Last updated [July 21, 2020]
Objective and Scope
Aaryaa Digital Private Limited (“we”, “us”, “our”, “Aaryaa Digital Private Limited”) values the trust placed in us by data subject (“you”, “your”, “user”, “subscriber”) and therefore, we assure that we follow the highest standards of privacy guidelines to protect the information shared by you with us.
By using Aaryaa Digital Private Limited (for example, when you register for an account, enter a contest or promotion, 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 to determine the relevant Aaryaa Digital Private Limited services which should be offered to you. In the event IP detection fails, we will consider the last cached location as your current location to provide you with Aaryaa Digital Private Limited 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 the Aaryaa Digital Private Limited.
Collection and Use of Personal Information
‘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.
A. Information you provide to us
Information Collected at the Time of Registration When you register using your web accounts like Facebook & Twitter we retrieve the following Information from your account(s) to continue to interact with you and to continue providing you the Services. Information that we collect include -
• User Name
• E-mail id
• Mobile number
• Public profile information – (Facebook & Twitter) Information collected under my profile section when a user has completed with the registration:
• Date of Birth
• Profile picture upload
• Pin code
We may collect sensitive personal information when you provide feedbacks, report spam, participate in polls, survey, contest etc. for the activity it is being collected. This information will only be captured if you have provided us with explicit consent.
Information collected when you use our Mobile Application When you download our mobile application we may collect, including but not limited to, the below information from you-
• Email ID
• Mobile number
• Location/IP address for geo-locating
• Device ID
• SMS for OTP
• Android Advertiser ID/ iDFA ID
Information you provide to us voluntarily
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect and store such information.
We may collect additional information at other times, including but not limited to, when you provide feedback(s), modify your content or email preferences, respond to surveys, provide comments, or communicate with us. This information may include your name, e-mail id, mobile number, location, etc.
B. Information automatically collected while browsing /navigating through the website
Do Not Track
The Website and Aaryaa Digital Private Limited currently do not process or respond to “Do Not Track” requests/signals which some internet browsers have the ability to send out.
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.
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.
C. Inferred Information through usage and log data
We may track certain information about you based upon your behaviour on the Aaryaa Digital Private Limited. We use this information for conducting internal research on our users' demographics, devices, interests, and behaviour to better understand, protect and serve our users.
We may also collect Your Information to track user behaviour and preferences for internal analytics and research. We may also use your information:
i. To evaluate your interest for various genres of content, services, offers;
ii. To perform analytics and conduct customer research, to determine your interest, for identifying content that generate sales and to analyse 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.
The above information may also be captured by keeping cookies on our websites by our affiliates for the purposes mentioned above.
D. Information we collect from third parties
a) Information obtained from other Sources
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.
b) Information obtained from third party websites
If you link, connect or login to your Aaryaa Digital Private Limited account with third-party services they may send us information such as your registered e-mail id and public profile information from the service as stated below;
• Facebook – Email ID and public profile information which includes name, profile picture, age gender etc.
• Twitter – Email ID, see who you follow, read tweets from timeline, post tweet for you, access direct messages and update your profile
c) Demographic and other 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.
d) 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 by the . 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.
e) 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).
Disclosure to Third parties
a) Service Providers
b) Promotional Offers
We may share or disclose your personal information outside of Aaryaa Digital Private Limited when we have your consent. For example, providing SMS and E-mail related services such as marketing Digital/Aaryaa TVletters, promotions and offers.
We do not provide any personally identifiable information to third party websites / advertisers / ad-servers without your explicit consent.
In the event Aaryaa Digital Private Limited is merged with or acquired by another company or in case of re-organization or re-structuring of business, we and our affiliates may share your personal information, wholly or in part, with another business entity.
e) Business transfers
Information we share with our group companies/affiliates
When you interact with any of the Aaryaa Digital Private Limited websites (such as follow articles, follow other users, follow activities etc) Aaryaa Digital Private Limited will collect your follow activities and create a Aaryaa Digital Private Limited profile against those activities for you to refer to them at a later stage and review articles and your activities. Aaryaa Digital Private Limited doesn’t collect any additional personal information but only tracks your behaviour on various Aaryaa Digital Private Limited Websites and the activities that you choose to follow or the users you wish to follow. Any comments, views, shares that are performed by you on the Aaryaa Digital Private Limited Websites will be publicly available information. Usage of our Mobile Applications
This policy shall also apply to our Mobile Applications that are available in the country governed by a data protection regulation. These Mobile applications have been updated to make them compliant to the country governed by a data protection regulation and few of the services have been discontinued in certain platforms in the country governed by a data protection regulation. You are urged to update to the most current version of certain apps listed and/or to delete certain apps that we no longer provide access, service or support so that we do not collect or store information of users located in the country governed by a data protection regulation. If you use an older version of these apps and/or access discontinued services, then we may collect, store and process your information. In such case we would not be responsible or liable for such collection, storage and processing of your information.
Purposes and Lawfulness of processing
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 use information to provide, analyse, 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
• 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.
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.
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.
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. Information sharing with third parties
The Company shares your information with any third parties without obtaining the prior consent of User in the following limited circumstances:
a) When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations.
c) 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.
d) 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.
How long do we store and use your information
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 Aaryaa Digital Private Limited and its services. We will delete your information whenever you request us to do so. However, we may archive and/or retain some information for legal purposes. Your Controls and Choices
A. Accessing and Rectifying your personal information
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 will get a link on your registered Email address through which you can access all the data Aaryaa Digital Private Limited collects and stores about you. You can ask us to correct inaccurate or incomplete personal information.
• a. Concerning your login credentials by editing the same through My Accounts section, through the SSO portal. The same shall be reflected across all properties.
• b. Concerning details that are separately collected and maintained by Aaryaa Digital Private Limited by sending an e-mail to our support team to perform the rectification.
B. Data Portability
You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format; wherever feasible.
C. Data Retention and Erasure
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 Aaryaa Digital Private Limited account. Please note that if you request for the erasure of your personal information;
• 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 a Aaryaa Digital Private Limited 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 the Aaryaa Digital Private Limited, 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 of time 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.
D. Withdrawing Consent and Restriction of Processing
For withdrawing your consent at any time during the tenure of your services with us, you may choose to do so by sending us an e-mail. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you and stop any further processing of your personal information
You can write to us in case of any grievance or compliant at the support e-mail address. If you have any complaints regarding processing of your personal information you may contact our data protection officer at the below mentioned e-mail address. You have the right to complaint about the data processing activities carried out by Aaryaa Digital Private Limited before the competent data protection authorities.
F. Objection to Processing
Where your personal information is processed for direct marketing purposes or any contests or promotions or other services, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to us.
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact us at the below mentioned e-mail address.
We may take 30 days from the date of receipt of request to complete your requests. However, if the nature of the requests is excessive in nature or would require significant effort then may ask for an extension of 60 days by giving a prior notice to you with the reason for the extension. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize 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.
Aaryaa Digital Private Limited is not intentionally designed for or directed at persons less than 16 years of age. Aaryaa Digital Private Limited does not knowingly permit any person who is under 16 years of age to register with the services or to provide any other personally identifying information. If Aaryaa Digital Private Limited becomes aware that any personally identifiable information of persons less than 16 years of age has been collected on the Aaryaa Digital Private Limited without verified parental consent, then Aaryaa Digital Private Limited 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 16 years of age or offer to send any promotional materials to persons in that category. Aaryaa Digital Private Limited 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 Aaryaa Digital Private Limited with personal information without their prior consent, please contact our customer support team to ensure that the personal information is removed from the Aaryaa Digital Private Limited.
Data transfer, storage & processing globally
Security and Compliance with Laws
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. 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. If you know or have reason to believe that your Aaryaa Digital Private Limited 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. Changes in the Policy