1. DATA WE MAY COLLECT
We may collect and process the following data about you:
- Personal data including, for example, your name, e-mail address, password, age, gender, state, city and in certain instances data about your usage of the Apps, data you provide in connection with your usage of the Apps, and data collected by tracking technologies as further described in clause 4 below that may identify you as an individual or allow online contact with you as an individual.
- Data collected via tracking technologies, as fully described in clause 5.
2. USES MADE OF THE DATA
We use information held about you in the following ways:
- To provide you with the Apps.
- To answer your questions or requests for information or handle your complaints.
- To ensure that content provided by the Apps is presented in the most effective manner for you and for your computer or other device.
- To provide you with promotional communications, such as email, to the extent that you have provided consent and/or consistent with notice and any opt-out rights to receive such communications under applicable law.
- To carry out our obligations arising from any agreements entered into between you and us.
- To allow you to participate in interactive features of the Apps, when you choose to do so.
- To notify you about updates or changes to App features and content.
- To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as state and city).
- To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent and/or consistent with notice and any opt-out rights for such uses under applicable law.
- To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law.
3. CONFIDENTIALITY AND SECURITY
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at firstname.lastname@example.org. Except as described under the “Disclosure of Your Data” clause below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law. Saksham maintains technical, administrative and physical safeguards to the best of its ability to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, misuse or disclosure. Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties.
4. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
If you sign up to receive promotional materials from us via email and/or push notifications we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at
email@example.com, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level. If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply. We will endeavour to comply with these requests as soon as reasonably practicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional email messages from us that are required to provide you with our Apps.
5. TRACKING TECHNOLOGIES
Saksham and our analytics partners may use technologies such as cookies, beacons, tags, and scripts, etc to enable a service to recognize your device so you don’t have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don’t need to do it for every web page requested, and to measure how people are using the Apps.
We use local storage, such as HTML5, to store content data and preferences. Third parties with whom we partner to provide certain features on the Apps also use HTML5 to collect and store data. Various browsers may offer their own management tools for removing HTML5.
We partner with third parties, such as Facebook and Google, to manage our advertising of the Apps on other sites or platforms as well as across your other devices based on your past visits to our Website. Our third party partners may use technologies such as cookies to gather data about your activities within the Apps to deliver such advertising to you, such as retargeting ads. We do not respond to do-not-track signals. For more data about interest-based ads, including how to opt-out of having your web-browsing data used for behavioural advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third party platforms. You may also opt out of receiving ads across devices by adjusting your ad preference in your Google account.
We use third party trackers to let us know when users have visited the Apps by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Apps use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Apps and the volumes of usage of the Apps. This is done to ensure that the Apps are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.
We will acquire consent from you in order to use such trackers or provide you with the opportunity to opt-out of such trackers, to the extent required by applicable law.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Apps, the events that occur within the Apps, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
As true of most websites, we gather certain data automatically and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
6. WHERE WE STORE YOUR PERSONAL DATA
All data you provide to us through the Apps is stored on our secure servers located in India. Any data transmission will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.
Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Apps; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
7. YOUR DATA RIGHTS
As you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users exercise those rights. As required under applicable law, the rights afforded to you are: A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof.
A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Saksham will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Saksham may have legal or legitimate grounds for keeping such data.
A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
A right to data portability: you have the right to receive the personal data concerning you which you have provided to Saksham, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Saksham. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Saksham. Saksham may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your Saksham account and following the instructions here.
A right to lodge a complaint with the competent supervisory authority: you have the right to lodge a complaint with the supervisory authority about Saksham’s personal data protection practices provided that before approaching the supervisory authority, a grievance has been raised with Saksham and the same has not been resolved to your satisfaction within a reasonable timeframe.
A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Saksham instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email firstname.lastname@example.org. You may access your personal data to modify or update at any time via an online account, or by emailing email@example.com. We will respond to your request in a reasonable timeframe in accordance with applicable law.
8. LEGAL BASES OF PERSONAL DATA PROCESSING
In accordance with GDPR, Saksham provides the following information regarding its clause 8 legal bases for personal data processing: The performance of the contract (the Saksham Terms & Conditions) between you and Saksham for the data processing relating to your use of Saksham’s Apps;
Saksham’s legitimate interest, more specifically:
- Our business interest in providing you with emails and push notifications for timely introductory materials and information about your Saksham account, and our Product features and updates.
- Our business interest in collecting data regarding your general usage activities for the purpose of improving our Saksham user experience.
- Our business interest in collecting data related to unplanned downtime or errors in the Apps.
9. DISCLOSURE OF YOUR DATA
We may disclose your personal data to third parties as follows:
- In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfil a request for data from such party. An example of this is the SMS Service such as for Mobile Device / SIM verification at the time of account creation.
- In some limited circumstances, our email service provider may receive certain information you share in-app to provide you with personalized email communications.
- If Saksham’s service providers (like hosting, IT maintenance, market analytics) require this data to provide services to Saksham.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Saksham or substantially all of our assets are acquired by a third party, in which case personal data held by us about our users will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a summons , bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of Saksham, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- With third parties, such as Facebook, in order to serve Saksham advertisements on such third party platforms, to the extent that you have consented to or have been provided with notice of, and an opportunity to opt-out of, such practices under applicable law.
10. DATA RETENTION
The retention periods applied by Saksham comply with applicable legislation in effect on the date hereof, namely:
- For data relating to your account: such data will be permanently and irrevocably anonymized in the event that your account is: (i) inactive for a period of two (2) years; Moreover, we will permanently and irrevocably anonymize your account data within thirty (30) days of your written request to do so via email to
- For data collected based on your consent to receive our marketing communications: we will use such data until you opt out, withdraw consent or applicable law requires that such data is no longer used.
- When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.
- When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.
11. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing
12. USE OF SAKSHAM BY MINORS
You must be at least 18 years of age to sign up as a registered user of the Apps. Saksham shall not be liable for prosecution under any law in the event it is found that a user has registered by providing incorrect age. Saksham reserves its right to take all appropriate action in such a scenario.