As used in this policy, the terms listed below have the following meanings:

Customer

– A “customer” is anyone who purchases ACEFONE products or services. When a customer purchases retail products or services for others, they may be considered as customers for this policy.

User

– A “user” is anyone who visits our websites.

Personal Information

– “Personal information” is information that directly identifies or reasonably can be used to identify an individual customer or user. Examples include but are not limited to name, address, telephone number, e-mail address and financial account number etc. Personal information does not include information that is readily available to the public through no fault of ACEFONE.

Anonymous Information

– “Anonymous information” means information that does not directly identify and cannot reasonably be used to identify an individual customer or user.

Aggregate Information

– “Aggregate information” means information about groups or categories of customers or users, which does not identify and cannot reasonably be used to identify an individual customer or user. Aggregate information is a kind of anonymous information.

Website

– “Website” means any page or location on the internet, no matter what device (cell phone, laptop, PC, etc.) or protocol (http, WAP, ftp or other) is used to access the page or location. In this policy, we use the term website’s other similar terms such as “internet site,” “site,” and “webpage.”

We may collect different types of personal and other information based on your use of our products and services and our business relationship with you, including contact information, billing information, equipment, performance, ACEFONE’s website usage, viewing and other technical information about your use of our network, services, products or websites, information may be collected when you give it to us with the intent to purchase or interact with us about a product or service we offer or provide. When we collect it automatically when you visit our websites or use our products and services; or when we obtain it from other sources, such as credit agencies. ACEFONE may collect/store your calls and SMSs and content thereof, received or initiated using the services, including but not limited to, details of the phone numbers that interact with your account, IVR content and call recordings; and information which it may automatically receive and record on its server logs from your internet browser, including but not limited to, your IP address, cookie information and details of the web pages you request. To register on the website and use the services, you are required to share the information for the effective performance of the services.

Information collected while using the services through mobile application: when you use solutions provided by ACEFONE through mobile applications, including but not limited to ACEFONE dashboard, IVR solutions, automated voice technology, inbound call solutions, ACEFONE may collect information including but not limited to device id, text, graphics, software, phone contacts, photos, videos, music, film clips, digital content, audiovisual combinations, interactive features, call records and other materials that you may view on, access through, or upload to the product or services. Call logs and recordings are available both in ACEFONE’s database as well as the mobile application, while the rest of the information accessed remains on the customer’s device unless saved specifically by the customer on ACEFONE’s application. We may access the call logs on your device to integrate them with ACEFONE’s mobile app. This is used to provide call analytics and a studied pattern of usage for the customer. However, customers can choose to mark calls as personal and disable this feature. All such calls will then be excluded from the analytics. ACEFONE does not store any of the personal call logs on its server.

Our goal of collecting your information is to provide you with the best customer experience possible by communicating with you regarding service updates, offers and promotions; delivering advertising that may be of interest to you; addressing network and security issues; investigating or taking action regarding illegal activities or violations of our terms of use or other policies, as may be laid out in our website from time to time. We collect some information on an anonymous basis and may anonymize the personal information we collect about you into data groups. When we employ non-ACEFONE companies to anonymize or aggregate data on our behalf, the requirements for sharing personal information with non-companies apply. We may share aggregate or anonymous information in various formats with trusted non-ACEFONE entities, with whom we have contracted to aggregate such data and may work with those entities to do research and provide products and services. When ACEFONE jointly provides a service with a non- ACEFONE company, your personal information may be subject to both this policy and the privacy policy of the non ACEFONE company. We encourage you to review the privacy policies of any non- ACEFONE company with which we do business to determine what information will be collected and how it will be used or disclosed to others.

We do not sell your personal information to anyone for any purpose, and we maintain information about you in our business records while you are a customer, or until it is no longer needed for business, tax, or legal purposes. We have implemented encryption or other appropriate security controls to protect personal information when stored or transmitted by ACEFONE. Subject to applicable legal restrictions, such as those that exist for customer proprietary network information and other information applicable under the information technology act 2000 and its applicable rules, the ACEFONE family of companies may share your personal information with each other to make sure your experience is as seamless as possible, and you have the full benefit of what ACEFONE and its subsidiaries have to offer. Customer proprietary network information (CPNI) is information that relates to the quantity, configuration, type, destination, location and amount of use of the telecommunications services you purchase from us, as well as the information contained in your bills for those services. We collect CPNI in the normal course of providing you with telecommunications services. Your telephone number, name and address are not CPNI. We share your personal information only with non-ACEFONE companies that perform services on our behalf, and only as necessary for them to perform those services. We require those non-ACEFONE companies to protect any personal information they may receive in a manner consistent with this policy, and we do not provide personal information to non-ACEFONE companies for the marketing of their own products and services without your consent. We may provide personal information to non-ACEFONE companies or other third parties for purposes such as emergencies, pursuant to court orders, identity verification to prevent fraud and identity theft, enforcing of property rights, or obtaining payment for products and services that appear on your ACEFONE billing statements.

You can review and correct your personal information collected by us. We are happy to correct information found to be inaccurate. Customers may verify that appropriate corrections have been made. However, it may be noted that ACEFONE, its subsidiaries, affiliates and third parties shall not be responsible for the accuracy and/or authenticity of the information supplied by you and ACEFONE hereby disclaims all liability arising out of or in connection with the accuracy and/or authenticity of the information.

ACEFONE uses cookies to store information that can be used to serve ads relevant to your interests, and to help our advertisers measure the effectiveness of a particular advertisement. You hereby acknowledge that ACEFONE uses cookies while providing access to its website and services and consent to its continued use of the same. For clarity, ‘cookies’ are small files that a website or service provider transfers to your computer and/or hard drive through your web browser, provided you consent to the same, that enables the websites’ or service providers’ systems to recognize your web browser and capture and retain certain information. This helps us tailor ads to your interests. These cookies can not only help us ensure that you do not repeatedly see the same ads, but (if you opt-out) they can also help us prevent you from seeing targeted ads at all. The information collected with these cookies is not personally identifiable, and we do not associate it with your personal information. You may opt out of ACEFONE’s use of data for internet-based advertising. Please keep in mind that even after you opt-out, you may continue to see ads, but they will no longer be tailored to your interests. Opting out also does not remove ACEFONE cookies. They will remain on your computer, but we will not use the data connected to your cookie for our services. Please note that if you delete your cookies, you will need to opt-out again to avoid being served targeted ads in the future. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. To opt out of the benefits of our targeted ads, click here: disable ACEFONE cookie. We have relationships with other third-party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These third-party advertising companies may place cookies on your computer when you visit our website or other websites so that they can display targeted advertisements to you. These third-party advertising companies do not collect personal information in this process, and we do not give any personal information to them. However, this privacy statement does not cover the collection methods or use of the information collected by these entities.

The information that you provide to non-ACEFONE companies is not covered by this policy. For example: when you download applications or make an online purchase from a non-ACEFONE company while using ACEFONE’s services or click on certain links which may direct you to other websites not maintained by ACEFONE (the “third party website”) , the information collected by the non-ACEFONE company/ third party website is not subject to this policy. If you use public forums — such as social networking services, internet bulletin boards, chat rooms, or blogs on ACEFONE or non-ACEFONE websites — you should be aware that any personal information you disclose publicly can be read, collected, or used by others. Once you choose to reveal personal information on such a site, the information is publicly available, and ACEFONE cannot prevent distribution and use of that information by other parties. You hereby further acknowledge and agree that ACEFONE has no control over the information in such an event. ACEFONE urges you to acquaint yourself with the terms and conditions and privacy policy of every such third-party website and in this regard, ACEFONE hereby expressly disclaims all liabilities with respect to the way the third-party website collects and/or uses the information. ACEFONE may enter into written product or service agreements with business customers that contain specific provisions related to the confidentiality, security or other handling of information. When provisions of a written product or service agreement differ from or conflict with the provisions of this policy, the terms of the written agreement will apply. In all other instances, the terms of this policy apply.

We have established electronic and administrative safeguards designed to secure the information we collect, to prevent unauthorized access to or disclosure of that information and to ensure it is used appropriately. Although we strive to keep your personal information secure, no security measures are absolute, and we cannot guarantee that your personal information will never be disclosed in a manner inconsistent with this policy (for example, as the result of unauthorized acts by third parties that violate the law or this policy). We will make reasonable attempts to notify you if we determine that ACEFONE has experienced a security breach and there is a reasonably likely risk of identity theft, or where otherwise required by law.

We have established policies and practices to meet the expectations of customers and potential customers who have expressed a desire to limit certain types of solicitation communications from ACEFONE, including marketing contacts made via telephone, e-mail and text messaging. You can also request to be removed from these telemarketing lists when you receive a marketing or promotional call. Where required by laws and/or regulations, we honor requests from businesses to be removed from our telemarketing lists. The TRAI maintains a national do not call registry at “NDNC”. Putting your number on these registries also may limit our telemarketing calls to that number. Our practices as described above are designed to satisfy legal requirements limiting marketing contacts. You should know that those laws and regulations — such as the requirements governing the national “do not call” lists — generally permit companies to contact their own current and, in some cases, former customers, even when those customers are listed on the national “do not call” lists. Similarly, restricting our use of your CPNI will not eliminate all types of ACEFONE marketing contacts.

ACEFONE works hard to detect and prevent junk e-mails (also referred to as “spam” e-mails) from ever reaching your computer. However, if you are receiving unwanted spam from an ACEFONE e-mail address, please contact us for assistance at [email protected].

Third-party marketing providers or we may use your information for marketing of our products, services, offers, and discounts only as per your pre-selected marketing preferences and applicable laws. We use google ads remarketing to advertise our products and services across the internet. Google ads remarketing will display ads to you based on what parts of the website you have viewed by placing a cookie on your web browser. It also shows ads to the people who share a similar interest and characteristics to our site visitors. The cookie does not in any way identify you or give access to your computer or mobile device. Google AdWords remarketing allows us to tailor our marketing to better suit your needs and only ads that are relevant to you.

If you do not wish to see ads from the ACEFONE, you can opt out in several ways:

1. Opt out of Google's use of cookies by visiting Google's ads settings.
2. Opt out of a third-party vendor’s use of cookies by visiting the network advertising initiative opt-out page.

When selecting usernames and passwords for ACEFONE accounts, you should choose words or characters that are not obvious. Likewise, you should always keep personal information such as account numbers, usernames, passwords or similar information in a secure place and not share the information with others.

ACEFONE is not intended for or designed to attract users under 18, and we do not intentionally or knowingly collect personal information on our websites from anyone under 18. We encourage parents to be involved in the online activities of their children / minors to ensure that no information is collected from a child without parental permission.

Support data is the information we collect when you submit a support request or run an automated troubleshooter, including information about hardware, software, and other details related to the support incident, such as: contact or authentication information, chat session personalization, information about the condition of the machine and the application from when the fault occurred and during diagnostics, system and registry data about software installations and hardware configurations, and error-tracking files. We use support data as described in this privacy statement, and additionally use it to resolve your support incident and for training purposes.

Payment data is the information that you provide when you make online purchases. This may include your payment instrument number (e.g., Credit card, PayPal), your name and billing address, and the security code associated with your payment instrument (e.g., The CSV or CVV). You hereby acknowledge and agree that the payment data, to the extent consisting of details related to the manner and mode of payment of fees for the use of the website and services (such as details of your bank account, credit card, debit card, net banking, etc.), Submitted by you while making payment of fees: (a) goes through the safe and secure transaction process provided by ACEFONE’s payment gateway partners; (b) goes through the visa or Mastercard pages, as the case may be, based on your payment method(s) in order to prevent any misuse of your payment details; and (c) that such payment details are not shared with the website, ACEFONE, its subsidiaries, affiliates and third parties or any other users of the website and services.

Push notifications: when you use ACEFONE on your device, ACEFONE may use notification services available for that device to let you know of incoming calls, chats and other messages when you are not actively running or using the ACEFONE application. These services may be provided by a third party. For example, messages sent to an apple device may use apple’s push notification services. Notification services may receive information about the caller, sender of the message and the content of the message as part of providing the service and may use the information in accordance with the terms and conditions and privacy policy for the third-party service provider. ACEFONE is not responsible for the data collected by third party notification services. If you do not want to use third party notification services to receive notification of incoming ACEFONE calls and messages, you can disable this in your notification settings in the ACEFONE application settings or in the notification settings found in your device settings.

Information about our customers and users, including personal information, may be transferred as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the unlikely event of an insolvency, bankruptcy, or receivership in which customer and user records would be transferred to another entity as a result of such a proceeding, you acknowledge and agree that the information may form part of the transferred assets. You further acknowledge that the acquirer or successor of ACEFONE may continue to use the information in the manner set forth herein, provided that ACEFONE shall make reasonable commercial efforts to ensure that the acquirer or successor keeps the information that they may receive from ACEFONE confidential as per industry standards.

We reserve the right to update this privacy policy as necessary to reflect any changes we make and to satisfy legal requirements. If we make a material change to this policy, we will post a prominent notice of the change on our websites and provide you with other appropriate notice and choice regarding the use of your information, at least 30 days before the effective date. Please check our websites periodically for changes to this privacy policy. You hereby acknowledge and agree that your continued use of the website and services constitutes your agreement to this privacy policy and any updates hereto.

We are happy to address any questions or concerns you may have about our privacy practices and policies. You may e-mail us at [email protected] or write to us at SERVETEL INFOCOM PRIVATE LIMITED, bougainvilla apartments, pocket B3, Vasant Kunj, New Delhi – with an appropriate marking, for example “LEGAL”, “PRIVACY POLICY”, “REPORT ABUSE”, etc. If you believe you have been aggrieved by any act of ours in violation of the law, we encourage you to contact us directly at either of these addresses to resolve your question or issue. You also have the option of filing a complaint with our website in our “SUPPORT PAGE”, using an online form, or by calling 0124-4018891.Other rights and remedies also may be available to you under applicable Indian laws.

By using ACEFONE’s website and/or registering for and using the services, you consent to our privacy policy. In the event that you do not agree with and/or consent to the terms and conditions set out herein, please do not use or access the website and services. You hereby acknowledge and agree that by mere use of the website and services, you expressly consent ACEFONE’s collection, receipt, storage, processing, disclosure, transfer, dealing with and handling of the customer data in accordance with this privacy policy. You understand that while your account is active to use the website and services, ACEFONE, its subsidiaries, affiliates and third parties engaged by it, may retain your information and use it in any manner in order to comply with its contractual obligations and other obligations under applicable law. In the event that you wish to withdraw your consent to ACEFONE’s collection, receipt, storage, processing, disclosure, transfer, dealing with and handling of the information, you may contact ACEFONE at [email protected], informing ACEFONE of your withdrawal of consent to its use as aforesaid of your information. You hereby acknowledge and agree that in case you withdraw your consent to ACEFONE’s use and disclosure of your information as provided for in this privacy policy, ACEFONE hereby expressly reserves the right to discontinue provision of access to the website and services at its own sole discretion.

2.1 what personal data means?

The personal data means any information that helps directly or indirectly in the identification of any natural person. It may use or do not contain an identifier such as name, identification number, location details, an online identifier (such as email address, profile URL, and others), or any factor relevant to the social, cultural, economic, mental, genetic, physiological, or physical identity.

2.2 what is the sensitive personal data?

Sensitive personal data contains the above information but includes the following information specifically.

• Medical conditions
• Philosophical or religious beliefs
• Political opinions
• Ethnic or racial origin
• Convictions
• Any membership

2.3 what is data controller?

As per Article 4 of General Data Protection Regulation (GDPR), the "data controller" determines the purposes and the manners to process the data.

2.4 what is data processor?

The "data processor" is either an organization or a person who processes the personal data for the Data Controller.

2.5 what is the data processing?

It is an operation or set of operations performed upon personal data, or its sets, either manually or by automated systems. Article 4 in General Data Protection Regulation (GDPR) lists the Data Processing examples that include collection, storing, recording, structuring, organizing, adapting, consulting, altering, retrieving, disclosing by transmission, using, disseminating or making available, combining or aligning, restricting, destruction, or erasure.

3.1 personal data you provide

We collect the following information that you provide us directly when you use our Website, Apps, or Services.

• Title
• Name (including First Name and Last Name)
• Job Title
• Company Name
• Email Addresses
• Address
• Phone Numbers
• Usernames
• Information related to our services
• Marketing Preferences
• Credit Card, Banking, or other Payment Information
• Transactional Information
• Any communication, inquiry, or contact with us
• Other information you provide during the usage of our services

We use the above-mentioned personal data for that specific reason only for which you have provided it to us. If you want us to remove any personal information from our database, please contact us at [email protected]

3.2 account information

We collect the following information when you create an account with us, modify the account, set preferences, or make purchases.

• Contact Information
• Billing Information
• Self-picture or Profile Photograph
• Job Title
• Preferences
• Or other required information

3.3 information we collect automatically

When you visit our Website, submit a query on the Website, use our Chat, or use other services, we automatically collect information from your device (such as computer or smartphone).

NOTE: In some countries, including EEA (European Economic Area), this information is termed as personal data as per their data protection laws.

3.3.1 usage information

We track your activities when you visit our Website, use our Apps, or avail our Services. We collect following information during these activities and use them to make the proposed facility or service much better.

• Billing and payment details while making purchases on the Website
• Emails and other communications
• Device information such as hardware model, operating system, device identifier, phone number, and other configuration information
• Log information such as date/time stamp, operating system, browser details, content viewed on the Website, clickstream data (that helps in analyzing the visited Web Pages and the order to visit them followed by a visitor), Internet Service Provider details, and other
• The Internet Protocol (IP) Address of device used to access our Website, Apps, or Services
• Communication logs such as SMS (text messages), voice broadcast, calls, and conferences taking place using our platform
• Metadata that contains information about other data, such as title, author, abstract, keywords, size, and others

3.3.2 cookies and other similar technologies

We may use cookies to collect the previously mentioned information. Moreover, we deploy similar technologies such as web beacons and others. Please view "Acefone Cookies Policy" for more information about the cookies and other technologies.

3.4 information obtained from third-parties

3.4.1 information received from third-parties for marketing

We may collect the following information about the individuals from the public domain (such public databases or social platforms) and receive (purchase) it from third-parties to market our products.

• Name (including First Name and Last Name)
• Email Addresses
• Postal Addresses
• City and Country of office or residence

The collection, usage, storage, and processing of the above-listed information, and the marketing is performed in accordance with the applicable laws.

3.5 information received from your-opted third-party services

When you or your administrator link or integrate a third-party service with our Services, we may receive information that is controlled by your account or settings with the selected third-party service provider. It can be done for any purpose, such as accessing, storing, sharing, and editing content, connecting to calendaring services to allow you to manage the meetings, connecting to an address book service to allow you manage and use the contacts, and others.

The information we receive from such third-parties during such integrations depends upon and is controlled by your account settings by third-party providers, your selected or their default permissions, and their privacy policy. We recommend you check the privacy policies and settings of your preferred third-party service providers to understand what all data will be shared with us during such integrations.

We may use your information to deliver our services, personalise your experience, run marketing campaigns with third-parties, and for other purposes listed hereinbelow. These include our services you have opted, the way you are using them, and your preferences either set in your account with us or communicated to us through any channel.

4.1 delivering services

We may use the information to deliver you our services or their parts, for which you have subscribed with us. We use the information to identify you as our customer, authenticate you as a registered user, process transactions, deliver your opted services, provide customer care support, and maintain our deliverables. For example, the name and picture provided in your account are used to identify you and the provided login credentials are used to authenticate your login at our Website.

4.2 personalizing user experience

Your information is used to personalise the user-experience and improve your productivity and collaboration when you visit our Website, use our Apps, or avail our services. We automatically analyse the activities of you and your added team members to deliver the most relevant notifications and other feeds, activity logs, recommendations, connections, and search results. If you are using our multiple services, we combine your information and activities to offer you a unique user experience overall.

We may use the title of your name or domain name given in the email address to identify you or your affiliation with a specific organization to personalise your experience and serve you relevant content when you visit our Website or use our services.

We may combine your pre-selected user role (such as an administrator or regular user) and your activities to show the information (like feeds or search results) that are very important for you. Similarly, we may hide administrative details from a normal user.

4.3 marketing with third-parties

We have partnered with third-party marketing service providers to run our marketing campaigns through different channels including email. Third-party marketing providers or we may use your information for marketing of our products, services, offers, and discounts only as per your pre-selected marketing preferences and applicable laws. You can opt-out from our email marketing campaigns by clicking "Unsubscribe" link given at the bottom of any promotional email.

4.4 other specific purposes

In addition to service delivery, personalisation of your experience, and marketing, your information is used for the following purposes specifically.

• Delivering our Website, Apps, or Services to you and your users or customers
• Administration, operating, protection, and maintenance of our Website, Apps, or Services
• Analysing your usage of our Website, Apps, or Services for user analysis, traffic analysis, monitoring trends, marketing, and advertising
• Improving our Website, Apps, or Services to enhance the user experience
• Processing and completing the transactions related to your purchases
• Delivering the support to you when you contact us in case of any help related to our Website, Apps, or Services
• Responding to your requests and inquiries to provide you with the requisite information and services
• Sending you communications through email or text messages such as transaction confirmations, invoices, administrative communication, security notifications, technical updates, and alerts
• Detecting and preventing unauthorised access, fraudulent practices, and illegal activities related to our Website, Apps, or Services
• Target Advertising and Marketing Practices as per your preferences and law
• For other purposes for which we have received your consent either through preferences or other mediums

4.5 legal basis to process personal information of users of european economic area

The legal basis to collect and process the personal information of users of the European Economic Area depends upon the type of concerned information and the purpose to collect it. Acefone usually collects your information, including personal data, with your consent only. We may need this information to deliver you the requisite information or service as per a contract with you, or where the processing of your information is in our legitimate interests and is not overridden by your freedom, fundamental rights, or data protection laws. Acefone also has the legal obligation as per law to collect and process your personal information.

We may state the purpose to collect information at every instance, whenever we ask you to provide any personal information required either to offer you with your requisite service, or to enter in a contract with you, or to comply with a legal requirement. We may also advise you about the essentially required components of your information, including personal data, and consequences if you do not deliver the required information.

The use of your information, including personal data, by our third-party partners or by us are already listed in the "Usage of the Information Section". If your information is used for other purposes by our third-party partners or by us, we will notify you about the purpose and interests at that instance.

If you need more information or have any query related to our legal basis to collect and use your information, contact us at [email protected]

Acefone is not in the business of selling the personal information of anyone to third-parties including advertisers. Instead, we share your information with third parties only in the following situations.

5.1 sharing information with our other users

When you start using our Services, we share some specific information related to you with our other Service users.

5.2 sharing information with managed accounts and administrators

You register with our Services through an email address containing a domain name, which is owned by your organization or employer. If such an organization may wish to create a site or an account, your information such as name, contact details, content, profile picture, and past usage of your account may be accessible to the administrator of that organization and our other Service Users who are using the same domain name. If you are a group member, group owner, or administrator of a site or user group (created within our Services), your contact information may be shared to facilitate the Service-related requests with the group members who are present or past users of our Services.

5.3 sharing information with third-parties

We may share your information with the third-parties, who help us in operating, providing, improving, integrating, customizing, delivering support, and marketing our Services.

5.3.1 sharing information with our service providers

We may take services from third-party service providers for Website development, Application development, Website, and Data Hosting, on-premises or virtual infrastructure, backup, storage, payments, analysis, and others. These services are necessary to run our operations. Our third-party service providers may need to access or use your information to deliver us our required services. Any access to our service providers to your information is made as per our close instructions, which are guarded by our policies and procedures to protect your personal information.

5.3.2 sharing information with our partners

We work with our third-party partners, who provide us technical services, sales, and consultation that enable us to deliver and implement the solutions related to our services. With your consent, we may share your information with our third-party partners as per their services.

5.3.3 sharing information with third-party applications

You, an administrator, or another user on your behalf may install or integrate third-party applications within our Services to get a new functionality or to change the default behaviour of our Services. With such integration, opted third-party application may get access to your account information such as your name, email address, contact details, and any content that you select to use with that application. If you are billing, technical, or administrative contact for an account, your details may be shared with the third-party application providers upon such integration. We cannot control, and this Privacy Policy document does not cover how third-party applications use your information. Therefore, before going for any such integration, we recommend you go through the privacy policies of such third-party application providers to know about their information and privacy handling practices. If you have any objection to share your information with such third parties, please undo the integration by uninstalling the third-party app or using another medium.

5.3.4 sharing information with the third-party review or social media sites

We may ask you to share your feedback and rate us on third-party online reviews and online social media Websites. If you already have created an account on such a third-party site, they already have access to your information. Or if you create an account yourself or upon our request, such a third-party review or social media site may get access to your information such as your name, email address, contact details, your profile name, your profile picture, and any content that you select to share or use with that site. We cannot control, and this Privacy Policy document does not cover how these third-party sites use your information. Therefore, before taking any such step yourself or upon our request (to rate our services there), we recommend you go through the privacy policies of such third-party sites to know about their information and privacy handling practices. If you have any objection to share your information with such third-party review or social media sites, please do not process our request or do not take your self-decision to rate us and write about us there. Our request to rate us on such third-party review or social media sites is not our endorsement of a linked service or site with them.

5.4 sharing information with your consent

We take your consent to share your information with third parties for marketing purposes.

Example: After taking your consent, we may share your name, picture, and feedback on our Website for marketing purposes.

5.5 sharing information with our affiliates

We may share and disclose your information to our affiliates or prospects who could be our affiliate. Affiliated companies are owned or operated by us. Our information security procedures and privacy policy protect your information shared in such cases.

5.6 sharing information with business partners, vendors, and authorized third-party agents

We may share and disclose your information to our business partners, vendors, or authorized third-party agents for the following purposes.

• Enforcement of our acceptable use policy
• Marketing, operating, delivering, improving, and customizing our Services
• Providing technical and other support
• Sending marketing and other communications
• In connection with acquisition, sale, merger, reorganization, or financing with prospective or actual selected companies

5.7 sharing information to comply with laws, compliances, and enforcement requests

We have to share your information, including your personal data, with Government bodies, regulatory authorities, law enforcement agencies, Courts, or other third parties only if we have a good-faith belief that use or sharing of your information is really necessary due to any of the following reasons.

• Comply with a legal obligation or process, law, regulation, compliance, Court order, or a Government request for any reason or to meet requirements of National Security
• Enforce our terms of services, policies, and agreements
• Protect the integrity and security of our Website, Apps, or Services
• Protect our property, rights, and interests or those of third-parties
• Protect the public or our customers from fraud, harm, or other illegal activities
• Detect, prevent, or investigate the technical issues, frauds, or any wrongdoing related to our Website, Apps, or Services

6.1 access and update your information

• Wherever needed or where demanded by law, we provide you opportunities to access, view, modify, and delete their own information that we are processing.
• You may also have wider rights to access, modify, and delete the personal information. You can also object and restrict the processing of your information or make a request for its portability. You can contact us at [email protected] to make such requests. We will treat all such requests as per the applicable laws.
• If you have earlier given your consent to us to collect, use, process, and share your information, you can withdraw your consent. Withdrawal of consent, neither affects the lawfulness of processing conducted before your consent withdrawal request nor affects the processing your information, including personal data, performed as per law requirements irrespective of your consent.
• You can complain to the Local Data Protection Authority at any time.

6.2 your privacy rights as an EEA person

We take the consent of our customers of the European Economic Area (EEA) before processing their information, and we do on their behalf only. As per any applicable EEA law, if you want to access, review, modify or delete your information that we are processing on another customer’s behalf, you have to contact that Customer to request the same. We can only help you and that customer to fulfill your request as per your instructions.

Also, as per any applicable EEA law, if you want to access, review, modify, or delete your information that we are processing on your behalf, please contact us at [email protected].

This Privacy Policy document does not cover, and Acefone is also not responsible for the privacy, information, and practices of third parties, including those third parties for whom our Website or Services have links (URLs), and those third parties whose Website or Services have links to our Website or Services. A link or URL to any Website is not our endorsement of a linked service or a site with them.

It is very important for us to secure your information, including your personal data, that we collect through our Website, Apps, or Services. We have put different standard administrative, technical, and other organizational security procedures in place to safeguard your information during transmission, processing, usage, and storage.

Acefone neither controls nor have responsibility for the security, privacy policies, and practices of other Websites that you may visit and use for different purposes, even if you visit them using the links given on the Website, Apps, or Services.

Please note that no online service, App, or Website is completely secure; still, we are committed to protecting your information through the above-listed measures. However, we cannot guarantee the occurrence of data breach, data loss, hacking, and unauthorized access.

Acefone will retain your information, including your personal data, until the purpose for its collection is fulfilled unless a longer data retention period is really required or as such asked by the law (for regulatory, legal, tax, or different reasons), and other legitimate business requirements.

Where we have no continuously going on legitimate business purpose to retain or process or your information, we either anonymize or delete it.

9.1 retention of account information

Your account information is retained for as long as your account is active with us. After the deactivation of your account, it is retained for a reasonable period in which you can decide to reactivate the account. If this period also expires, we delete most of the information, but we will retain some necessary parts of your information to maintain records, to meet the law requirements, to meet legal obligations, to enforce our agreements, to support business operations, to solve disputes, and to continue or improve our Services. Where we retain the account information to improve or develop our Services, we take steps to eliminate that part of the information that identifies you directly. We use and process information to know the collective insights of the usage of our services, instead of analysing specifically about your personal characteristics.

9.2 retention of the information you shared on our services

If your account on our Services is disabled or deleted, still some of your content and information that you have provided will remain so that the other members of your group and other users continue to make full use of our Services. For example, we have to display the content that you have shared and messages that you have sent to the users even after disabling or deletion of your account.

9.3 retention of marketing information

If you have opted to receive the marketing communications, including email or text messages, we retain your marketing preferences and other information for a specific period starting from the date when you last displayed interest in our Website, Apps, or Services, or stopped using your account.

9.4 retention of information received from cookies and other similar technologies

We retain information received from the cookies and other similar technologies for a fixed specific period starting from the date when such information was collected at first.

You have the following choices to access and control your information, including personal data, which we collect, store, use, and process.

10.1 your choices

You can make the following requests related to your information, including personal data.

• Request a copy of your information
• Request for the restriction or deletion of your information
• Request to receive your information in an electronic and structured format
• Raise objection to our use of your information (such as information for marketing)

We have mentioned hereinbelow the processes and tools to make these requests.

If you are a member of a user group created in our Services, your information and opted Services are being administered by a Group Administrator, so in the first place, you have to contact your Group Administrator for such requests. We would in such a situation where you face any issue in getting your such request processed by a Group Administrator.

For all other requests, you have to contact us at [email protected].

Please note that your choices and requests may be limited in some specific cases, such as if meeting your request can disclose information about other persons, or if you request to delete the information that your Administrator or we have compelling legitimate reasons or permissions as per law to keep that information. If you have asked us to share your information (and personal data) with third-parties (for example by installing third-party apps in our Services or integrating our services with third-party), you have to contact those third-parties directly to make requests to access, review, modify, restrict, or delete your information.

If you have a concern or issue related to your information, including personal data, please contact us at [email protected]. If your concern remains unresolved even after contacting our dedicated Privacy Team, you can raise a complaint to a Data Protection Authority in the country where you live, work, or where your right was infringed.

10.2 access and update your information

In our Services, we give you the options to access, review, and modify your certain information. Such as you can access and modify your profile information in your Account Settings and search for the content that may contain your information using the text-based search in our Services. The content containing information about you can also be edited using the provided tools in our Services. If you need any help to access or update your information, please contact us using the details given at "Contact Us Page" of this Website.

10.3 deactivate your account

If you do not want to use our Services, you or your administrator on your behalf can contact us using the details given at "Contact Us Page" of this Website to deactivate your account. Please refer to the "Retention of Account Information Section" to know about the retention of your account information.

10.4 request to stop us from using your account

In some cases where you believe we do not have rights, you can request us to stop storing, accessing, using, and processing your information, including your personal data. For example, if you believe that your account has been created on our Services without your permission or if you are no more using our services actively, you may request us to delete your account. If you had earlier given consent to use the information towards a limited purpose, you might contact us to withdraw your consent, but it could not affect any processing or usage of your information that has been taking place already. You can click "Unsubscribe" link given at the bottom of promotional emails, being sent as a part of our Marketing Campaigns.

We need time to investigate, process, and facilitate such opt-out requests. If there is any delay or dispute (as to our rights to use your information) related to your such opt-out requests, we restrict any further processing or usage of your information until your request is honoured or the dispute is resolved unless your administrator has any objection.

If you want to object to the information being shared with a third-party service or app, you or your administrator can either disable such third-party app or service or contact us to get it disabled.

10.5 opt-out of communications

To opt-out from our promotional marketing campaigns, you can click "Unsubscribe" link given in each promotional email sent to you. You can update the email preferences in your account settings, or by contacting us at [email protected]. You can also opt-out from some notifications in your account settings itself. Even if you opt-out from receiving promotional emails and messages, you will continue to receive the transactional communications related to our Services.

Your information, including your personal data, may be collected in, stored in, transferred to, or processed in the countries different from the country where you live, work, or where your right was infringed. Your information collected outside European Economic Area (EEA) specifically can be transferred to or stored on our servers located in countries where Acefone, our group companies, our partners, or other third-parties operate. The Data Protection Laws of these countries can be different to Data Protection Laws of your country, and these may not be as much protective as your country’s laws in some cases.

However, Acefone has deployed the appropriate safeguards to protect your information, including personal data, as per this Privacy Policy document and applicable laws.

Acefone does not create or offer products or services, which are designed to be used by or take information whatsoever from the children below the age of 16 years. If you believe that information or personal data of a child below 16 years of age has been shared or disclosed to Acefone, please contact us at [email protected].

If we modify our Privacy Policy document, we will publish these changes on this page and update the "Last Updated" section given at the top. We will notify you directly by sending an email or by posting a message or notification on this Website, before making changes in this Privacy Policy document effective. We encourage you also to go through this Privacy Policy document regularly to be informed about the latest changes.

If you have queries, concerns, comments, or feedback about our Privacy Policy document, please email us at [email protected].