This Policy of “MCSSAN ITECH COMPANY LLP”, explains how we may Process your information. This Policy may be amended or updated from time to time.
What Categories of Information We May Process
SUMMARY – CATEGORIES OF INFORMATION WE MAY PROCESS
We may Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.
We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We may Process the following categories of Personal Information about you:
• Personal details: your name; username or login details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
• Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
• Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
• Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
• Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
• Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
• Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.
We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
• Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
• Browsing history including the websites or other services you visited before and after interacting with the Services.
• Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
• Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
• Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.
• Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID).
• Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
• Internet connection means, such as internet service provider (“ISP”), mobile operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”).
• Device type, settings and software used.
• Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
• Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
• Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
• Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
• Mobile analytics to understand the functionality of our mobile applications and software on your phone.
SUMMARY – SENSITIVE PERSONAL INFORMATION
We do not seek to collect or otherwise Process your Sensitive Personal Information. Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with Indian applicable law. The Services are not intended for use by children.
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under Indian law,s (collectively, “Sensitive Personal Information”) in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under Indian Law’s, we would rely on one of the following legal bases:
• Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law.
• Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud).
• Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights.
• Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.
Children. The Services are not intended for use by children, especially those under 13 years. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.
SUMMARY – COLLECTION AND CREATION OF INFORMATION
We may collect or obtain User Information about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make your Personal Information public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Services; when you visit our Services; when you register to use any part of the Services; or when you interact with any third party content or advertising on the Services. We may also receive User Information about you from third parties (e.g., social network sites). We may also create User Information about you, such as records of your interactions with us. MCSSAN ITECH COMPANY LLP is not responsible for Personal Information you volunteer about yourself in public areas of the Services. This Policy does not cover the practices of third parties who may provide information about you to MCSSAN ITECH COMPANY LLP.
Collection of User Information: We may collect User Information about you from the following sources:
• Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, bulletins, webinars or white papers; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
• Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
• Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
• Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
• Speedtestforyou, by MCSSAN ITECH COMPANY LLP: When conducting a test through Speedtestforyou on any device or platform, we collect: (a) the test results; (b) non-precise information about the approximate physical location of your computer or device-derived from GeoIP Data and/or Precise Location Data (if your mobile device settings allow it); and (c) Other Information, including, but not limited to, the IP address, the ISP, college or organization that operates the network you test, and network, hardware and device identifiers such as your SSID or IMEI (if the test is conducted on a smartphone). If you install Speedtestforyou on your smartphone or other mobile device, MCSSAN ITECH COMPANY LLP may collect your Precise Location Data, both while you are running a test and when the application is not actively in use but is running in the background on your device. If you install the Speedtestforyou extension on your web browser, in addition to allowing you to run a test of your internet speed, the extension uses our Web Speed feature, which measures the load time for a particular website and allows you to measure how long it takes for a particular website to load. Through the Web Speed feature, we collect page load metrics for the websites you visit, including page URLs, load times, and GeoIP Data. Web Speed does analyze your IP address when you run a test to ascertain the approximate location of your device, but the IP addresses analyzed by Web Speed are not retained by MCSSAN ITECH COMPANY LLP and are deleted automatically after the test is completed. Note, however, that we also combine this information with recent Speedtestforyou information collected from the same device.
• Content and advertising information: If you choose to interact with any third party content or advertising on the Services or Channels, we may receive User Information about you from the relevant third party.
• Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.
Creation of User Information. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.
SUMMARY – PURPOSES FOR WHICH WE MAY PROCESS YOUR INFORMATION
We may Process User Information for the following purposes: providing the Services to you; communicating with you; providing advertising to you on the Services and Channels; analyzing engagement with our audience; observing user engagement and purchase activity across the Service and Channels; offering business-to-business lead generation services; offering Speedtestforyou by MCSSAN ITECH COMPANY LLP and Sensorly to test your internet connectivity offering Downdetector to inform you about outages of third-party services; marketing our services and offerings to current and prospective customers; managing our IT systems; financial management; conducting surveys; ensuring the security of our systems; conducting investigations where necessary; compliance with applicable law; and improving our Services.
The purposes for which we may Process User Information, subject to applicable law, include:
• Provision of the Services to You: providing the Services to you from MCSSAN ITECH COMPANY LLP or its partners including (i) offering of contests, as well as chat areas, forums and communities, (ii) posting of your personal testimonial alongside other endorsements, (iii) display of your personal reviews of products or services, (iv) allowing you to search for other website members using information you may already know about that member such as username, full name or gamer profile and identify users matching that criteria, (v) management of your account, and (vi) customer support and relationship management.
• Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
• Surveys: engaging with you for the purposes of obtaining your views on our Services.
• Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 6 below.
• Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties. For further information, please see Section 7 below.
• Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.
• User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
• Commerce Offerings: using cookies to track your browsing history and the amount of money spent at a particular third party merchant’s site to offer coupons and other offers that are relevant to your shopping experience; offering of coupons via SMS messages if a mobile phone number is provided.
• Lead Generation: business-to-business lead generation in the provision of leads to customers to improve customer’s target marketing campaigns and services through different strategies. This includes generating leads through phone calls and email newsletter marketing to drive you to content, such as white papers and webinars, offered by MCSSAN ITECH COMPANY LLP, whereupon your contact information will be shared with our customer.
• Speedtestforyou Offerings: Speedtestforyou by MCSSAN ITECH COMPANY LLP and Sensorly are offered on multiple devices, products and platforms, such as an extension on your web browser or as applications in certain products such as routers. They enables you to test the speed, latency and other primary network characteristics of your TCP/IP network connections and be provided with the results. Your Speedtest or Sensorly results may be used by MCSSAN ITECH COMPANY LLP to conduct analyses and prepare product enhancements, as well as to prepare market reports. MCSSAN ITECH COMPANY LLP licenses the Speedtest and Sensorly results to its business customers. MCSSAN ITECH COMPANY LLP also licenses the Speedtest and Sensorly applications to business customers who wish to have their end users test their own networks’ internet connectivity or, in the case of Speedtestforyou, to test an end user’s connection(s) between a product and the MCSSAN ITECH COMPANY LLP network of servers.
• Marketing to Customers: We may market to current and prospective customers and their employees who have indicated an interest in doing business with, or have previously conducted business with, MCSSAN ITECH COMPANY LLP in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of advertising, Speedtest/Sensorly and Online Data licensing, lead generation and other business services offered by MCSSAN ITECH COMPANY LLP.
• IT Administration: administration of MCSSAN ITECH COMPANY LLP’s information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
• Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
• Financial Management: general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements.
• Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
• Legal Proceedings: establishing, exercising and defending legal rights.
Subject to applicable Information Technology Act (2000) (“IT Act”) of India.
SUMMARY – DIRECT MARKETING
We may Process your User Information to contact you with information regarding services that may be of interest to you. You may unsubscribe for free or opt out of SMS messages at any time.We may Process your User Information to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.
SUMMARY – LAWFUL BASIS FOR PROCESSING USER INFORMATION
We may Process your User Information where: you have given your consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.
In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
• Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us.
• Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law.
• Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual.
• Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purposes of managing, operating, improving or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
As described above, we have identified legitimate interest as the basis for processing in connection with the Speedtestforyou and Sensorly offerings by MCSSAN ITECH COMPANY LLP and how we market our business to our current and prospective customers.
For Speedtest and Sensorly, MCSSAN ITECH COMPANY LLP has a legitimate interest in sharing your Speedtest results with internet providers, hardware manufacturers and industry regulators to help them understand and create a better and faster internet.
SUMMARY – DISCLOSURE OF USER INFORMATION TO THIRD PARTIES
We may disclose your User Information to: legal and regulatory authorities; our external advisors; parties who Process User Information on our behalf (“Processors”); any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on the Services.
We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.
• outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality.
• third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Section 9.
• any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights.
• any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security.
• any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
• any relevant third party provider, where our Services use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
For some of our Services, we may make some information, such as the name of our users, their mailing address, phone number, email address—and in certain circumstances their employer’s name, company size and other industry data—available on a rental or other basis (e.g., sale) to third party providers of goods and services, for example, when such information is provided in connection with webcasts, white papers or other sponsored downloads.
When you use a co-branded service (a service operated with a partner of MCSSAN ITECH COMPANY LLP), or register or otherwise provide information on a co-branded site, you grant us permission to pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services;
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where MCSSAN ITECH COMPANY LLP advises users of the possibility of such disclosure at the time they take the survey, MCSSAN ITECH COMPANY LLP reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.
MCSSAN ITECH COMPANY LLP and some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Services. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.
We may also sell or transfer Online Data to certain third parties such as advertisers who will use this data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture.
We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.
We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from MCSSAN ITECH COMPANY LLP with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.
Information collected through Speedtestforyou and Sensorly may not be anonymous as follows: for some ISPs and mobile carriers, MCSSAN ITECH COMPANY LLP will provide full IP addresses and/or network, hardware or device identifiers for such ISP or mobile carrier’s customers upon request. MCSSAN ITECH COMPANY LLP may also provide full IP addresses and/or network, hardware and device identifiers, to equipment manufacturers and core network, or wholesale providers on a case-by-case basis for network research purposes. MCSSAN ITECH COMPANY LLP may also collect GeoIP Data and/or Precise Location Data, and such data may also be licensed and/or transferred to third parties.
If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
SUMMARY – DATA SECURITY
We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
SUMMARY – DATA ACCURACY
We take every reasonable step to ensure that your User Information is kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.
SUMMARY – DATA MINIMIZATION
We take every reasonable step to limit the volume of your User Information that we Process to what is necessary.We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.
SUMMARY – DATA RETENTION
We take every reasonable step to ensure that your User Information is only retained for as long as they are needed. Online Data related to OBA is kept by MCSSAN ITECH COMPANY LLP for not more than 180 days after which it will expire, subject to certain conditions.
We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need. MCSSAN ITECH COMPANY LLP retains historical Speedtestforyou and Sensorly data in connection with the following purposes identified in Section 5 above: conducting analysis and preparing product enhancements, preparing market reports, and licensing the Speedtestforyou and Sensorly results and to its business customers. MCSSAN ITECH COMPANY LLP may also retain historical Speedtestforyou and Sensorly data for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.
SUMMARY – CONTACT DETAILS
You may contact us at the addresses set out below or by emailing firstname.lastname@example.org