Preface
At by Leap247 Finnovations Private Limited (Fego), we value your privacy and make all possible endeavours to protect the personal information that you may directly or indirectly share with Fego or information that we may collect during your interaction with the website www.fego.ai and the associated software products and services (collectively, the Platform). This privacy policy (Privacy Policy) explains the details of collection, processing, storage, and disclosure of your personal and sensitive personal information as collected and processed by Fego on or through the Platform.
Please read this privacy policy (Policy) carefully to understand our practices regarding your personal information. By accessing, or using the Platform, you grant your express consent to be governed by the terms of this Policy. For the purpose of this Privacy Policy, ‘access’ and ‘use’ will mean and include your directly or indirectly availing services from Fego and, or, your using the Platform. It is clarified that in the event of any contradiction between the Privacy Policy and any other agreements governing your access to Fego’s Platform and services the terms of such agreements will supersede this Privacy Policy.
Scope And Terms Of Privacy Policy
1. You hereby provide your free and informed consent to the collection, processing, storage, and disclosure of your personal and sensitive personal information by Fego as is set out in this Privacy Policy. By accessing the Platform, regardless of the device or internet enabled resource used by you to access the Platform (each a Device), you expressly consent to be bound by the terms of this Privacy Policy.
2. If you do not agree with the terms of this Privacy Policy, you must immediately cease your access to the Platform. Your continued access to the Platform indicates your acceptance of the terms set out in this Privacy Policy.
3. You agree and accept that this Privacy Policy is administered by Fego in compliance with the applicable Indian laws, and warrant that you are resident in India and subject only to the laws of India.
Information Collected By Fego
4. Pursuant to other agreements including inter alia a Master Service Agreement, service level agreements, and other terms and conditions executed by you with Fego in order to gain access to the Platform (each an Agreement), Fego will issue you with an account on the Platform with access to such functionalities as per the terms and conditions negotiated between you and Fego under the Agreement(s)] (collectively Your Account). Fego requires the following information to set up Your Account:
5. You will be required to register yourself with the Platform by creating an account to access the services offered by Fego (Your Account). You voluntarily submit the following information, including personal and sensitive personal information, to the Platform to set up Your Account and to gain access to the Platform:
a. The password for Your Account;
b. Your first name and last name and, or, the first name and last name of your company’s representative;
c. Designation of the company’s representative;
d. Company name;
e. Your official e-mail address and, or, the official e-mail address of the company’s representative; and
f. Your mobile number and, or, the mobile number of the company’s representative.
6. Should Your Account represent that you are a company and not an individual, the details of the authorised personnel must be provided as the nodal person through whose registration the company would access the Platform. The username and password created by such nodal person will belong to the company.
7. Fego automatically collects the following information when you access the Platform to efficiently provide our services and to ensure that your interactions with the Platform are smooth and uninterrupted:
a. Tracking Information including inter alia the IP address of your Device and Device ID when connected to the Internet, the URL that you accessed previous to the Platform (whether this URL is on the Platform or not), the URL you access after using the Platform (whether this URL is on the Platform or not), your device browser information, and other information associated with your interaction with the Platform and other unique identifiers such as browser type, browser version and network service provider details;
b. Information retrieved from Device access provided by you including location;
c. Information collected by cookies and other similar technologies, including advertisement data (see Cookie Policy below for details).
d. Your browsing behaviour on the Platform and the pages viewed etc.
Information You Submit To Fego
8. You represent and warrant that you will not directly or indirectly upload on the Platform or provide Fego with access to any personal data or sensitive personal data or identifiable information of any natural person including your clients and end-users, save and except to the limited extent sought by Fego for the creation of Your Account as set out hereinabove. Save and except the information set out at Paragraph 5 above, you agree and warrant that the personal information of any natural person will only be submitted on the Platform after anonymising or masking such information to ensure that it cannot be traced back to the provider of the information and is not capable of identifying a natural person either by itself, or in combination with other information made available to Fego.
9. You will not send or provide Fego with access to or upload on the Platform any personal data or sensitive personal data or identifiable information of any natural person, unless such data is anonymized or masked such that it cannot be traced back to a natural person.
10. You will always remain responsible for any data and the content of any database that you make available on the Platform, and the selection and implementation of procedures and controls regarding access, security, encryption, use, and transmission of the personal data or sensitive personal data or identifiable information of any natural person and the backup and recovery of any database and any stored data further to your use of the Platform.
11. To the extent that you accidentally or voluntarily submit the personal and sensitive personal information of your end-clients or any third-parties to the Platform in the course of availing Fego’s services, you warrant that such end-client or third-party information has been lawfully collected by you with informed consent of the information provider and the information provider has agreed for you to share all such information with Fego, under similar or better terms as set out in this Privacy Policy. Fego assumes no responsibility for ensuring that the end-client or third-party information that you submit to the Platform has been obtained in compliance with applicable laws, and you will be solely responsible for ensuring the legality of such end-client or third-party information before sharing it with the Platform.
Cookie Policy
12. Cookies are small data files containing information which are automatically stored on your Device when you visit the Platform. Fego uses cookies to personalize the services for you including inter alia identifying the Platform pages which you visit the most, and to accordingly tailor and optimize the browsing experience for you.
13. Fego inter alia collects the following types of cookies when you access the Platform through a Device:
a. Strictly necessary cookies which are essential for functional running of the Platform;
b. Performance cookies which monitor the Platform’s performance to provide you with a tailored experience and optimise the browser experience for you; and
c. Functionality cookies which Fego utilises to remember your choices and preferences (such as your username, e-mail address etc.).
14. You can control Fego’s use of cookies through your browser settings and may refuse to accept cookies. Please note that unless you have adjusted your browser setting to refuse cookies, Fego will collect cookies when you access the Platform.
15. You may, at any time, disable cookies on your browser by visiting the settings and blocking cookies or by clearing your cache regularly. However, disabling or blocking cookies will inter alia: (i) limit your browsing experience on the Platform; (ii) limit the Platform’s functionality, for instance, the ability to auto-suggest the text to be filled into certain fields based on your past inputs and remembering your preferences; and (iii) may affect your ability to access certain functions and features of the Platform.
Why Fego Collects Information
16. Fego will only collect your information for lawful purposes and where the collection of your information is necessary in order to provide you with Fego’s services and, or, is considered necessary for achieving a seamless, efficient and safe experience on the Platform, which is customized to your needs including:
a. To create and validate Your Account on the Platform;
b. To provide you with the Agreement(s) you are required to execute to access Fego’s services;
c. To provide you access to Fego’s services;
d. To Maintain internal records;
e. To keep constant checks for any unauthorized activity on Your Account;
f. To manage the web system and troubleshoot problems;
g. To cater personalized content/ads according to your preferences and interests;
h. To communicate with you about the products and services you are currently using, updates regarding your customer support requests, new products you may like, feedback questions and surveys, and policy updates.
i. To send you information pertaining to Fego’s services and with respect to your access to Fego’s services through e-mail, courier, SMS and any other lawful means;
j. To send you non-transactional messages and e-mails carrying inter alia promotional materials and marketing surveys;
k. To provide you with suggestions for services and products best suited for your needs;
l. To provide you with customer support and resolve related issue and to process grievances raised by you against Fego, any other user of the Platform, and, or, any other third party;
m. To enforce the Terms and Conditions for the use of and access to the Fego’s Platform accessible athttps://www.fego.ai/legal/terms-of-service;
n. To the extent necessary to ensure compliance with applicable laws; and
o. For any other purpose as Fego may deem fit and necessary in respect of the services offered to you, subject to applicable law for the time being in force.
collectively, the Purpose.
Disclosure Of Your Information
17. Fego will disclose the personal information you submit to us solely for the purpose of perfoming the Agreement(s) executed between you and Fego and for fulfilling the Purpose and for other actions related to the Purpose, as outlined below:
a. For providing information to Fego’s key shareholders, board, investors (debt or equity);
b. For the purpose of processing of your personal information by third-parties who work on behalf of Fego to provide you with services;
c. For external data analysis in an anonymised form;
d. As mandated by the law and, or, a regulator such as to comply with a judicial order, an executive order, requirement by a law enforcement authority or by any other legal process;
e. When Fego believes, in good faith, that such disclosure is necessary to protect our rights, protect your safety or the safety of others and, or, such disclosure is necessary to investigate fraud or crime;
f. To enforce the Terms of Service for the use of and access to the Platform offered by Fego accessible at https://www.fego.ai/legal/terms-of-service;
g. If Fego (or any of our affiliates) are involved in a merger, acquisition, or sale of all or substantially all of our assets or equity;
h. To deliver marketing, products and services communication that Fego believes may be of interest to you; and
i. To any other relevant third-party, where the disclosure of your personal and sensitive personal information is necessary for the performance of a lawful contract between you and Fego.
18. Please note that certain third-party service providers whose services are also offered on the Platform may disclose your personal information in accordance with their own privacy policies. Fego does not assume any responsibility for the actions of such third-parties with whom you may choose to share your personal information.
19. Fego may provide access of your data to analytics companies in order to understand how the Platform is accessed and can be improved upon. Fego may link the information it stores within the analytics software to any personal and sensitive personal information you submit within the Platform.
Your Rights
20. You have the following rights in relation to your personal and sensitive personal information that is available with Fego:
a. The right to access (and obtain a copy of, if required) the categories of personal information that Fego holds about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared;
b. The right to withdraw your consent to Fego’s continued processing of your personal information, at any point of time, subject only to any legitimate reason that Fego may have for continued processing of your personal information in certain circumstances;
c. The right to request that Fego delete your personal information in certain circumstances, such as when it is no longer necessary for the Purpose for which it was originally collected;
d. The right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by your continued use of the Platform;
e. The right to correct and update the information Fego holds about you or to rectify any inaccuracies. Based on the Purpose for which Fego uses your information, you can instruct us to add supplemental information about you in our database; and
f. The right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
21. The submission of your information to the Platform and your acceptance of this Privacy Policy will have an overriding effect on any registration of your mobile number with the National Do Not Call Registry of the Telecom Regulatory Authority of India and any other Do Not Call Registry operated by any other service provider.
22. You can unsubscribe or opt-out from receiving non-transactional e-mail communications from Fego at any time by clicking the ‘Unsubscribe’ option available at the bottom of each such e-mail communication.
Security Of Information
23. Fego understands that we must safeguard your personal information and therefore, employs all reasonable technical, organisational, logical and physical security practices and procedures to protect your personal information against any unauthorised access, damage, modification, disclosure, impairment and, or, misuse.
24. Fego maintains its commitment to data security by employing various international standards for data encryption and security. Fego’s servers are protected behind firewalls and our systems are monitored to prevent any unauthorised access. Fego ensures that the security measures are in compliance with the applicable regulatory requirements and industry standards.
Storage Of Information And Data Retention Policy
25. Fego will retain your information for as long as necessary to continue providing you with access to the Platform. Thereafter, Fego may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes, if any, and enforce agreements.
26. You agree that subject to compliance with Indian law, all information processed by Fego may be transferred, processed, and stored anywhere in the world, including but not limited to, India or other countries, which may have data protection laws that are different from the laws where you live.
27. Retention periods for records of your personal data are based on the type of record, the nature of the activity and the product and service to which it is associated or linked. The periods for retention of your personal information by Fego may vary depending on specific legal, business, and statutory requirements.
Changes To Our Privacy Policy
28. Fego may update this Privacy Policy from time to time, and if we make any material changes, we will notify you by means of a notice on the Platform. We encourage you to check our Privacy Policy regularly to ensure you have read the latest version.
Grievance Redressal
29. Please feel free to contact our Data Protection Officer Raguraman Srinivasan at legalsupport@fego.ai with any questions regarding the Privacy Policy, or security of your personal information, or if you have any concerns, requests, or comments.
This Privacy Policy was last updated on January 6, 2023 at 11:30 hours.
