1. BACKGROUND

1.1 Vahan Technologies India Pvt. Ltd., a private limited company incorporated in Delhi, India (“Vahan”, "us", "we", or "our") provides recruitment services through the Whatsapp Messenger Application (the "Messenger"). The services provided by us through the Messenger shall be known as the “Services”. Any reference to “you” or the “User” shall mean you, the user of the Services. Vahan and you shall collectively be known as the “Parties” for the purposes of these Terms of Use.

1.2 Your privacy is very important to us. We respect your privacy and believe that we should clearly and transparently disclose our privacy practices to you. This privacy policy (the “Privacy Policy”) explains our policies regarding collection, use, and disclosure of your personal information, personally identifiable information, and other data collected from you when you avail the Services offered by Vahan. This Privacy Policy does not apply to any third-party websites or applications. Please note that you shall visit any third-party sites and apps at your own risk upon conditions laid down in such third-party sites’ or apps’ respective terms of use and privacy policies.

1.3 We may change, modify, amend, terminate or replace this Privacy Policy at any time at our discretion. If we change, modify, amend or terminate this Privacy Policy, such modifications will become effective immediately upon posting it here. You agree to periodically review the current version of the Privacy Policy, as posted here. If you do not agree with the terms of this Privacy Policy, please do not use the Services offered by Vahan.

1.4 We will not use or share your information with anyone except as described in this Privacy Policy or as required to sufficiently carry out the offered Services. We use your information to operate and improve the Services. By availing the Services and interacting with Vahan over Messenger, you agree to the collection and use of information in accordance with this Privacy Policy.

1.5 This Privacy Policy is to be read with, and is an integral part of, our Terms of Use available at https://vahan.co/terms-of-use (“Terms of Use”). Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use.

2. COLLECTION OF INFORMATION

2.1. While your availment of our Services and interaction with us, we collect certain personally identifiable information (“PII”) that can be used to contact or identify you. PII includes, but is not limited to, your phone number and other information that by itself or in conjunction with other information, can be used to specifically identify you. However, PII does not include aggregated information that, by itself, does not permit identification.

2.2. Information that we collect when you avail the Services offered by us includes:
(i) Information provided by you
We may require you to provide us with certain information such as your name, email address, and mobile number, postal address, email address, identity proof, address proof, driving license and other information etc. Further, if you communicate with us via the Messenger, our website, or through email, we may collect any information provided in such communication.
(ii) Log Data
We collect information that your browser or device sends us whenever you avail our Services ("Log Data"). This Log Data includes information such as your Internet Protocol ("IP") address, geolocation and geospatial data, browser details, domain servers, device ID& model number, details of your operating system, and other related information. We also collect data on the time and date of your engagement with our Services, the time spent on your engagement with our Services, default language and user preferences, and other similar usage related statistics. We may assign each user of the Services unique identifiers to help keep track of future engagement.
(iii) Cookies
When you avail our Services, we may be able to access information via cookies. Cookies are files with small amounts of data which are transferred to your browser or device that allow our systems to recognise your browser or device and capture certain information. For example, we may use cookies to compile data about our operations, display relevant advertisements to you or to understand your preferences based on your previous activity to optimise your user experience. The cookies we send to your browser or device may also include anonymous unique identifiers, which we may use to collect data about your device, to create and store a unique identity of you for the purposes of fraud prevention, security, or authentication.
Most browsers and devices are by default set up to accept cookies. You may reset your settings to refuse all cookies or to indicate when a cookie is being sent. However, it is likely that some of the features of our Services may not function properly if cookies are disabled on your browser or device.
Please note that clicking on any links to third-party services may result in cookies being transmitted to your browser or device. In such events, you understand that except for cookies transmitted to you by intermediaries authorised by us for that purpose, this Privacy Policy does not cover the transmission and use of cookies by any third-parties. We bear no responsibility for the data collected by such third parties and encourage you to review and understand the relevant privacy policies of such third-parties before utilising their services.
(iv) Information received from others
We may combine information about you that we already have with information we obtain from other sources, to provide you a better user experience, to show you advertisements relevant to you, or to optimise the Services offered by us. Examples of information we may receive from other sources includes without any limitation, identification information, date of birth, educational background, customer support or enrolment information, page view, search term and search result information, and credit or identity information.

2.3. Apart from the information listed above, we do not collect any sensitive information such as political opinions, health-related information or any information related to race, caste or religion (collectively, “Sensitive Personal Information”), unless provided by you voluntarily or required by provisions of any applicable law.

3. USE OF INFORMATION

3.1. We use your PII and other information collected from you for the following purposes:
(i) To provide you with the functionalities of our Services in a proper manner;
(ii) To track your usage of our Services customise them accordingly to best suit your requirements;
(iii) To send you communications, as per your notification settings, on any updates or developments pertaining to our Services or your engagement with us over Messenger;
(iv) To provide you with support services, whether through email, phone, push notifications or messages through the Messenger;
(v) To provide you with technical support, including updating Services;
(vi) To improve the quality, features and functionality of our Services, including by seeking performance reviews or feedbacks pursuant to the recruitment opportunities provided through the Services;
(vii) For the purposes of auditing, research and analysis to ensure the stability of our Services;
(viii) To improve the security of the Services provided by us;
(ix) To carry out marketing analysis to understand the features of the Services that may be optimised;
(x) To back up our systems to ensure preparedness for disaster recovery;
(xi) To protect our rights and property and the rights and property of our other users;
(xii) To offer customized ad experience by us or google ads;
(xiii) To combine your PII or other information with information obtained from other sources, and publish summaries online or offline;
(xiv) To provide information to third-parties performing services in support of our Services;
(xv) To communicate promotions and other offers, and for the purposes of advertisements;
(xvi) In pursuance of the terms and conditions of any arrangement or transaction with any third party, that we are currently engaged in or might potentially engage with in the future including without limitation, for the transfer of your PII and other information in lieu of consideration;
(xvii) To prevent and detect any fraud or other illegal activity carried on or through our Services, and to prevent violations of our Terms of Use;
(xviii) To respond to legal requirements, exercise our legal rights and defend against any legal claims, to protect our interests or those of any third parties; and
(xix) As may otherwise be necessary to enforce the terms of this Privacy Policy and the Terms of Use.

4. STORAGE OF INFORMATION

4.1. Your PII or other information collected from you may be stored and processed on computer systems located outside India, and through your use of the Services you unequivocally consent to the processing and storage of your information outside of your own jurisdiction. You understand and agree that we may continue to store your information after you cease to use the Services or disable your use of the Services.

4.2. We store some of your information on your browser or device for subsequent retrieval and utilisation. Such information stored on your personal device is subject to the security offered by your device, browser, and other components. You understand and agree that we cannot be held responsible for any compromise of access to your personal browser or device, for loss of information, theft or for any exploits or logic attacks on your browser or device through malware or other software or hardware that is outside the control of Vahan and the scope of Services offered by us.

4.3. Although the security of your PII and other information is important to us, do remember that no method of electronic storage or method of transmission is 100% secure. While we strive to use commercially acceptable and standard means to protect your information, including internal reviews of our data collection, storage and processing practices and security measures, we cannot guarantee absolute security in this regard. You provide your PII and other information to us at your own risk.

5. DISCLOSURE AND SHARING OF INFORMATION

5.1. We may employ third parties to facilitate the functioning of the Services, to provide the Services’ functionalities on our behalf, to help us analyse how the Service is being used, to serve advertisements to our users, or to perform other related activities pertaining to our operations. We may share your information with third-parties in the following circumstances:
(i) We have obtained your consent, including when you choose to provide us your information for any purpose whatsoever;
(ii) For the purposes of carrying out the Services offered by Vahan, including but not limited to matching Users with employment opportunities offered by third parties;
(iii) If sharing or disclosure of your PII or other information is necessary to operate the Services;
(iv) For the purposes of displaying advertisements;
(v) If we have been purchased by a third-party;
(vi) If sharing or disclosure of your PII or other information is necessary to be shared with our associate entities, including any related companies, successors, assigns, licensees, affiliates or business partners. We require that these entities process your PII or other information as per our instructions and in compliance with the conditions of this Privacy Policy and other appropriate confidentiality and security measures;
(vii) If your PII or other information is demanded by a court order or by governmental or statutory authorities;
(viii) If sharing or disclosure of your PII or other information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty;
(ix) If sharing or disclosure of your PII or other information is needed to protect our employees, independent contractors, officers, members or other users; and
(x) If otherwise permitted to do so by this Privacy Policy or by applicable law.

5.2. Unless otherwise required by law or necessary to carry out the Services as offered, when any PII or other information pertaining to the Service users is shared with third-parties such as recruiters, company’s offering employment opportunities, advertisers, licensees and content distributors, we ensure that such information is non-private, aggregated or anonymised so that it will not identify you personally. You understand that we may further distribute your information to a wider audience through third-party sites and services, if such distribution is consistent with this clause and the contents of this Privacy Policy.

5.3. We may share your PII or other information with our parents, subsidiaries, divisions, and affiliates or as part of any sale, merger or acquisition.

5.4. We will never sell your PII or other information to unaffiliated third-parties without your approval.

6. INFORMATION RETENTION

6.1. Upon you ceasing the use of our Services, we shall archive your PII. We will retain archived information indefinitely in our secure database for the purposes of our records. Non-personally identifiable information is retained indefinitely for analytics. However, any Sensitive Personal Information collected by us, if any, shall be destroyed upon such cease of use.

6.2. We collect and retain certain information that is required for our detection, investigation and prevention of fraud, cheating and other violations of our Terms of Use and applicable laws ("Breach(es)"). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on such Breaches and stored only for the minimum amount of time needed for the purpose of dealing with such Breaches. If the data indicates that such a Breach has occurred, we will further store the data for the establishment, exercise or defence of legal claims, until a legal case related to it has been resolved, or such legal claim no longer exists due to the expiry of relevant limitation periods. Please note that the specific data stored for dealing with Breaches may not be disclosed to you if such disclosure will compromise our legal rights as well as the mechanism through which we detect, investigate and prevent such Breaches.

7. GOVERNING LAW

7.1 This Privacy Policy shall be governed by and constructed in accordance with the laws of India, without reference to conflict of laws principles. The courts in Delhi shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, this Privacy Policy. You agree to waive any and all objections to the exercise of jurisdiction by such courts and to venue in such courts.

8. CONTACT US

If you have any questions about this Privacy Policy or have any grievances, please contact our Grievance officer, as provided below:
Name: Madhav Krishna
Email: info@vahan.co