Your privacy is of prime importance to us. We value your Personal Information that you share with us. We appreciate the trust you have reposed in us in doing so. Through this Privacy Notice we would like to inform you of the manner in which we collect and process your Personal Information using our websites and mobile applications for you to avail the services offered by our Company, its subsidiaries and branch offices (hereinafter referred to as ‘Access Infinity’, ‘we’, ‘us’ or ‘our’).

The Services, so offered here, adhere to all the laws, rules, regulations and policies including European Union – General Data Protection Regulation (“EU – GDPR”) and Data Protection Laws of United Kingdom (“Applicable Laws”) with regard to the collection, use, disclosure, retention, purging and protection of your Personal Information that our Company would have access to as a result of your use of our Services and consent thereto.

1. Controllers of Personal Information
   1. Access Infinity Limited having its registered office at 2 Attfield Close, London N20 0LG, United Kingdom is the Data Controller of Personal Information collected and processed for providing the services.
2. What the Company collects from you
   1. Information that you give us
      • Any Personally Identifiable Information (‘Personal Information’) that we collect from you, with your consent, that relates to you, which includes your name, gender, phone number, email address, communication address, date of birth, identity proof, phone number, medical records, et cetera, in furtherance to the services being offered by us.
      • We may also collect recurring information of your geographic locations on a continuous basis in furtherance to the services being provided by us.
   2. Information that receive automatically
      • We automatically collect and store certain types of information, including but not limited to usernames, passwords, and other security and usage related information, whenever you visit or utilize the Services such as Log Data, Analytical Code, Time Stamp, Geo Stamp, IP address, version and identification number of the App and device, browser type, browser language, the date and time of your request, your profile, websites visited by you, search terms used, your mobile carrier data, platform type, number of clicks, phone number, requested status of other Users and various status information with regard to the Services provided through [Product] (“Usage Information”). Such Usage Information collected is not associated with any Personal Data and is only tagged to the unique identifier for a particular device.
      • As a standard practise, we use “cookies” for collecting information, from your device through which you are accessing our Services, in order to allow you to enter the sessions without frequently having to enter your password. These cookies are temporary and are automatically deleted from your device at the end of every session.. You are always at the discretion to decline the cookies.
   3. Information that is anonymous
      • We may also collect such other anonymous information that is not associated with or linked to any Personal Information (“Anonymous Data”) and which, by itself, does not permit the identification of any individual User. Anonymous Data includes without limitation, unique identifiers of the device on which [Product] is installed, such as VPN, information of WiFi connectivity and such other information. We may also store this unique identifier, at many times and create a profile for you based on such Anonymous Data.
3. Purpose for which the information, so collected, is being used

   We may use the Personal Information and the information so associate with it for the following purposes:

   • to effectively provide the Services;
   • for the purposes of software verification or administering software upgrades;
   • to allow you to participate in surveys regarding Services;
   • to maintain the quality of the Services and provide general statistics regarding their use;
   • to deliver Services, including email notifications, confirmations, technical notices, updates, security alerts, and support and administrative messages that you may request;
   • archival or backup purposes;
   • to alert you about updated information and other such new or updated services that may be offered by other Users;
   • to allow access to exclusive features or functionality of [Product];
   • to launch and/or open other mobile applications installed on your device based on functionality of [Product]; and
   • to resolve disputes, collect fees and troubleshoot problems.
4. Sharing of the collected information
   • We may share the Personal Information, so received from you, in the following manner:
     • With the Company’s affiliates in connection with matters relating to the consumption of Services by you to help detect and prevent identity theft, fraud and other potentially illegal acts; correlated or multiple accounts to prevent abuse of Services; and to facilitate joint or co-branded services that you request, where such services are provided by more than one corporate entity other than the Company; and
     • if required to do so by law or regulation; to its legal counsel, law enforcement officers, governmental authorities who have asserted their lawful authority to obtain the information or where the Company has in good faith reasonable grounds to believe that such disclosure is reasonably necessary to enforce its Terms of Use or this Privacy Policy.
   • The Company shall not rent, sell, or otherwise provide Personal Data received from you to third parties without your consent, except as described herein or as required by law. However, the Company and its affiliates reserve the right to share, sell and transfer some or all of the Personal Data to other business entities should the Company, or its assets, plan to merge with, or be acquired by that business entity.
5. Security of Personal Information
   • The Company has implemented commercially reasonable physical, managerial, operational and technical security measures to protect the loss, misuse, alteration and security of the Personal Information received from you in the Company’s care. The Company’s security practices and procedures limit access to Personal Data only on ‘need to know’ basis. Such measures may include, where appropriate, the use of firewalls, secure server facilities, implementing proper access rights management systems and processes, careful selection of processors, standard authentication and encryption policies for its servers and other technically and commercially reasonable measures.
   • The Company is committed to protecting the security of any Personal Data and uses reasonable efforts including a variety of security technologies and procedures to help protect such Personal Data from any unauthorized access, use or disclosure. However, the Company can only guarantee such protection of your Personal Information reasonable control. In situations involving any breach, the Company will try to rectify the problems as soon as possible.
   • Any Personal Information, so destroyed, shall be disposed of in a manner that protects the privacy of the Personal Information received by us from you in an appropriate manner as per the industry standard practices and norms.
   • You hereby acknowledge and understand that all Personal Data provided by you is with your express consent and understand the risk involved sharing your Personal Information.
6. Your Obligation
   • As a registered user of the Services, you have certain obligations to other users. Some of these obligations are imposed by applicable law and regulations:
     • You must, at all times, abide by the terms and conditions of the Privacy Policy and Terms of Use.
     • You must respect all intellectual property rights that may belong to third parties.
     • You must not upload or insert any comments that may be deemed to be injurious, violent, offensive, racist or xenophobic, or which may otherwise violate the purpose and spirit of our Company and its community of users;
     • You must keep your username and passwords confidential and not share it with others; and
     • All information given must be genuine and true. The Company shall not be held responsible in case of any fraudulent information given at the time of registration for using our Services.
     • Any violation of this Privacy Notice by you may lead to the restriction, suspension or termination of your account with us, at the sole discretion of the Company.
7. User’s Rights
   • For being in the European Economic Area (‘EEA’), you have the following rights with respect to your Personal Information:
     • Right to Access: You have the right to request for a copy of, or access to your Personal Information held by us. You may be required to prove your identity before providing the requested information;
     • Right to Rectification: You have the right to direct the Company to rectify any inaccurate or incomplete Personal Information;
     • Right to Deletion; Right to be Forgotten: You have the right to request the Company to delete your Personal Information to the extent Diligent is not required to retain such data in order to comply with a legal obligation;
     • Right to Restriction of Processing: You have the right to restrict the Company from processing your Personal Information;
     • Right to Data Portability: You have the right to request the Company to transfer your Personal Information to another data controller to the extent possible;
     • Right to Object: You have the right to object to any processing of your Personal Information carried out on the basis of our legitimate interests;
     • Right to Withdrawal of Consent: If you have consented to the processing of your Personal Information by the Company, you have the right to withdraw your consent at any time.
   • The EU GDPR and UK Data Protection Laws require a legal basis for us to use your Personal Information. Kindly note that the legal justification may vary depending on the specific purpose for which we use your Personal Information.
8. International Transfer of Data
   • In the process of providing you the Services, the Company may transfer your Personal Data and other information that it collects to affiliated entities, within or outside the EEA, which is duly permitted under the applicable laws governing data protection and privacy.
   • In the event, we transfer your Personal Information to countries outside of the EEA or the United Kingdom, we ensure that such Personal Information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection and Privacy.
   • Kindly note that we rely on European Commission adequacy decisions or use contracts with standard safeguards published by the European Commission and similar measures under the laws in United Kindly for such transfers.
   • The Company shall ensure adequate level of protection by entering into Standard Contractual Clauses for the transfer of data as approved by the European Commission under Article 46 of General Data Protection Regulation (“GDPR”), or the Company shall seek your prior consent to such international data transfers.
9. Governing Law
   • The usage of the Services is exclusively governed by the Laws applicable to England and United Kingdom and the jurisdiction of the competent courts at London.
   • The Company expressly disclaims any implied warranties or liabilities imputed by the laws of any other jurisdiction.
10. Modifications
    • Any modification to this Privacy Notice by the Company would be in accordance with the application laws and posted on the Website to reflect such modification so that you are always aware of what information Company collects and processes your Personal Information.
    • You are requested to periodically visit this page for the latest information on Company’s privacy practices. Once posted, those changes are effective immediately. Continued access or use of [Product] constitutes your acceptance of the changes and the amended Policy.
11. Third Party Sites
    • The website may contain links to other third-party websites that may collect the Personal Data. You agree to comply with all third-party privacy policies, if any, applicable to the use of such websites or its services.
    • The Company is not responsible for your use of any third party product and/or service including the terms and conditions, privacy practices or the content of those linked websites or such third party product and/or service or violation and infringement of any third party rights, policies, terms and conditions in connection with access, download or installation of such mobile applications.
12. Advertisements
    • The Services offered by our Company may use third-party advertising and links to other websites and applications. The advertising partners may collect your Personal Information when you interact with their content, advertising or services.
    • We never share your Personal Information with such Companies. Instead, we may use an advertising identifier like a cookie or other device identifier and share only your advertising identifier and data about that event.
13. Questions/Grievance
    • In the event of query or clarification regarding this Privacy Notice you may write to the email address: [email protected]
    • In the event, you have grievances with respect to your Personal Information, you may write to the email address: [email protected]