Privacy Policy

INTRODUCTION

Crossbow Global Marketplace Solutions Pvt. Ltd. (“Crossbow Global”) (the “Company”) offers Digital Employment Background Verification. It is provided to you i.e. the User who utilizes the Website/Portal/Mobile Application (“Services”) of the Company. This Privacy Policy presents the modes by which the Company collects, uses and

discloses information of the User, and the ways in which the User’s privacy is protected. This Privacy Policy describes the practices adopted by the Company in connection with information collected through activities that link to the Privacy Policy. By providing Personal Information to the Company through any of the Services, Users agree to the terms and conditions of this Privacy Policy.

1.PERSONAL INFORMATION

What is Personal Information?

Personal Information of the User is information that identifies the User to the Company through the Services, as an individual, such as two or more of the below:

• Name
• Date of birth
• Gender
• Email address
• Postal address
• Telephone/mobile number
• Educational qualification records
• Employment history records
• PAN
• Aadhaar
• Voter ID (If need arises)
• Passport (If need arises)
• Driving license (If need arises)
• Bank statement (If need arises)
• Credit information (If need arises)
• Medical records and history (If need arises)

If Users submit any Personal Information of other people to the Services, such Users represent that they have the authority to do so and to permit the Company to use such information in accordance with this Privacy Policy.

How Personal Information may be Collected

The Company may collect Personal Information in a variety of ways, including:

Personal Information may be collected through the Services, for e.g., when the Users sign-up, browse the Services, etc.

Personal Information may be collected from the offline services, such as when the Users contact customer services in relation to any queries that the Users may have.

Personal Identifiable Information (PII) may be collected from other sources, such as public databases, joint marketing partners, social media platforms and other third parties. For example, if Users elect to connect or interact with the social media account of the Company with their account, certain PII from their social media account will be shared with the Company, which may include PII that is part of their profile or their friends’ profiles.

The Personal Identifiable Information that is provided through the Services may be combined with PII and other Information that the Users provide to the Company, that is publicly available or that the Company may otherwise obtain online or offline.

How Personal Identifiable Information may be Used

Personal Identifiable Information is used for the following:

To respond to enquiries and fulfill the requests of the Users, such as to send them newsletters, respond to questions/comments, etc.

To send Users administrative information that may be important for the use of the Services that they may not opt out of receiving, for e.g., information regarding the Services, changes made to the terms, conditions and policies, updates, etc.

To contact the Users or even re-contact them if the Company has not heard from them in a while. To send advertising/promotional material to the Users.

For the Company’s business purposes, such as analyzing and managing their business, retargeting offers, market research, audits, developing new products, enhancing and improving the Services, identifying usage trends, determining the effectiveness of the promotional campaigns, gauging customer satisfaction and providing customer service.

As the Company believes to be necessary or appropriate:

Under the laws applicable and in force in India;

• To comply with legal process;
• To respond to request from public and Government Authorities;
• To enforce the Company’s terms and conditions;
• To protect the Company’s rights, privacy, safety or property and/or that of their affiliates, the Users or others;
• To protect the operations of the Company; and
• To allow the Company to pursue available remedies or limit the damages that they may sustain.
• To carry out anonymous analytics and publish reports as may be required for the business purposes of the Company

How PII may be Disclosed

The Company discloses the Personal Information of Users in the following ways:

To the Company’s affiliates.

To third party service providers who provide services such as data analysis, payment processing, infrastructure provision, IT services, customer service, email delivery services, auditing services and other similar services to enable them to provide the Services.

With third parties. All third parties will use the Personal Information of Users in accordance with their own privacy practices. The Users should check the websites or apps of the third parties for information regarding their privacy practices.

PII disclosed by the Users on the Services and the official social media pages of the Company may, at the sole discretion of the Company, become public information and may be available to the general public. Users must be careful when deciding to disclose their Personal Information or any other information on such mediums, as the Company shall not be responsible for the misuse of such information.

To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Company’s business, assets or stock (including in connection with any bankruptcy or similar proceedings).

As the Company believes to be necessary or appropriate:

Under the laws applicable and in force in India;

• To comply with legal process;
• To respond to request from public and Government Authorities;
• To enforce the Company’s terms and conditions;
• To protect the Company’s rights, privacy, safety or property and/or that of their affiliates, the Users or others;
• To protect the operations of the Company or its affiliates; and
• To allow the Company to pursue available remedies or limit the damages that they may sustain.

2.OTHER INFORMATION

What is Other Information?

Other Information is any information that does not reveal the specific identity of the User. Other Information shall

include the following:

• Browser and device information,
• Server log file information,
• Information collected through cookies, pixel tags and other technologies,
• Services’ usage data,
• Demographic information,
• Location information, or
• Aggregated information.

How Other Information may be Collected

The Company and their third party service providers may collect Other Information in a variety of ways, including:

• Information collected through browsers or automatically through the device of the Users, such as language, Internet browser type and version, service provider, and the details of the Services they are using. The Company uses this information for statistical purposes as well as to ensure that the Services function properly.
• Information collected through the server log files. The IP Address is a number that is automatically assigned to the computer or device that the Users are using by their Internet Service Provider (ISP). An IP Address is identified and logged automatically in the Company server log files whenever a User utilizes the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites and apps.
• Information collected by using cookies. Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. The Company uses cookies and other technologies to, among other things, better serve the Users with more tailored information and facilitate their ongoing access to and use of the Services.
• Information collected using pixel tags, web beacons, clear GIFs and other similar technologies. These may be used in connection with some pages and email messages to, among other things, track the actions of Users and email recipients, measure the success of the Company’s marketing campaigns and compile statistics about the Services’ usage and response rates.
• Information collected through the Users’ use of the Services. When the Services are viewed or used by the Users, the Company and their service providers may track and collect the usage data, such as the date and time the Services on the User’s device accesses its servers and what information and files have been downloaded to the Services based on such device number.
• Information collected from the Users, such as gender and postal pin code, their preferred means of communication, etc. may be collected when they voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify them.
• Information collected from the device using satellite/cell phone tower/WiFi signals. The Company may also share information about what advertisements were viewed on the device and other information collected, with the service providers and marketing agencies to enable them to provide Users with more personalized content, including advertising and to study the effectiveness of advertising campaigns. In some instances, Users may be permitted to allow or deny such uses, but if they choose to deny such uses and/or sharing, the Company and/or its providers may not be able to provide them with the applicable personalized services and content.
• Information collected from Aggregated Personal Information, as this does not personally identify the Users of the Services, for e.g., Personal Information of Users may be used to calculate the percentage of users who belong to a particular city, etc.

How Other Information may be Used and Disclosed

The Company and its affiliates may use and disclose Other Information for any purpose, except where they are required to do otherwise under applicable law. If they are required to treat Other Information as Personal

Information under applicable law, then, in addition to the uses listed in the “How Other Information may be Collected” section above, they may use and disclose Other Information for all the purposes for which they use and disclose Personal Information.

In some instances, they may combine Other Information with Personal Information (such as combining the name of Users with their zip code). If they combine any Other Information with Personal Information, the combined information will be treated by the Company as Personal Information as long as it is combined.

3.THIRD PARTY WEBSITES / APPS

This Privacy Policy does not address, and the Company is not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or app to which the Company’s Services contain a link. The inclusion of a link on the Services does not imply endorsement of the linked website or app by the Company.

This Privacy Policy does not govern third party e-commerce websites or apps. Any Personal Information that Users provide through a third party e-commerce websites or apps will be subject to their privacy policy and not this Privacy Policy. The Company has no control over, and shall not be responsible for, the use of information collected through a third party website or app.

The Company is also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information disclosed by Users to other organizations through or in connection with the Services or social media pages of the Company. The Company has no control over, and shall not be responsible for, any third party’s use/misuse of information that Users provide to such platforms through the use of the Services.

4.THIRD PARTY ADVANTAGE VENDORS

The online and email advertising-related vendors of the Company may use pixel tags, web beacons, clear GIFs or other similar technologies in connection with the Services to help manage the online and email advertising campaigns and strengthen the effectiveness of such campaigns. For example, if a vendor has placed a unique

cookie on a User’s device, the vendor may use pixel tags, web beacons, clear GIFs or other similar technologies to recognize the cookie during such User’s visit to their website or app and to learn which of the Company’s online advertisements may have brought the User to their websites or apps, and the vendor may provide the Company with such Other Information for their use.

The Company may link such Other Information provided to them by their vendors to Personal Information about Users that they have previously collected. Such combined information will be treated as Personal Information hereunder as long as it is so combined.

The Company may use third party advertising companies to target advertisements to Users on the Services based on the Personal and Other Information collected from and about Users, as well as information relating to them on this and other websites or apps. To do so, these companies may place or recognize a unique cookie on the Users’ browser (including through the use of pixel tags) or recognize an identifier associated with their device.

5.SECURITY

The Company uses reasonable organizational, technical and administrative measures to protect Personal Information under their control. We have implemented the best practices taking into reference the international standards like ISO 27001 & ISO 27701, which focus on commitment towards the security & privacy controls. Our organization uses various detection & preventive controls such as Anti-virus, DLP, MFA and other technical and logical access controls. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If Users have reason to believe that their interaction with the Company’s Services

are no longer secure, it is their duty to immediately notify the Company of the problem by contacting the customer service personnel and the Company shall take necessary action as the Company may deem fit, under the circumstances. The Company shall not be held responsible for any disclosure of information herein which results

from the Users’ failure to keep their Personal or Other Information secure.

6.OPT-IN AND ACCESS

The Users may opt-in regarding the Company’s use and disclosure and use of their Personal Information.

If at any time Users wish to stop receiving email marketing communications from the Company, they shall let the Company know by emailing, or by using the unsubscribe feature in the marketing email they received.

Users may make changes and updates to the information provided by them on the Services. Any changes they make through the Services shall be updated by the Company and will be reflected on the Services.

In addition, the Company will not disclose a User’s Personal Information to third parties for the third party’s direct marketing purposes if they have received and processed a request from the Users that their Personal Information not be shared with third parties for that purpose.

All the changes that Users require and request the Company to make may not be effective immediately. The Company will endeavor to comply with the request(s) as soon as reasonably practicable. If Users opt-out of receiving marketing-related messages from the Company, the Company may still send them important administrative messages which the User cannot opt-out from receiving.

To review, correct, update, suppress, delete or otherwise limit the Company’s use of Users’ Personal Information that has been previously provided to them, the Users must email, call or write to the customer service personnel and clearly describe the request. The request must clearly state what information the Users would like to change, suppress or limit. The Company will try its best to comply with such requests, however, if certain information by their inherent nature are not capable of change/removal then such information shall not be removed or changed and the Company shall not be held responsible/liable for the non-compliance. Further, certain information is mandated and necessary to be retained for recordkeeping purposes and the same shall be so retained irrespective of a request to the contrary.

7.RETENTION PERIOD

The Personal and Other Information collected by the Company shall be retained for the period necessary to fulfill the purposes outlined in this Privacy Policy, in part or in full, unless a longer retention period is required or permitted by law.

8.USE OF THE SERVICES by MINORS

The Services shall not be used by minors. The Services are directed only to individuals who are permitted to share their Personal Information without parental consent and such Users requiring parental consent or consent from their natural/legal guardian shall not be permitted to disclose their Personal Information/Other Information through the Services and are hereby cautioned from providing the same. However, despite such caution if such User were to provide such information, then the Company shall not be responsible for the same.

9.COOKIE NOTICE

Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimize user experience and for features and services to function properly. We use automatically collected information and other information collected through our website through cookies and similar technologies to: (i) personalize our service, such as remembering your information so that you will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service

10.SENSITIVE INFORMATION

The Company requests the Users not to disclose any sensitive Personal Information (for e.g., information related to political and religious views, any material that is obscene, indecent, vulgar, profane, etc.) on or through the Services or otherwise to the Company.

11.UPDATES TO THIS PRIVACY POLICY

The Company reserves the right to change, amend, modify or alter this Privacy Policy, from time to time, at its sole discretion. The Users are advised to look at the “Last Updated” legend on the Services to see when this Privacy Policy was last revised. Changes made to this Privacy Policy will become effective when they are posted on the

Services. The Users’ use of the Services following these changes shall mean that they have accepted the revised Privacy Policy.

For any queries or concerns with respect to data privacy, please reach out to the DPO at ravindranath@digiverifier.com