PRIVACY POLICY

WHO WE ARE.

This is the privacy policy (“Privacy Policy”) of deKoder, a division of iKroya.com LLP (referred to as “deKoder”, “We”, “Us” or “Our”), and applies to information that deKoder collects through those deKoder Services (including through its Website and App) which make this Privacy Policy available.

In this Privacy Policy, wherever the context so requires, “You”, “Your” or “Yourself” shall mean any natural or legal person who visits Our Website/App and/or uses any other Services offered by deKoder and/or has signed up for a newsletter and/or expressed an interest in deKoder in any manner.

Some of Our Services have their own policies, which will be relevant to You when You are using those Services.

We want to ensure that in using any of deKoder’s Services, You understand the terms of this Privacy Policy, including any subsequent changes made to the Privacy Policy as described below, and are aware of the privacy choices available to You.

Find out more about how We manage Your Information (defined hereunder) below.

WHAT THIS PRIVACY POLICY TELLS YOU.

This Privacy Policy explains the types of information We may collect, how We may use and disclose the information once it is collected, and, where applicable, how You can stop Us from collecting, using, disclosing or continuing to hold Your information.

This Privacy Policy forms part and parcel of the Terms of Use for the Services. Terms of use Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in Our Terms of Use.

Our values guide everything that We do – including how We use Your Information. We are strongly committed to keeping Your Information safe. This commitment exists throughout the lifecycle of Your Information, from the design of any deKoder Service which uses Information to the deletion of that Information.

This Privacy Policy does not apply to any third-party websites, content, data, information, applications, goods, services or materials (“Third Party Services”), even if a link to such Third-Party Services (including social media services) becomes available to the User while using Our Services and accessing Content made available by deKoder. The information that You share with Third Party Services will be governed by the specific privacy policies and terms of service of the Third Party Services and not by this Privacy Policy. By providing these links, We do not imply that We either control or endorse or have reviewed these Third Party Services. Please contact the Third Party Services directly for information on their privacy practices and policies.

If You object to the practices described in this Privacy Policy, You should (a) remove cookies from Your computer/mobile device after leaving Our Website, App and/or any other deKoder Services; and (b) discontinue Your use of Our Website, App and/or any other deKoder Services.

ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY BY YOU.

This Privacy Policy is to be read and understood along with the cookie policy (“Cookie Policy”), terms of use (“Terms of Use”), disclaimer (“Disclaimer”) and other deKoder policies (collectively referred to as ‘deKoder Policies’) Policy & disclaimer which are applicable to You when You visit, access, browse and/or use Our Services. By using Our Services, You confirm that you have read this Privacy Policy and expressly, freely and unambiguously consent to Our collection, use, processing, disclosure, and retention of Your Information as described in this Privacy Policy.

We encourage You to retain and review this Privacy Policy to stay informed about Our information practices and the ways You can help protect Your privacy.

HOW WE RECEIVE COLLECT AND STORE YOUR INFORMATION.

We collect and process some or all of the following types of information in the course of You using Our Services. The types of information We collect will depend on the circumstances and the Service You are using. Generally speaking, the information about the User as collected by deKoder is: (a) data supplied by Users; (b) data automatically tracked while navigation; and (c) data collected from any other source (collectively referred to as “Information”).

Information Supplied by Users.

Registration Data.

This Information includes, but is not limited to, basic contact information provided by You on Our Website/App/Service, which may include Your name, mobile number, address, e-mail address, date of birth, demographic information, gender, interests, preferences, place of work, position, country. It can also include information that We have not requested but which You have volunteered, such as information provided during interactions via comments or other submissions You have made while using Our Services, such as online forums, in response to a survey, while requesting certain Services, or to enter a contest/competition or other promotion.

In case You choose to decline submission of personal Information on the Website/App/Service, We may not be able to provide certain Content/Services/ features to You. We will make reasonable efforts to notify You of the same at the time of registering Your account. In any case, We will not be liable or responsible for the denial of certain Services to You owing to You not providing the requisite personal Information to Us.

Payment Data (if applicable).

This Information can include Your name, Your billing address, Your telephone number, Your email address, Your credit or debit card information and any other relevant information. This Information is collected to enable Us to process Your payments and use Your payment information, if You consent to and subscribe to any portion of our paid Services (as and when applicable).

Information about other individuals.

In some circumstances, You might provide Us with Information about other individuals, in which case You must ensure that You (1) have their permission to provide their Information to Us; and (2) You have made them aware of the terms of this Privacy Policy. By submitting the Information about others, You represent and warrant that You are authorized to do so and that You have received authorization from the person about whom You are providing the Information and that person has explicitly consented to have their Information used, processed, disclosed, and transferred in accordance with this Privacy Policy.

Information automatically tracked while navigation.

When You use Our Services, We automatically record Information about Your usage of those Services, Your interaction with Our emails as well as information about the device You are using and Your internet connection. We do this in the following ways:

Use of Cookies and other Electronic Tools.

deKoder and the parties with whom We work (e.g., business partners, advertisers and advertising servers) may place, view, and/or use cookies, web server logs, web beacons, or mapping pixel/pixel tag or other electronic tools to collect statistical and other Information about Your use of the Website/App/Service and other websites. This Information may include information about the IP address of Your computer, browser type, language, operating system, Your mobile device, geo-location data, the state or country from which You access deKoder’s Website/App/Service/Content, the date and the time of a visit, the websites You visited immediately before and after visiting Our Website, the number of links You click within the Website/App/Service, the functions You use on the Website/App/Service/Content, the databases You view and the searches You request on the Website/App/Service/Content, the data You save on or download from the Website/App/Service/Content and the number of times You view an advertisement.

Log File Information.

We automatically collect limited information about Your computer’s connection to the internet, mobile number, etc., when You visit the Website / App. We automatically receive and log information from Your browser, including Your computer’s name, Your operating system, browser type and version, IP address, CPU speed, and connection speed. We may also collect log information from Your device, including Your location, IP address, Your device’s name, device’s serial number or unique identification number (e.g. UDiD on Your iOS device). If You access the Services and/or Content from a mobile or other device, We may collect a unique device identifier assigned to that device, geo-location data, or other transactional information for that device.

Clear GIFs.

Besides web beacons, We may also use clear GIFs in HTML-based emails sent to Our Users to track which emails are opened by recipients. We use this information, inter-alia, to measure traffic within the Website / App/Service/Content to improve the Website/App/ Service/Content quality, functionality and interactivity and let advertisers know the geographic locations from where Our visitors come.

Information collected from any other source.

We may receive Information about You from other sources, add it to Our account information and treat it in accordance with this Privacy Policy. If You provide Information to the platform provider or other partner, Your account information and order information may be passed on to Us. We may obtain updated contact information from third parties in order to correct Our records and fulfill the Services or to communicate with You and You expressly consent to this.

Information from other Sources: Demographic Information
We may reference other sources of demographic and other information in order to provide You with more targeted communications and promotions. We use analytical tools to track User behaviour on Our Website/App/Service/Content. These tools have been enabled to support display advertising towards helping Us gain understanding of Our Users’ demographics and interests. The reports are anonymous and cannot be associated with any individual personally identifiable Information that You may have shared with Us.

Advertisements.

deKoder or third-party advertisers or their advertising servers may also place or recognize unique cookies on Your computer or use other electronic tools in order to help display advertisements that You see on the Website or on other websites. Information about Your visits to, and activity on, the Website/App/Service/Content and other websites, an IP address, the number of times You have viewed an advertisement, and other such usage information is used, alone or in combination with other information, to display on Your device screen advertisements that may be of particular interest to You. We may use web beacons, provided by third-party advertising companies, to help manage and optimize Our online advertising and product performance. The use and collection of Your Information by these third-party service providers, and third-party advertisers and their advertising servers is not covered by this Privacy Policy.

CHILDREN’S PERSONAL DATA.

We do not aim any of Our Services directly at children under the age of 18 and We do not knowingly collect personal data about children under 18 in providing Our Services.

If You have reason to believe that a child under the age of 18 has provided personal data to deKoder through the use of its Services, please email Us at [email protected]. We will investigate any notification and if appropriate, delete the Information from Our systems. If You are under 18, You must have consent from Your parent or guardian to use Our Services and/or Content.

SENSITIVE PERSONAL INFORMATION.

Unless specifically requested, We urge You to not send and/or disclose, on or through the Services or otherwise to Us, any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, national identification numbers, social security numbers, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).

HOW WE USE YOUR INFORMATION.

We use Information collected through Our Website, App and other Services We offer only when We have a valid reason and the legal grounds to do so. We determine the legal grounds based on the purposes for which We have collected Your Information.

Legal grounds for using Your Information.

The legal ground may be one of the following:

Consent. Often, We will use Your Information because We have asked for Your consent, which You can withdraw at any time. Please refer to the table below for examples of where We ask for Your consent.

Performance of a contract with You (or in order to take steps prior to entering into a contract with You). We will use Your Information in order to perform a contract with You. For example, where You have subscribed to receive Our newsletters , We will need to use Your contact details to deliver Your subscription or We may contact You directly via social media or email if You enter competitions/contests, bids or respond to call-outs.

Compliance with law: In some cases, We may have a legal obligation to use or keep Your Information.

Our legitimate interests. We may process Your Information where it is necessary for Our legitimate interests in a way that might be expected as part of running deKoder and in a way which does not impact Your rights and freedoms. For example, it is in Our legitimate interests for Us to understand the Users of Our Services, promote Our Services & Content, and operate Our Website and App (including provision of Services) efficiently for the creation, publication and distribution of Content online, globally, so as to empower Our Users with reliable data. Please refer to the table below for examples of when We rely on Our legitimate interests to use Your Information.

Remember, We might use more than one lawful Purpose for handling Your Personal Information, depending on why We are using it. If You want to know details of the same, please reach out to Us at [email protected].

Purpose	Lawful Basis	Our Legitimate Interest (if applicable)
To place non-essential cookies, or other similar technologies.	Consent	N/A
To personalise the advertising that You see through non-essential cookies.	Consent	N/A
To use Your Information to personalise advertising.	Consent	N/A
To process Your payments (if applicable).	Consent or Legitimate Interest	We may collect and use Your payment information to process Your payments (if applicable). This can include Your name, Your billing address, Your contact number, Your email address, Your credit or debit card information and any other relevant information.
To send marketing communications to You.	Consent or Legitimate Interest.	We send marketing communications to You if You have (i) signed up for those communications; or signed up for a newsletter; or if You have made a purchase or registered and have not opted out of Our marketing. You can opt out of these communications at any time by clicking on the “unsubscribe” link at the bottom of the email or by following the instructions in the message. You can also opt out and select communication preferences (such as email, SMS, mail) when signed into Your deKoder account.
To analyse what Content has been viewed while availing Our Services (including deKoder’s Website and App).	Legitimate Interest	To understand how Our Content has been viewed and improve Our Content.
To monitor the number of articles that Our Users read.	Legitimate Interest.	To provide deKoder Users with the option to access more customised Content through Our Services.
When We embed Content on Our Website/App or while offering any other Services (if applicable).	Legitimate Interest	To understand how Users interact with Our Content, for example, whether Users watch the full video or only a proportion of it. This will involve using cookies as described in Our Cookie Policy and sharing information with YouTube/any other relevant platform from which Content is embedded on Our Services.
To compare the Information We hold about Our Users with third parties, using a service provider’s secure tool. This Information is not shared with third parties and is not used to directly target individuals. We use this analysis to create “segments” of particular types of audiences.	Legitimate Interest.	To analyse and understand Our Users better, so that We can make Our marketing and advertising more relevant to the “segments” that You may be in. You can opt out from having Your Information used for marketing analysis when signed into Your deKoder account.
To use the abovementioned “segments” to create “custom audiences”.	Legitimate Interest.	To identify Our audience across third party websites. This is normally achieved by using cookies as described in Our Cookie Policy. You can manage the use of cookies when signed into Your deKoder account.
To improve and manage Our Website, App and/or any other Services & Content offered by deKoder, using Your IP address.	Legitimate Interest.	To understand how You use Our Services and improve Our Content.
To provide the Content, including marketing and contextual advertising, for Your geographical location, using Your IP address.	Legitimate Interest.	To provide deKoder Users with the option to access customised Content on deKoder.
To remember Your settings, and recognise You when You sign in to access Our Services in different ways, such as by Our App and on Our Website.	Legitimate Interest.	To personalise Our Services (for example, by welcoming You back when You sign in).
To test changes to Our Website/App and/or any other Services, We may vary the Information that is collected and how it is used.	Legitimate Interest.	To see the impact on Users and how Users interact with different options on Our Website/App and/or any other Services and Content.
To backup Our systems and databases.	Legitimate Interest.	For recovery purposes in the event of any issue with Our systems.
To provide, improve and develop new features vis-à-vis the AI-powered features available as a part of Our Service offerings.	Legitimate Interest.	To improve the efficiency and accuracy of Our AI-powered features for Our Users (including keeping the said AI powered features updated and relevant), We use the Information collected through Your use of the said feature(s)/ AI Curations .
For security and fraud prevention.	Legitimate Interest.	For security and fraud prevention, and to ensure that Our Services, including Website and App, are safe and secure (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and used in line with Our Terms Of Use. To prevent fraud, criminal activity, or misuse of Our Services, and to protect the security of Our IT systems, architecture, and networks.
Others.	Legitimate Interest.	For internal administrative purposes related to Our services - such as Our accounting and records. To inform You of any changes to Our services, such as updates to deKoder Policies. To enable You to share Our Content with others using social media or email. To respond to Your queries and resolve Your complaints. To contact You directly via social media or email if You send Us emails or engage with deKoder on social media or contact Us. We may collect Your Information for any competitions/contests or call-outs (including surveys) that You participate in or respond to. Any other legitimate use/ground for which deKoder may collect Information of Users, per applicable laws.

deKoder seeks to provide insights and understanding of election dynamics to empower individuals and organizations with reliable data. Data protection law includes certain exemptions when personal data is processed for the aforesaid purposes. Those exemptions apply to some of the ways deKoder uses Information and accordingly, this Privacy Policy does not cover personal data that deKoder processes for research, archiving or statistical purposes.

WHO DO WE SHARE YOUR INFORMATION WITH

a) Within Our group companies.

Depending on where You live, We may share Your Information within the Our group companies. We may share it in order to perform a contract with You, for administrative purposes, or when We have a legitimate interest in doing so.

b) With external organisations.

We share Your Information with other organisations that are not directly linked to Us under the following circumstances:

Service providers.

We may share Your Information with other organisations that provide services on Our behalf. We may do this to perform a contract We have entered into with You, where it is in Our legitimate interests or with Your consent.

Advertising partners.

We may also share the Information collected through Your use of Our Services with our Advertising partners, as set out in Our Cookie Policy. These partners help Us deliver relevant advertising across Our Service offerings.

Agencies and authorities if required by law.

We may reveal Your Information to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if We are required to do so as to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect Our rights or the rights of anyone else (for example, in response to a valid and properly served legal process such as a warrant). If We have Your contact details, We will take reasonable steps to attempt to notify You prior to disclosing Your Information unless (i) prohibited by applicable law from doing so, or (ii) there are clear indications of unlawful conduct in connection with Your use of Our Services.

Contests/ Competitions.

We may share Your Information with sponsors and partners for the purposes of selecting and notifying winners when You participate in any of Our contests/competitions. We may also share Your Information with entities offering any prize You have won in order for that entity to contact You about such a prize.

Social media platforms.

We may share Your Information with other organisations such as social media platforms, when Our Website/App uses social plug-ins from social media (such as liking or sharing on social media). The said platforms may receive and use Information about Your visit and use of Our Services (including Our Website and App). For more information on how social media platforms use Information, please read their privacy policies.

Organisation/s that buy any of Our group companies.

We may share Your Information to any other organisation that buys, or to which We transfer all or substantially all of Our assets and business. If this sale or transfer takes place, We will use reasonable efforts to try to make sure that the organisation to which We transfer Your Information, uses it in line with Our Privacy Policy.

When We share Your Information, as specified above, with any organisation which accesses Your Information in the course of providing services on Our behalf, they will be governed by contractual restrictions to make sure that they protect Your Information and comply with applicable laws. We may also independently audit these service providers to make sure that they meet Our standards.

HOW DO WE SECURE YOUR INFORMATION.

We have implemented appropriate technical and organisational controls to protect Your Information against unauthorized processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when We ask You to set up a password to access parts of Our Website, App or other deKoder Services. You should keep this password confidential and You should choose a password that You do not use on any other site. You should not share Your password with anyone else, including anyone who works for Us. We cannot guarantee the security of any Information sent to Us while accessing Our Services while still in transit and so You provide it at Your own risk. If You feel Your Information has been compromised in any way, please contact Us immediately at help@deKoder.com.

NOTIFICATION TO YOU IN CASE OF A DATA BREACH.

In the event of a data breach that may compromise Your Information, deKoder is committed to taking prompt and transparent action. We understand the importance of protecting Your privacy and will take all necessary steps to mitigate the effects of such breaches.

If We become aware of a data breach that may affect Your Information, We will notify You within a reasonable time period of Our discovery of the breach. We will use the contact information You have provided to Us, such as Your email address, if available, or by other means, if possible. We may also provide information on steps You can take to protect Yourself from potential harm resulting from the breach.

Additionally, in compliance with applicable data protection laws and regulations, We will promptly notify the relevant data protection authorities of any data breach that may pose a risk to Your Information, in accordance with Our legal obligations.

Please note that while We take every reasonable precaution to protect Your Information, no method of transmission over the internet or electronic storage is completely secure. Therefore, We cannot guarantee absolute security, but We are committed to promptly addressing and mitigating any breaches to the best of Our ability.

Your continued use of Our Services constitutes acceptance of this data breach notification provision as outlined in Our Privacy Policy.

If You have any questions or concerns regarding Our data breach notification process, please contact Us at help@deKoder.com .

Please note that deKoder reserves the right to modify this clause as necessary to comply with changes in applicable data protection laws or regulations. Any such modifications will be communicated to You through Our Website/App or other appropriate means.

DATA RETENTION.

We will only retain Your Information for as long as reasonably necessary to fulfill the Purpose for which We collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

The criteria used to determine our retention periods include:

a) The length of time We have an ongoing relationship with You and provide the Services to You (for example, for as long as You keep using the Services);

b) Whether there is a legal obligation to which We are subject (for example, certain laws require Us to keep records of Your transactions for a certain period of time before We can delete them);

c) Whether retention is advisable considering Our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

Once the retention period expires, Your Information will be securely deleted or anonymized in a manner that prevents identification, unless otherwise required by applicable laws.

YOUR RIGHTS.

You have a number of important rights at Your disposal. In summary, those include rights to:

a) Access and get Your Information updated by Us. When You use Our Services (including its Website and App), We make good faith efforts to provide You, as and when requested by You, with access to Your Information. Further, if there is any change in Your Information, You may update it by accessing the relevant page of the Website/App/Service, or by contacting Us. If You have any questions about how We use the Information collected which relates to You, please contact Us at help@deKoder.com. We will endeavour to update Your Information within a reasonable time period of any new or updated Information being provided to Us, in order to ensure that the Information We hold about You is as accurate and up to date as possible;

b) Require Us to correct any mistakes in Your Information. In such cases, We shall ensure that any Information/data found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such Information to be retained by law or for legitimate business purposes;

c) Require the erasure of Your Information in certain situations.

d) Require Us to restrict processing or object at any time to processing of Your Information in certain situations.

e) Receive the Information concerning You which You have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit the same to a third party in certain situations.

f) Object to decisions being taken by automated means which produce legal effects concerning You or similarly significantly affect You.

g) Object in certain other situations to Our continued processing of Your personal Information.

h) Right to nominate: You have the right to nominate a person to act on Your behalf in case of Your death or incapacity. To nominate such a person, please contact Us at help@deKoder.com .

i) Otherwise restrict Our processing of Your personal Information in certain circumstances.

We ask individual Users to identify themselves and the Information requested to be accessed, corrected or removed before processing such requests or inform other limitations You would like to put on Our use of Your personal Information. If You would like to exercise any of those rights, please:

email Us at help@deKoder.com and provide Us enough information to identify You (e.g. user name, registration details);

let Us know the Information to which Your request relates.

We may need to verify Your identity before fulfilling Your request. We will try to comply with Your request as soon as reasonably practicable.

Please note that We often need to retain certain data for record keeping purposes and/or to complete any transactions that You began prior to requesting a change or deletion (elaborated under this Privacy Policy). Further, because of the way We maintain certain Services, after You delete Your Information, residual copies may take a period of time before they are deleted from Our active servers and may remain in Our backup systems. In addition, there may be certain Information/data that We may not allow You to review for legal, security or other reasons.

CHANGES TO THIS PRIVACY POLICY.

If We decide to change Our Privacy Policy to incorporate necessary changes in technology, applicable law or any other variant from time to time, the updated Privacy Policy will be posted on this page. Such changes will be effective upon posting. If the changes are significant, We may choose to email all Our registered Users with the new details. If required by law, We will get Your permission or give You the opportunity to opt out of any use of Your Information. In any case, You are advised to review this Privacy Policy periodically to ensure that You are aware of the latest version.

CONTACT US/GRIEVANCE REDRESSAL.

If You have any questions about how We use Your Information or if You have a concern about how Your Information is used, you may also contact our Consent Manager at consentmanager@deKoder.com.

Further, if You notice that any output of Our AI-powered features contains factually inaccurate information about You and You would like Us to correct the inaccuracy, You may submit a correction request to help@deKoder.com. Given the technical complexity of how Our AI-powered features work, We may not be able to correct the inaccuracy in every instance. In that case, You may request that We remove Your Personal Information from the output of Our AI-powered features by filling in the form or any other document that deKoder may request You to provide upon receipt of such a request.

Complaints will be dealt with by deKoder’s data protection team and will be responded to by the Grievance Officer within a reasonable time-period. The contact details of the Grievance Officer are provided below:

Name: Mr. T.D. Jayaprasad

Designation: Grievance Officer

Email: grievanceofficer@deKoder.com

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