therefore, we and selected third parties may use your personal data to send you marketing communications about products and services based on your preferences and interest. You have a choice and can object to our use of your personal data for marketing purposes. When we are required by law to do so, we will obtain your consent before using your personal data for marketing purposes. If you do opt out, we will stop sending you marketing communications, but we will continue sending you non-marketing communications that relate to the Services you are using (for example billing information, software update communications, password resets etc);
  • if you attend an event, we may process information about you gathered in relation to the event and may share information about your attendance with your company. We may also permit designated event partner or conference sponsors to send you communications related to the event if you have shared your contact information at the event. Please note that sponsors from other companies may directly request information about you at their conference booths or presentations, and their use of your personal data that you provide to them will be subject to their privacy policies;
  • to assist us in advertising our products and services in various mediums including, sending promotional emails, advertising our services on third party sites and social media platforms, direct mail, and by telemarketing.
  • where we ask you for specific consent to a use of your personal data , we will use it in the ways we explain at the time of obtaining that consent; and
  • in any way required by law, regulation or the public interest such as in response to requests or orders by government or law enforcement authorities conducting an investigation or to respond to an emergency. This use may require us to disclose your personal data including contact details and/or information about your usage of our Services to relevant authorities or to block, intercept or otherwise interfere with your use of our Services and any personal data generated by that usage. Achieving a balance between, on the one hand ensuring protections for the privacy and other fundamental human rights that may be exercised through use of our Services and, on the other, the exercise of lawful investigatory powers for the public good on the other can be complicated. We do not accede to such requests without careful consideration of all the circumstances. Even where we are legally obliged to disclose personal data , we will give careful consideration to the extent to which doing so will infringe on the fundamental rights, including the right to privacy, of any person whose personal data is to be disclosed or intercepted and we take whatever steps are practicable to mitigate and minimise any such infringement.

JUSTIFICATION OF USAGE OF DATA:

 

      • Our  justification (sometimes referred to as “legitimate” or “lawful basis” legal basis) for processing any particular category of personal data will vary depending on the information itself, our relationship with the subject of the personal data , the Service being provided, the specific legal and regulatory requirements of the country in which the Services are being provided, the personal data processed and many other factors. Subject to modifications in specific countries, the legal bases for our processing are as follows:
      • In order to communicate adequately with you as a user of our Services and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information to ensure the efficient and effective operation of our business;
      • In order to engage in transactions with customers, suppliers and business partners, and to process purchases and effect installation of our products and deliver Services, we need to process information about you as necessary to enter into or perform a contract with you;
      • We process personal data for marketing and sales activities based on your consent, where it is required and so indicated on our sites or at the time your personal data is collected, or further to our legitimate interest to market and promote our products and services;
      • We rely on our legitimate interests to process personal data and other information in order to analyse, develop, improve and optimise our Sites, products and Services, and to maintain the security and integrity of our Sites, network and systems. We also have a legitimate interest in using your personal data in connection with legal claims, compliance, regulatory and investigative purposes as necessary.; or
      • Because  applicable laws (including telecommunications laws), regulations or the public interest require us to, such as to comply with legal processes, law enforcement or regulatory authorities or to assist in the prevention, detection or prosecution of crime or to process an opt-out request.
      • We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests and which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out in this Policy. In all other countries (except in the EU or in jurisdictions where similar EU type requirements exist), our justification for processing your personal data will be based on your consent and/or acceptance of the Terms of Use and this Policy. In all situations, where you withhold any personal data requested by us, we may not be able to provide you with certain Services or parts of Services or functionality.



How your information is used for Advertising

We use third-party advertising companies to serve ads when you visit or use our website, mobile application or services. These companies may use information (not including your name, address, email address or telephone number or other personally identifiable information) about your visits or use of a particular website, mobile application or service, in order to provide advertisements about goods and services of interest to you.

Services may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, and are beyond our reasonable control. Once you leave our server (you can recognize your location by checking the URL in location bar on your browser), any kind of information provided by you is governed by the privacy policy of the operator of the applications/website(s) you are visiting. Their policy may differ from ours. If you can't find the privacy policy of any of these applications/websites via a link from the application's homepage, you should contact the application owner(s) directly for more information.

Presentation of information to our advertisers for helping them to understand our audience(s) and to know the value of advertising on our websites or applications, is usually in form of aggregated statistics on traffic to various pages / content within our websites or Applications.

We do not provide any personally identifiable information to any third party websites / advertisers / ad-servers without obtaining your consent.

Information Use by the Company

The Information supplied by you enables us to improve our services and provide you the most user-friendly experience(s). In some cases, for e.g. provision of certain service(s) or utility (ies), we may require your contact information as well. All required information is service dependent and the Company may use the above said user. Information to, maintain, protect, and improve the Services (including advertising on the "Application") and for developing new services. We may also use your email address or other personally identifiable information to send commercial or marketing messages with your consent [with an option to withdraw your consent (wherever feasible)]. Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, twitter etc.

Any posted/uploaded/conveyed/communication by users on the public sections of the "Application/Websites" becomes published content and is not considered personally identifiable information subject to this Privacy Policy. In case you choose to decline to submit personally identifiable information on the Application/Websites, we may not be able to provide certain services on the Application/Websites to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information or consent.

When you register with the Application or Services, we may contact you from time to time about updating your personal information to provide you features that we believe may benefit / interest you.

  1. DISCLOSURE OF YOUR PERSONAL DATA

In addition to the Neocortex entities We share your Personal Data with the following types of third party organizations subject to obtaining your consent as may be required in some jurisdictions, we may share or disclose your personal data as necessary for the purposes described above and as further detailed below:

  • Affiliates
  • The Company proposes to share such information within its group companies and officers and employees of such group companies for the purpose of processing personal information on its behalf. We also ensure that these recipients of such information agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.We may disclose the personal data we collect from you to our subsidiaries. Where permitted by law and with your consent where required, our affiliates may use your information for the purposes indicated in this Policy, including to market their products and services to you. In processing your personal data, our affiliates follow practices at least as protective as those described in this Policy. 
  • Third party companies using Personal Data for their own marketing purpose: Except in situations where you have given your consent, We do not license or sell your Personal Data to third party companies for their own marketing purposes. The Company may present information to our advertisers - to help them understand our audience and confirm the value of advertising on our websites or Applications – however it is usually in the form of aggregated statistics on traffic to various pages within our site. Their identity will be disclosed at the time your consent is sought.
  • The Company may share your information regarding your activities on websites or Applications with third party comments sites , social websites to populate your social wall that is visible to other people however you will have an option to set your privacy settings, where you can decide what you would like to share or not to share with others.
  • Business, Sales and Marketing Partners: 

We may offer some of our Services together with or through third parties who may be system integrators, resellers, solution partners, network partners and affinity organizations. If we do so, we will need to share your personal data with these third parties to assist in providing and marketing that Service to you, as well as to enable the third parties to market their own products and services to you (with your permission, if required). We may also share your personal data with companies that are system integrators, resellers, solution partners, network partners and affinity organizations, and whom we believe might offer products and services of interest to you (again with your permission, if required).

  • Third-Party Service Providers: We employ other companies and individuals to perform functions that are necessary for the provision of the Services or for any of the purposes described above. Examples include: where permitted, jointly offering a product or service, sending communications, processing payments, assessing credit and compliance risks to give you access to our Services, fraud and financial crime prevention detection and prosecution, analysing data, providing marketing and sales assistance (including advertising and event management), customer relationship management, providing training, these third parties include; system integrators, resellers, solution partners, network partners, affinity organizations, third party vendors, service providers, contractors or agents, and other carriers or providers that we may disclose personal data to where necessary to provide our Services or fulfil your requests or orders, as well as entities that provide website hosting, service/order fulfilment, customer service, and credit card processing, effecting payments, among others. These third-party service providers have access to personal data needed to perform the functions we have entrusted to them but may not use it for other purposes where they process your personal data on our behalf. Whenever we share personal data with third parties, we take steps to ensure that third party contracts contain appropriate protections for your personal data.
  • Business Transfers: If we are acquired by or merge with another company, or if substantially all of our assets are transferred to another company (which may occur as part of bankruptcy proceedings), we may transfer your personal data to the other company. We may also need to disclose your personal data before any such acquisition or merger, for example to our advisers and any prospective purchaser’s adviser. 
  • Legal Protection and in Response to Legal Process: We may disclose the personal data we you hold about in order to comply with applicable law, in response to or to pursue judicial proceedings, court orders and in other legal processes. We may also disclose, transfer or share it when we believe in good faith that disclosure is necessary: to protect or enforce our rights; protect your safety or the safety of others; investigate or prevent fraud; to respond to government requests – including from government and national or international law enforcement authorities outside of your country of residence – or for national security, public safety and/or law enforcement purposes. Personal data shall only be disclosed when we in good faith believe that we are obliged to do so in accordance with the law or that there are compelling reasons of public interest for us to do so. This will only be after a careful evaluation of all legal requirements and other relevant considerations, including any infringement on the fundamental rights to privacy or freedom of expression that might be impacted by the disclosure.
  • Sharing Aggregated and De-Identified Information: We may use your personal data to create aggregated and anonymized information which we may share with third parties. Nobody can identify you from that anonymized information. In other circumstances we may pseudonymize your personal data before sharing it with a third party so that we can re-associate you with the information once it has been processed and returned to us. Whilst the third party will not be able to identify you from the pseudonymized information, we will still be able to. We treat pseudonymized data as though it were personal data and ensure the same level of protection for it when sharing with third parties.

 

  • Non-disclosure of Personal Data

We will not sell, share, or otherwise distribute your Personal Data to third parties except as provided in this Privacy Policy. We may disclose your Personal Data to other affiliates worldwide that agree to treat it in accordance with this Privacy Policy. Personal Data may also be transferred to third parties who act for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed, such as services delivery, evaluating the usefulness of this website, marketing, data management or technical support. These third parties have contracted with us to only use Personal Data for the agreed upon purpose, and not to sell your Personal Information to third parties, and not to disclose it to third parties except as may be required by law, as permitted by us or as stated in this Privacy Policy.

  • Personal Data collected from you may also be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat Personal Data in accordance with this Privacy Policy. Also, Personal Data may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.

 

  1. RETENTION OF YOUR PERSONAL DATA

In accordance with applicable laws, We will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected or to comply with applicable legal requirements. Personal data used to provide you with a personalized experience will be kept for a duration permitted by applicable laws.

We retain the information which we have collected no longer than is necessary. This is determined on a case by case basis . Normally we will retain the information as long as you maintain an account with us and till the time you continue to access and use our services. We retain personal data for as long as and/or for no longer than we are permitted to do by applicable law, regulation, tax or accounting practice or the terms of any governmental telecommunications licenses or authorizations to which we may be subject. We also delete personal data in accordance with any contractual obligations that we may be subject to (for example if we are processing personal data on behalf of one of our customers rather than for our own business purposes).

Where maximum or minimum data retention periods are not otherwise stipulated, we determine appropriate retention period for the personal data by considering: the amount, nature and sensitivity of the personal data contained in the records; the potential risk of harm from unauthorised use or disclosure of personal data; the purposes for which we process the personal data and whether we may be able achieve those purposes through other means; whether the personal data can be permanently and effectively anonymized; the security measures in place in relation to that personal data and any other relevant factors.

We will delete your information whenever you request us to do so. However, we may archive and/or retain some information for legal purposes.

We retain your personal information as long as necessary for us to provide services to you or you ask us to not retain your data. If you no longer want us to use your information, then you can request that we erase your personal information and close your account. Please note that if you request for the erasure of your personal information; Your request will be processed, and you will receive confirmation of the same via email. Please note that this will only perform a deletion of the information that has been collected by us and will disable your SSO information for Neocortex.

  • The personal information (Name, E-mail, Mobile No) will be retained as a part of the SSO Login functionality and will be governed by the SSO Login Policy.
  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
  • Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on our site, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
  • Because of the way we maintain certain services, after you delete your information, residual copies may take a period before they are deleted from our active servers and may remain in our backup systems.

Please note that if you have multiple accounts with us, then you will have to raise separate requests for each of the accounts, along with the associated email IDs or phone numbers.

  1. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA

We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third party social networks.

People who can access your Personal Dat: Your Personal Data will be processed by our authorised staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data have been collected (e.g. our staff in charge of consumer care matters will have access to your consumer record).

Measures taken in operating environment: We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although We will do our best to protect your Personal Data, We cannot guarantee the security of the data during transmission through our Websites/apps.

Measures We expect you to take: It is important that you also play a role in keeping your Personal Data safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls We provide you in our Website/app.

 

DATA TRANSFER, STORAGE & PROCESSING GLOBALLY: Because of the international nature of our business, we may need to transfer your personal data within the Neocortex group, and to third parties, in connection with the purposes set out in this Privacy Notice. For this reason, we may transfer your personal data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

INTERNATIONAL TRANSFER OF PERSONAL DATA:

  • Subject to obtaining your consent as required in some jurisdictions, Neocortex may transfer personal data across national borders in running our business and delivering the Services. In doing so, your personal data may be transferred to and processed by other Neocortex entities and/or unrelated third parties outside of the country where you are located or where the personal data was collected.
  • All Neocortex affiliates /entities have signed an intra-group agreement applicable to transfer of personal data within and outside of the EU or to jurisdictions which do not provide adequate levels of protection for the personal data under applicable law. This agreement is based on the EU Commission standard contractual clauses (and which therefore contractually impose a standard of protection for the personal data transferred that is equivalent to that offered within the EU). This way we ensure that adequate protections are in place for the security of your personal data when we transfer it to one of our affiliates, wherever they may be located in the world. 
  • When we share your personal data with third parties unrelated to the Neocortex affliates, we require all such third parties to respect the security of that personal data and to treat it in accordance with applicable data protection laws. We also ensure that at the very least, the same level of protection of data is provided by the third parties, as is provided to you by us. Where we engage third-party service providers to process your personal data on our behalf, we do not allow them to use that personal data for their own purposes and only permit them to process it for our own specified purposes and in accordance with our instructions. When initiating such processor relationships, we will ensure that adequate safeguards are in place for your personal data using the data transfer mechanism most appropriate to the personal data and to the countries within or to which the personal data may be transferred. This mechanism may include: the use of the EU approved contractual clauses; ensuring that the recipient has implemented EU approved Binding Corporate Rules governing transfer or personal data; (in the US) is Privacy Shield Certified (EU and Swiss Privacy Shield) or certified under any equivalent successor programme; or confirming that the country in which the recipient is located has been formally confirmed as providing adequate protections for personal data by the EU.

 

  1. YOUR RIGHTS:

To enforce your rights, please use the details provided in the “Contact. In doing so, please ensure that an unambiguous identification of your person is possible.

1 Right to information and access

You have the right to obtain confirmation from us about whether or not your personal data is being processed, and, if this is the case, access to your personal data.

2 Right to correction and deletion

You have the right to obtain the rectification of inaccurate personal data. As far as statutory requirements are fulfilled, you have the right to obtain the completion or deletion of your data.

This does not apply to data which is necessary for billing or accounting purposes or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).

3 Restriction of processing

As far as statutory requirements are fulfilled, you have the right to demand for restriction of the processing of your data.

4 Data portability

As far as statutory requirements are fulfilled you may request to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible – that we transfer those data to a third party.

 

5 Right of objection

5.1 · Objection to direct marketing

Additionally, you may object to the processing of your personal data for direct marketing purposes at any time. Please take into account that due to organizational reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.

5.2 · Objection to data processing based on the legal basis of “legitimate interest”

In addition, you have the right to object to the processing of your personal data at any time, insofar as this is based on “legitimate interest”. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.

6 Withdrawal of consent

In case you consented to the processing of your data, you have the right to revoke this consent at any time with effect for the future. The lawfulness of data processing prior to your withdrawal remains unchanged.

7 Right to lodge complaint with supervisory authority

You have the right to lodge a complaint with a supervisory authority. You can appeal to the supervisory authority which is responsible for your place of residence or your state of residency or to the supervisory authority responsible for us.

RESOLUTION OF RIGHTS:

  1. Under the law of many countries, you have certain rights in relation to your personal data that is held by us and we respect and observe these rights. Such rights may include the rights to: ask us to confirm that we are processing your personal data, ask us for a copy of your personal data (including information regarding who we share your personal data with); to correct, delete or restrict (stop any active) processing of your personal data; to limit the use and disclosure of your personal data; and to ask us to share (port) your personal data to another person, such as another provider of telecommunications services.
  2. In addition, in certain countries you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). Where applicable, you can also withdraw the consent you have given us to process your personal data and request information on the consequences of not providing such consent.
  3. These rights may be limited, for example: if fulfilling your request would reveal personal data about another person; where it would infringe the rights of a third party (including our rights); or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, to raise any concerns about our privacy practices, or to obtain other privacy related information, you can get in touch with us, see our contact details above. If you have unresolved concerns, you may have the right to complain to your relevant national data protection authority.  Please do contact us before making such a complaint however as we would appreciate the opportunity to investigate and address your concerns first.

Access to Personal Data: You have the right to access, review and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Data.

These rights can be exercised by sending Us an e-mail sales@neocortexls.co.in or writing to us at NeoCortex Life Sciences Private Limited, Reg Off: 8-2-293/82/A/384, ROAD NO.22, JUBILEE HILLS, HYDERABAD, Telangana, 500033 attaching a copy of your ID or equivalent details (where requested by Us and permitted by law). If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. Please note that any identification information provided to Us will only be processed in accordance with, and to the extent permitted by applicable laws. 

Additional rights (e.g. modification, deletion of Personal Data): Where provided by law, you can 

(i) request deletion, the portability, correction or revision of your Personal Data; 

(ii) limit the use and disclosure of your Personal Data; and

 (iii) revoke consent to any of our data processing activities.

Please note that, in certain circumstances, We will not be able to delete your Personal Data without also deleting your user account. We may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our business needs. When you use the Services Website/application (or any of its sub sites), we make good faith efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. We ask individual users to identify themselves and the information requested to be accessed or corrected before processing such requests. We may decline to process requests that are unreasonably repetitive or systematic, requiring disproportionate technical effort, jeopardizing the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. You can make access requests by sending an e-mail to our Grievance officer . You can ask us to correct inaccurate or incomplete personal information.

Where available, our Websites have a dedicated feature through which you can review and edit the Personal Data that you have provided. Please note that We require our registered consumers to verify their identity (e.g. login ID/email address, password) before they can access or make changes to their account information. This helps prevent unauthorised access to your account.

We hope that We can satisfy queries you may have about the way we process your Personal Data. However, if you have unresolved concerns you also have the right to complain to competent data protection authorities.

 

  1. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA

We strive to provide you with choices regarding the Personal Data that you provide to Us. The following mechanisms give you the following control over your Personal Data:

Cookies/Similar Technologies: You manage your consent via (i) our consent management solution or (ii) your browser so as to refuse all or some cookies/similar technologies, or to alert you when they are being used. Please see Section 4 above.

Advertising, marketing and promotions: You can consent for your Personal Data to be used by Nestlé to promote its products or services through tick-box(es) located on the registration forms or by answering the question(s) presented by our Customer Care representatives. If you decide that you no longer wish to receive such communications, you can subsequently unsubscribe from receiving marketing-related communications at any time, by following the instructions provided in each such communication. To unsubscribe from marketing communications sent by any medium, including third party social networks, you can opt-out at any time by unsubscribing through links available in our communications, logging into the Websites/apps or third party social networks and adjusting your user preferences in your account profile by unchecking the relevant boxes or by calling our Customer Care. Please note that, even if you opt-out from receiving marketing communications, you will still receive administrative communications from Us, such as order or other transaction confirmations, notifications about your account activities (e.g. account confirmations, password changes, etc.), and other important non marketing related announcements.

Personalization (offline and online): Where required by law, if you wish to have your Personal Data used by Neocortex to provide you with a personalized experience/targeted advertising & content, you can indicate so through the relevant tick-box(es) located on the registration form or by answering the question(s) presented by our CES representatives. If you decide that you no longer wish to benefit from this personalization, you can opt-out at any time by logging into the Websites/apps and adjusting your user preferences in your account profile by unchecking the relevant boxes or by calling our Customer Care.

Targeted Advertising: We partner with ad networks and other ad serving providers ("Advertising Providers") that serve advertising on behalf of Us and other non-affiliated companies on the Internet. Some of those advertisements are tailored to your interests based on information collected on Neocortex sites or on non-affiliated websites over time. You can visit www.aboutads.info/choices to learn more about this type of advertising, as well as about how to opt-out of interest-based advertising practices from companies that participate in the Digital Advertising Alliance's ("DAA") self-regulatory program. Additionally, you can opt-out of this type of advertising in mobile applications from companies that participate in the DAA's AppChoices app by downloading the app from the iOS or Android app store. You can also stop the collection of precise location data from a mobile device by accessing your device location service settings.

 

  1. CHANGES TO THIS NOTICE

If We change the way We handle your Personal Data, We will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, please check back frequently to see any updates or changes to our Notice.

The internet is an ever-evolving dynamic medium. We may alter our privacy policy from time to time to incorporate necessary changes in technology, applicable law or any other variant. In any case, we reserve the right to change (at any point of time) the terms of this Privacy Policy or the Terms of Use. Any changes we make will be effective immediately on notice, which we may provide by posting the new policy on the "Application". To ensure that you are always aware of how we use your personal data we will update the online version of this Policy from time-to-time to reflect any changes to our use of your personal data. We may also make changes to comply with developments in applicable law or regulatory requirements. Where it is practicable, we will notify you by other means prior to changes materially affecting you such as by posting a notice on our Sites or sending you a notification. We will not be under an obligation to notify you of any changes to this privacy policy except if the changes made to the policy significantly affects your rights or as may be required by law. We may also make reasonable efforts to inform you via electronic mail. In any case, you are advised to review this Privacy Policy periodically on the "Application") to ensure that you are aware of the latest version.

11.SECURITY

 

Security  is our highest priority. We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the personal data we collect through our Sites and in the provision of our services. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall on the cloud; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable, and so we cannot assure you that personal data that we collect will never be accessed or used in an unauthorised way, which may happen due to circumstances beyond our reasonable control. We have put in place procedures to deal with a suspected personal data breach, and we shall notify you and any applicable regulator of a breach where we are legally required to do so. If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team. If you have a user name and password to access our Services, you should take steps to protect against unauthorized access to your password, phone and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen or compromised passwords, or for any activity on your account via unauthorized password activity or other security breach caused by you.

  1. DATA CONTROLLERS & CONTACT

To ask questions or make comments on this Notice and our privacy practices or to make a complaint about our compliance with applicable privacy laws, please contact Us at sales@neocortexls.co.in or writing to us at :

 

Neocortex Life Sciences Pvt. Ltd., 8-2-293/82/A/384, Road No.22, Jubilee Hills, Hyderabad, Telangana, 500033 or 

 

contact our customer care at  info@neocortexls.co.in.

 

We will acknowledge and investigate any complaint about the way We manage Personal Data (including a complaint that We have breached your rights under applicable privacy laws).