This Privacy Notice (the "Notice") sets out how we, Cuddle Artificial Intelligence Private Limited, 1st Floor, Raheja Titanium, Western Express Highway, Goregaon East, Mumbai 400 063 (hereafter "Cuddle", "we", "us", "our") process the personal data of individuals (each a "User", "you", "your") who contact us or who use our websites, services, programs, content and related features (collectively, the "Services").
If you have any questions about this Notice, please contact us by email@example.com.
Please find below the details of the Data protection officer (DPO):
Name: Naushad Shaikh
Email id: firstname.lastname@example.org
This notice, together with any other documents referred to in these documents, set out our views and practices regarding your personal data and how we will treat it. Please read these documents carefully. By visiting our website or using our Services, you acknowledge the processing described in this Notice and related documents.
We will let you know, by posting on our website or otherwise, if we make any changes to this Notice from time to time. Your continued use of the Services after notifying such changes will amount to your acknowledgement of the amended Notice. This version of our privacy notice was published in October, 2018.
What is personal data?
"Personal data" means any information relating to an identified or identifiable natural person, known as 'data subject', who can be identified directly or indirectly; it may include name, address, email address, phone number, IP address, location data, cookies, call recording and similar information. It may also include "special categories of personal data" such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a data subject, data concerning health or data concerning a natural person's sexual orientation.
What personal data do we process?
We may process the following personal data:
Generally, you are under no obligation to provide this information, but without it, we may be unable to provide you with some of our Services. Some personal data will be mandatory in order for us to comply with mandatory client due diligence processes before we are able to provide the Services.
- Information provided by you. You may give us information about you by filling in forms such as the "Get Started" form and "Contact us" form on our website or corresponding with us by e-mail, phone or otherwise. This information may include your name, email address, company name, and employment information (including but not limited to: country, employer, job title and department, telephone number and facsimile numbers) and the content of any email you send to us and other personal identifying information.
- Information about others. You may also provide to us personal data relating to third parties, such as people who you work with, reporters and other individuals who comment on markets and news, business actors relevant to your industry and other individuals.
- Information about your device. When you visit our Website or use our Apps, we may collect technical information about your device. This information is compiled and analyzed on both a personal and an aggregated basis. The information may include Device Location, Device Locale Language, Device Make, Device Model, Device Platform Name, Device Platform Version, Application SDK Name, Application SDK Version and Device Carrier.
- Information from third party sources. This may include information received from our service providers and other third parties providing us with your information which is publically available or collected by them.
We do NOT collect sensitive personal data of website users such as financial information such as bank account or credit card or debit card or other payment instrument details, physical, physiological and mental health condition, sexual orientation, medical records and history and biometric information.
Information about third parties should only be provided if you have demonstrable permission to do so or if the information is available in the public domain.
Since Cuddle.ai is a Business Intelligence platform, we have no control over the data uploaded by you for analysis. We provide insights and analysis based on the information provided by you.
We will rely on the information provided by you as accurate, complete and up to date and you agree to ensure that this will be the case.
You must be at least 18 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use or disclose Personal data about visitors that are under 18 years of age.
How do we use your personal data?
We will only process personal data, in accordance with applicable law, for the following purposes:
The legal basis for our processing of personal data for the purposes described above will typically include:
- Responding to your queries, requests and other communications.
- Providing the Services including our website, apps/platform and related features as well as providing other information services.
- Resolve disputes, troubleshoot problems and enforce our agreements with you, including our Sales Terms and Conditions, and this Private Policy.
- Enabling suppliers and service providers to carry out certain functions on our behalf in order to provide the Services such as sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, etc. These third party service providers have access to personal data needed to perform their functions, but may not use it for other purposes. We do not sell, rent, share, or otherwise disclose personal data from customers for commercial purposes.
- Register to subscribe to newsletters.
- Participate in discussion forums.
- Diagnose problems with our servers, software, to administer our site, to gather demographic information and to track visitors to our website.
- Sending you personalized marketing communications based on your interests opted upon filling forms on our website.
- Serving personalized advertising to your devices, based on your interests in accordance with our Cookie Statement. You have the right to disable cookies as set out in Cookie statement. Click here to access our Cookie Statement.
- Complying with applicable law, including in response to a lawful request from a court or regulatory body.
- processing necessary for our or a third party's legitimate interests, such as processing for the purposes set out in paragraphs (a), (b), (c), (d), (e), (f), (g) and (h) which is carried out on the basis of our legitimate interests to ensure that Services are properly provided,
- your consent, such as processing for the purposes set out in paragraphs (i);
- processing necessary for compliance with a legal obligation to which we are subject, such as processing for the purposes set out in paragraph (j); and
- any other applicable legal grounds.
Disclosure of personal data
There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. These scenarios include disclosure to:
The service providers are contractually bound not to share Personal data collected from visitors to our website with anyone else.
- our affiliates or sister companies;
- our service providers who capture and store data collected through the forms that are filled by visitors to our website;
- subject to appropriate legal basis such as consent, our advertising and marketing teams who enable us, for example, to deliver personalized ads to your devices or who may contact you by email, telephone, SMS or by other means;
- our service partners to operate our website and better serve the visitors to our website:
- payer, such as your employer, who pays for our products and services;
- public authorities where we are required by law to do so; and
- other third parties where you have provided your consent.
Cookies are used for the following purposes:
- Necessary cookies: These cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don't collect any Personal Data.
- Functionality cookies: These cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, they might remember your name and e-mail so you don't have to re-enter this information next time when commenting.
- Analytics cookies: These cookies are used to track the use and performance of our website and services.
- Advertising cookies: These cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator's permission. These cookies remember that you have visited a website and this information is shared with other organizations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organization.
Click here to know more about the type of cookies we use.
At our site you can be assured that your Personal data is secure and consistent with current industry standards. The importance of security for all Personal data associated with our user is of utmost concern to us. We do not do any transmission of the Personal data collected through our website. Our service partners, who assist us in capturing and storing Personal data, are contractually bound not to share that information with any other party. Our company has a requisite information security policy in place with appropriate managerial, technical, operational and physical security control measures to protect the personal and non-personal information that is collected from website users.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal data, you acknowledge that:
- there are security and privacy limitations of the Internet which are beyond our control;
- the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and
- any such information and data may be viewed or tampered with in transit by a third party.
Retention of personal data
We retain personal data for as long as is necessary for the purposes listed above or longer as may be required by the law or as per the client requirement. Please contact us for further details of applicable retention periods.
Data subject rights
Data subjects may have numerous rights in relation to their personal data.
- Right to make a subject access request (SAR): Data subjects may request in writing copies of their personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other individuals. Each request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and any payment permitted by law, where applicable.
- Right to rectification: Data subjects may request that we rectify any inaccurate or incomplete personal data.
- Right to withdraw consent: Data subjects may at any time withdraw their consent to the processing of their personal data carried out by us on the basis of their previous consent. Such withdrawal will not affect the lawfulness of processing based on such previous consent.
- Right to object to processing including automated processing and profiling: We do not make automated decisions about data subjects. We will comply with valid objection requests unless we have a compelling overriding legitimate ground for the continuation of our processing or we have another lawful reason to refuse such request. We will comply with each valid opt-out request in relation to marketing communications.
- Right to erasure: Data subjects may request that we erase their personal data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the personal data, such as, our business record retention obligations that we have to comply with.
- Restriction: Data subjects may request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.
- Right to data portability: In certain circumstances, data subjects may request the controller to provide a copy of their personal data in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We do not consider that this right applies to our Services. However, to the extent it does, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject's personal data which may still be retained for legitimate and lawful purposes.
- Right to lodge a complaint with the supervisory authority: We suggest that data subjects contact us about any questions or complaints in relation to how we process their personal data. However, each data subject has the right to contact the relevant supervisory authority directly.