We are committed to safeguarding the privacy of our website visitors and “Platform” users.
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and Platform users; in other words, where we determine the purposes and means of the processing of that personal data.
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://www.docubay.com/privacy-policy
In this policy, "we", "us" and "our" refer to “DOCUBAY MEDIA PRIVATE LIMITED”. For more information about us, see Section15.
Consent To Access Personal Information:
How We Use Your Personal Data:
In this Section 3 we have set out:
The general categories of personal data that we may process;
In the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
The purposes for which we may process personal data; and
The legal bases of the processing.
Information Provided By You:
The following under mentioned data shall be provided by you:
Your name, e-mail address, address, postal code, inclusive of payment methods, and, telephone number.
Certain other information like your choice to provide further information pertaining to preferences, account settings, reviews, ratings, or any other information provided to us through our service, or elsewhere.
Data Collected Automatically:
The undermentioned data gets collected automatically:
Your activity on the Platform, which would include your search history, your search inputs, services or products viewed over the Platform, visits and the time stamps;
Device IDs and other unique identifiers like IP address, browser type, version, network service provider details;
Device and software characteristics including types and configurations, connection information, statistics on page views, URLs with time stamp;
Your interactions with our customer support via various support channels like e-mails, messages;
Service support and transaction history;
Information collected by cookies, and other technologies, also including advertisement data, etc.
Use of Information Collected by Us
In order to provide you with the services of the Platform and offer you enhanced use of the features of our Platform, we use your information to:
process your registration, and provide you with your login account details;
process your orders and payments in respect of our services;
provide you with algorithm based content including but not limited to regional content, customized and personalized viewing options, recommendations on videos, movies, etc. which you may like to watch;
perform analytics and customer research, to improve our service, including the user experience and the interface;
offer you certain types of services, free trials, and other applicable offers based on your eligibility.
offer you relevant contextual advertisements wherever applicable.
promote the Platform on social media.
How Do We Protect Your Information
We take appropriate technical and organizational measures to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the Information to be protected, having regard to the state of technological development and the cost of implementing any measures.
In order to protect your Information against any unauthorised access or any unlawful use, we use various technical and operational security measures such as but not limited to:
Limiting access to your Information to those employees, agents, franchisees, contractors, Third Party Service Providers and other third parties, who have a business need to know.
Ensuring the physical security of our offices, Websites and our application Platform, further ensuring digital and physical security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions.
Implementing processes (such as password hashing, login auditing, and idle session termination) to protect against unauthorized access to your Information.
Maintaining internal policies and deliver data protection and confidentiality training to our employees to ensure they understand their responsibilities towards protecting and safeguarding your Information and if required take appropriate measures to enforce these responsibilities.
Processing of Transaction Data
We may process information relating to transactions, including purchases of our subscription services that you enter into with us and/or through our website or Platform (“Transaction Data”) .The transaction data may include your contact details, your card details and the transaction details. The source of the transaction data is provided by you and/or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract/ Terms and Conditions between you and us and/or taking steps, at your request, to enter into such a contract/ Terms and Conditions; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the representatives of our Website or the administration of our website and business team shall not contact you for the same.
Information Regarding your Data Protection Rights under General Data Protection Regulation(GDPR)
We herein promise to follow the following principles for Data Protection:-
Data Processing is lawful, fair, and transparent. Our data Processing activities shall have lawful grounds. Our Website/Platform shall always consider your rights before processing your personal data. We shall also provide you information regarding processing of the data upon request.
Processing of the data shall be or is limited to the purpose. Our website’s data processing activities will fit the purpose for which personal data of an individual was gathered by our Company.
Processing is done with minimal data. Our Company only gathers the data and process only minimal amount of personal data required by our Company for any purpose.
The processing of the Data shall be within the same corporate group as our business or organization/ group companies and it shall abide the corporate rules regarding data processor.
Our company ensures that, processing of data is for limited span of time, we do not store your personal data for longer period than required by the officials of our Company
We shall do our best to ensure the integrity and confidentiality of your personal data.
Law Processing in Europe
The personal information collected by our company shall be used by us on lawful bases and our company shall use for the activities as defined herein under this policy in Europe as required under the European Data Protection law; are:
Wherein it is necessary for entering into a performing a contract/ Terms and Conditions with you.
Wherein we have a legitimate interest to do so, as per the information collected by our company your rights do not override these interest.
For Payment processing purposes
Wherein you have consented to its use of your personal information by our companies or any of its group companies, affiliates, subsidiaries etc.
Wherein our colleagues or our group companies, affiliates believe it is in your vital interest to share your personal details, for example with emergency services.
Wherein you are required to comply with our legal obligations.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. In certain circumstances, you have the following data protection rights:-
Right to Information: According to the RTI you have the right to know whether your personal data is being processed; what data is gathered, from where it is obtained and why this data is obtained and for whom such kind of data is processed.
Right to restrict processing: wherein certain conditions apply, you shall have a right to restrict the processing of their personal data used by us.
Right to erasure: In certain circumstances you shall have a right to request us to erase your personal data from our records.
Right to object the Data processing: In case of Direct marketing you shall have a right to object the processing of your personal data with any other third party or additional cookies used by our company.
Right to object for automated Processing: You shall have the right to object for automated processing of your data which shall include information that is automatically stored by Cookies and other session’s tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc.; such information is used to improve your customer experience. Such Data processing shall not be subject to a decision based solely on the automated processing. You can exercise such right whenever there is an outcome of the profiling that may produce legal effects concerning or significantly affecting you.
Right of Data Portability: You shall have the right to obtain your personal data in a machine i.e. in a readable format or if it is feasible, as a direct transfer from one Processor to another processor.
Right to lodge a Complaint: In the event our Company or our representative’s fails to process your request under the Rights of Access; we herein ensure you to provide you with a reason as to why we are unable to process your data. In such circumstances if you are not satisfied with the manner of handling your request, you can contact our customer care on our email address: Contact@docubay.com
Right to withdraw consent: You shall have the right to withdraw your consent at any time for processing of your personal data.
How Can You Protect Your Information:
In addition to us protecting your Information, you can also protect your Information if you take reasonable measures to protect the same, such as but not limited to - (i) Choose strong passwords and change them regularly (ii) at all times ensure that your Subscription references and passwords are kept confidential and ensure that you do not share them with anyone else; (iii) do not use your same password for multiple accounts (iv)if you are a registered user then you may ensure that you log out after each session; (v) in case you suspect that your password or booking reference has been compromised or if someone may have accessed your account, then you must immediately inform us; (vi) keep your devices protected by ensuring that you’re using the latest version of your operating system and have suitable anti-virus software, if applicable; and (vii)stay away from any and all fraudulent emails.
Sharing and Disclosure of Information
While the Platform is the recipient of your Personal Information or Sensitive Personal Information, we may allow access of this information to various third parties with whom Docubay has direct legal and confidentiality obligations and such data shall stay with them only for limited purpose and period for the processing and storage of information, provision of account to you, provision of customer support, content development and delivery, and other purposes as identified in the clause 3.4 of this Policy.
We also engage various service providers to perform services on behalf of us enabling us to provide you services better. Such services may include, communications, advertising, infrastructure and IT, payment gateways processing payments, customer support, data analytics, conduct customer surveys, geo tagging/ location based content. It is our constant endeavour to ensure that such service providers adhere to a similar standard of data protection and security that we have agreed to under this Policy. At times, when we offer promotional offers in collaboration with third party entities, we will not be responsible for the privacy practices of such third party entities.
Docubay, and our service providers may be required to disclose and otherwise use your personal and other information where we or our service providers reasonably believe that there exists the need to so disclose, and/or in case of any of the following requirements:
To meet or satisfy any applicable law, regulation, governmental request, or, legal process;
To address and investigate any illegal activities, which may also include financial frauds, any security or technical issues;
To protect itself against any harm, misuse, of the property or safety of Docubay Media Pvt. Ltd., its users and the public, as required or permitted by law.
In the event where there is any restructuring, reorganization, merger or sale, or any other transfer of assets, we shall transfer such information, including your personal information, subject to an Terms and Conditions by the other party with respect to your personal information in a manner which is consistent with this Policy.
Protecting the privacy of young children is especially important. For that reason, Docubay does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete the information we have stored as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us as indicated in the "Our details" section below.
Interaction with Other Applications, Platforms
Cross Border Transfers
Processing of Data outside the European Union:
Our Company’s Website(s) / App(s) are hosted in India.
We may also use services which may be outsourced to consultants or any other services in the countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the Indian Territory or any other country, can be processed outside the European Union. Our company ensures to follow safeguards with respect to data transferred outside the European.
There shall be international transfer of your personal information as our Website/ Platform being part of international business and the technologies used by our company, all your personal information may be accessed by our colleagues and our third-party service providers from the locations outside the European Economic Area, We shall use appropriate safeguards approved by the European Commission as mentioned herein below under clause (v).
Our Company aims to include in the contracts/ Terms and Conditions of any of our third party suppliers and consultants in standard clauses approved by the European Commission ( which is also known as “The EU Model Clauses”) in order to ensure that their data processing have been complied with the security standards as required within European Union.
Your Rights and Your Preferences
At all times, you have the right to access your personal information, or update, or correct the personal information we hold about you. This can be easily done by you through your “Account Settings”, which empowers you with multiple information about your account, which may relate to your contact information, payment information, and several other relevant information about your account. To access this section, and make the relevant changes, you must be logged into your Account.
You also have the right to make a request to us, for deleting your personal information as available with us. You also acknowledge that deletion of some of these details may result in cancellation of your registration.
If you no longer wish to receive certain communications from us via e-mail, messages, you can access the “Account Settings” and make your choice to unsubscribe. Please note that you cannot however, unsubscribe to service related correspondence made by us to you, such as messages regarding your transactions, subscriptions. You can also choose not to receive any push notifications, as may be enabled on your devices; this can be done through your device settings.
Compliance With Our Legal Obligations:-
Information may be identified from your browsing activity:
Your request to our web browser to our servers for web pages or platforms and other content on our website your information is recorded by our website or platform. We shall record information such as your geographical location, your internet service provider, your IP Address etc. and we shall also record information about the software you are using to browse our Website/ Platform. For example, the type of computer or devise and the screen resolution etc. We may use this information in aggregate ton assess the popularity of the Webpages/ Platform applications on our website and how our Company performs in providing content to you. If combined with other information our company’s server/ website gathers data about you from your previous visits, the data possibly could be used to identify you personally, even if you are not signed into our Website or the platform application.
Cookies and Advertising:
Cookies Used By Our Service Providers:
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
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Docubay Media Private Limited
Having its registered address at:
Ground Floor, Techweb Center,
New Link Road, Oshiwara, Jogeshwari (West),
Mumbai - 400102, Maharashtra, India
Data protection officer:
Name of our Data Protection Officer: Amey Kini
Some data controllers and data processors will have an obligation to appoint a data protection officer (DPO). The basic obligation is set out in Article 37(1) of the GDPR:
"The controller and the processor shall designate a data protection officer in any case where: (a) the processing is carried out by a public authority or body, except for courts acting in their judicial capacity; (b) the core activities of the controller or the processor consist of processing operations which, by virtue of their nature, their scope and/or their purposes, require regular and systematic monitoring of data subjects on a large scale; or (c) the core activities of the controller or the processor consist of processing on a large scale of special categories of data pursuant to Article 9 and personal data relating to criminal convictions and offences referred to in Article 10."
Article 13(1) of the GDPR provides that:
"Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information ... (b) the contact details of the data protection officer, where applicable".