Last Updated: May 31, 2024

Anunta Technology Management Service Limited (“We”, “Us”, “Our” and “Anunta”) operates the website ‘www.anuntatech.com’, https://*.anuntatech.com/, https://*.desktopready.com/ (“Platform”). At Anunta, We place the utmost importance on maintaining the confidentiality, integrity, and security of your (collectively, “You”, “Your”, “Yourself”, and “Users”) personal data and information that You share with Us while accessing Our Platform to avail Our services (“Service”).  Our comprehensive Privacy Policy reflects this commitment, which we encourage you to read fully.

This privacy policy (“Privacy Policy”) explains how information, including Personal Information (defined below), is collected, received, stored, processed, disclosed, transferred, dealt with, or otherwise handled by Us in connection with the Service or otherwise through Our Platform. This Privacy Policy is incorporated into and subject to our Terms of Use (“Terms”) and shall be read harmoniously and in conjunction with them. All capitalised terms used herein however not defined under this Privacy Policy shall have the meaning ascribed to them under the Terms.

Please read the Privacy Policy carefully before using or registering on the Platform, accessing any material or information, or availing of any Services through the Platform. This Privacy Policy (i) will be considered to be an electronic record under the Indian data privacy laws, including the Information Technology Act, 2000, read with rules and regulations made thereunder; (ii) will constitute a ‘Notice’ under the Digital Personal Data Protection Act, 2023 when applicable, read with rules and regulations made thereunder; and (iii) will not require any physical, electronic, or digital signature by the Company.

This Privacy Policy is governed by one fundamental principle – maintain Your trust and confidence when handling Your Personal Information.

(i) You will always be able to choose what Personal Information You provide to Us and how such information is used. We collect and process Your Personal Information to provide and improve Our Services. We will also offer You an explicit opt-out clause, and We will stop processing Your Personal Information. However, please note that We may only be able to provide You with Our Services if You provide Us with the requested information.
(ii) We will protect Your Personal Information by maintaining physical, electronic, and procedural safeguards as per Indian law.
(iii) We will train Our employees to handle Personal Information properly. When We use other companies to provide services for Us, We require them to protect the Personal Information We receive from You.
(iv) Our Privacy Policy describes how We handle Your information when You visit Our Platform and receive emails, SMSs, and WhatsApp Messages from Us.
(v) This Privacy Policy does not cover information You may provide to third-party websites We advertise on social media sites where We have a profile. Respective third parties will govern the privacy policies on those sites.

1. Personal Information Collected:

• Personal information is any information about an individual if such individual is identifiable: (i) by such information; or (ii) in relation to such information. We will collect the following personal information from You:
  a. Name, e-mail ID, phone number, address, zip code;
  b. Location details and Your device details such as device identifier, internet bandwidth, mobile device model, browser plug-ins, and cookies or similar technologies that may identify Your browser; and
  c. Your Short Messaging Service (SMS) messages stored on Your device.
  (“Personal Information”)

2. On what grounds do We process your Personal Information?

• Consent: In most cases, We will process Your Personal Information based on Your prior explicit consent, which You can withdraw at any time. Please refer to Section 4 below to understand the purposes for which We process Your Personal Information. You have the ability to reject consent to provide your Personal Information. However, certain Personal Information may be necessary to provide You with a Service and We may not be able to provide You with a Service or certain Platform features if the Personal Information requested is essential for the Service.
•  Notwithstanding anything contained herein, We may, in compliance with applicable laws in India, process Your Personal Information without obtaining Your consent in the event: (a) You voluntarily provide Your Personal Information to Us and do not indicate anything to show that You do not consent to the use of such Personal Information by Us. Specifically, this will involve situations when You fill out a form to (i) contact Us; and (ii) download a collateral. Further, if You voluntarily provide Us Your Personal Information for any of the purposes stated above, We shall not process Your Personal Information for any of the other purposes, unless You specifically voluntarily provide Us Your Personal Information for any and/or all of the other purposes; (b) the purpose of processing is for fulfilling any legal obligation to disclose any information to the State or any of its instrumentalities subject to such processing being in accordance with the provisions regarding disclosure of such information in any other law for the time being in force; (c) it is for employment purposes or for defending Ourselves from any loss or liability in the context of employment; (e) it is for compliance with any judgment, decree, or order issued under any Indian law or any judgment, decree, or order relating to civil contractual claims under any foreign law; (f) it is for responding to a medical emergency involving a threat to the life or immediate threat to Your health or of any other Users’ health; (g) it is for taking measures to provide medical treatment or health services to You or any other User during an epidemic, outbreak of disease or any other threat to public health; (h) it is for the purpose of taking measures to ensure safety of, or provide assistance or services to, any individual during any disaster, or any breakdown of public order and (i) it is in the interest of prevention, detection, investigation or prosecution of any offence or contravention of any law for the time being in force in India.

3. Information belonging to children and persons with disability.

Our Platform is not intended for children (i.e., persons below 18 years of age) or persons with disability. We neither collect Personal Information nor encourage children and/or disabled persons to create an account on Our Platform. We do not owe any responsibility to any such User, who is a child and/or disabled person, or towards his parents or lawful guardian, as applicable.

4. When do We collect Your Personal Information and how do We use the Information We collect?

We will only collect Your Personal Information on the grounds stated above in Section 2 and in accordance with applicable laws. We collect and use Your Personal Information by way of the following means:

• Directly from You, e.g., when You avail Our Services by visiting Our Platform, applying for a position in Our team, or by contacting Us to address a query. The Personal Information We receive from You in this instance involves name, gender, residential address, educational qualifications, email ID, phone number, country name, and date of birth.
  How do We use this Personal Information: (i) to provide and improve the Services and features on the Platform that You request; (ii) to resolve disputes and troubleshoot problems; (iii) to help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users; (iv) to customize Your experience on the Platform or share marketing material with You; (v) to detect, prevent and protect Us from any errors, fraud and other criminal or prohibited activity on the Platform; (vi) to enforce and inform about Our terms and conditions; (vii) to process and fulfil Your request for Services or respond to Your comments, and queries on the Platform; (viii) to contact You; (ix) to communicate important notices or changes in the Services, relevant for the use of the Platform; (x) in cases where We have a legal duty to use Your Personal Information for a particular reason; (xi) sharing and disclosure of data with partners and other third parties, as may be required for providing the Services; (xii) to alert You on new features or enhancements to our Services; (xiii) to communicate with You Our Services about which You have inquired; (xiv) to ensure that Our Platform and Services function in an effective manner for You; (xv) to investigate potential breaches, or to protect the rights, property or safety of the Platform and its users; (xvi) to fulfil Our contractual obligations towards You; (xvii) to enable You to participate in Anunta forums boards; (xviii) to facilitate Your registration on the ‘resource centre’ link in order to send You newsletters and other news alerts that You may have subscribed to; (xix) to consider You for employment with us and for conducting interviews; (xx) for any other purpose after obtaining Your consent at the time of collection.
  We use Your Personal Information to send You communications regarding the Services, as well as send You promotional emails, and transaction updates. However, We will allow You to opt out of receiving such emails from Us. If You opt out, We may still send You non-promotional emails, such as emails about the Services, and You can opt-out of such emails as well.
• Information received with Your permission, e.g., We collect, store, and monitor certain SMS information from Your device, location, and information of Your device. The Personal Information We receive with Your permission involves SMS information from Your device, device storage data, and location data.
  How We use this Personal Information: (i) We use SMS data to provide You with updates or confirmation of any actions taken on Our Platform during the term of Services; (ii) We collect and use Your location-based data for improving Services and providing more accurate Services to You.
•  Information We generate about You or collect about You, e.g., when You browse or use Our Platform, or information We generate about You. The Personal Information that We generate or collect here involves the IP address of the device You use to connect to the Internet, information such as what browser, browser version, operating system You have, the website You came from, or the advertisement You viewed or clicked on. When You browse the Platform, view Our emails/SMSs, use cookies and/or pixel tags to collect information and store online preferences. We may also supplement the information We collect with information from other companies and/or third parties by obtaining specific authorisations from You (if required under applicable law). For example, We may use marketing segments developed by Us or other companies to customize certain services.
  How We use this Personal Information: We use this information to help and analyse Our Platform flow, track user trends, and promote trust and safety. We retain such information as necessary to resolve disputes, provide customer support, and troubleshoot problems as law permits. We will use the cookies on Our website, similar to other landing websites or apps and online marketplace websites or apps, to do internal research on Our users’ demographics, interests, and behaviour to better understand, protect and serve Our users and improve Our services. This information is compiled and analysed on an aggregated basis. If You choose to decline cookies, the service might be affected in some parts of Our Platform. However, please note that We do not track the behaviour of users who are considered children/ minors per the laws of the relevant jurisdiction.

5. Blogs and Other Forums

• If You use a bulletin board, blog, or chat room on Anunta’s website, You should be aware that any information You submit, can be read, collected, or used by other users and could be used to send You unsolicited messages. Anunta will not be responsible for the Personal Information You choose to submit in these forums set out above. These forums may be hosted by Anunta or by one of Anunta’s third-party service providers on Anunta’s behalf.

6. Why and To Whom Do We Disclose Your Information?

• We do not sell or rent Your Personal Information to third parties for any purpose. We only share Personal Information when We have Your express consent, or as otherwise provided in this Privacy Policy.
• Disclosure to employees and third parties: We may disclose Your Personal Information, to employees, third-party contractors, vendors, or service providers who have been authorised by Us to undertake certain functions on Our behalf and who are also bound by the limitations associated with the use of Your Personal Information as indicated in this Privacy Policy. Such disclosures are only made if deemed necessary for providing the Service to You, such as sending e-mails on Our behalf or for hosting and operating a particular functionality of the Service. To this end, all the third parties and employees with whom We share Personal Information are monitored by Our IT department and the Information security team. They are subjected to strict disciplinary action, including termination, in the event of non-compliance to this Privacy Policy or any other policy or in case of any breach of their data protection obligations.Disclosure during change of control: Based on Your consent, We may share Your
• Information with Our parent, subsidiaries, and affiliates as a result of a sale, acquisition, merger, reorganization, or other change of control. We may also disclose and transfer all such information: (i) to a subsequent owner, co-owner, or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of Our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.
• Disclosures required by law: We may access, use, preserve, transfer, and disclose Your information (including Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in Our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Terms for any of Our Services or other policies applicable to any of Our Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, We may use IP addresses or other device identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers, and/or law enforcement agencies, including disclosing such information to third parties. Such disclosures may be carried out without notice to You.

7. Your Rights

We provide You with the following rights about Your Personal Information as per the applicable law. Your Rights include –

• Right to access information: You have the right to ask Us: (i) for a summary of Your Personal Information being processed by Us and the processing activities undertaken by Us with respect to such Personal Information; (ii) the identities of all other third-party entities with whom Your Personal Information has been shared by Us, along with a description of the Personal Information so shared. However, this right has certain limitations as prescribed under applicable law.
• Right to modify/rectify information: You have the right to correct or update any information, including Your Personal Information. In the event that You notice that any Personal Information already provided by You is inaccurate or incomplete or needs to be updated, You can ask Us to rectify such Personal Information (if the same cannot be done at Your end online) by contacting marketing@anuntatech.com. Further, if any Personal Information already provided by You is inaccurate, incomplete, or outdated, then You must give Us the accurate, complete, and up-to-date Personal Information by writing to Us at the email ID provided above, and We shall accordingly rectify such Personal Information at Our end immediately. We urge You to ensure that You always provide Us with accurate and correct information/data to ensure that Your use of Our Services is uninterrupted. In case of any such modification of Personal Information, You may be required to furnish supporting documents relating to the change in Personal Information for verification.
• Right to erasure: You have the right to request the deletion or removal of Your Personal Information where there is no compelling reason for Us to keep it. Such right of erasure can be exercised by writing to Us at marketing@anuntatech.com, which must be in a format prescribed by the government, when available. For now, You may write to us on the above email, to exercise this right. On such an erasure request, We shall delete all of Your Personal Information stored by Us. We shall also ensure that any third-party service provider processing Your Personal Information on Our behalf deletes all Your Personal Information, unless retention of the same is necessary for providing the Services or for compliance with any applicable law for the time being in force.
• Right with respect to consent: In certain instances, before collecting Your Personal Information, We take Your free, specific, informed, unconditional, unambiguous, and explicit consent. You can deny consent for the use of any particular information or revoke the consent already given. You shall have the following rights about Your Personal Information collected by Us:
  a. Deny Consent: You shall have the right to deny a request for consent for (i) collection and processing of specific Personal Information; (ii) disclosure of such Personal Information to any third parties; and (iii) retention of such Personal Information (except when the same is required to be retained under applicable laws). However, any such denial will not prejudice Our rights or the rights of Our partners to retain any Personal Information that You have provided in relation to the Services already availed by You through the Platform, or by any third-party service providers, per the provisions of this Privacy Policy. Further, in case of a denial of a request for consent, the Platform does not guarantee the continued facilitation of a Service.
  b. Withdraw Consent: You may also choose to withdraw Your consent (including consent provided for the processing of Your Personal Information by Us or by any third party on Our behalf) supplied to the Platform at any point in time. To withdraw Your consent for the use, processing, disclosure, sharing or transferring of any Personal Information, You may raise a request on the Platform or mail Us at marketing@anuntatech.com and/or alternatively, click on the “I would like to withdraw my consent” link provided to You in the email sent by Us. Please note You will not be able to withdraw consent to the collection of necessary cookies, which enables us to display our Platform on Your browser. Your withdrawal of the consent will not affect the lawfulness of processing of Personal Information based on Your consent before its withdrawal. In such an event, You are responsible for the consequences of such withdrawal of consent, and We do not provide a guarantee of Services if any such option to withdraw consent is exercised.
  If You do not provide Your consent or later withdraw Your consent, We reserve the right not to offer You a Service on the Platform. In such a scenario, We may delete Your Personal Information or other information We had earlier collected and stored, or de-identify it so that it is anonymous and not attributable to You.
  Upon receiving a request for deletion of Your Personal Information, or withdrawal of consent for the processing of Personal Information, We shall not retain Your Personal Information if we no longer need it, and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel, and We may still have to retain certain data and information at any time.
•  Right to restriction of processing of Personal Information: You shall have the right to ask Us to restrict the processing of Personal Information under following circumstances: (i) When You seek to rectify Your Personal Information which is inaccurate and for such period where We rectify and verify the accuracy of Your Personal Information; (ii) When the processing of Your Personal Information is unlawful, and You oppose erasure of Your Personal Information and request Us to restrict processing; (iii) When We no longer require to process Your Personal Information and retain Your Personal Information as per applicable law, but You also require Us to retain Your Personal Information for the establishment, exercise or defence of legal claims.; and (iv) When You have objected to the processing of Your Personal Information, for the duration the legitimacy of Your objection is pending.
• Right to data portability: You have the right to receive Your Personal Information which You have provided to Us, in a structured, commonly used and machine-readable format and have it transmitted to any other company without any hindrance from Us when (i) You provide Your Personal Information to Us with Your consent; and (ii) We process Your Personal Information through automated means.
• Right to object to automated decision making: You shall have the right to not be subject to a decision based solely on automated processing, including profiling, provided that such automated processing is undertaken by Us with Your specific consent.
• Right to nominate: You shall have the right to nominate any other individual, who shall, in the event of Your death or incapacity, exercise Your rights in relation to Your Personal Information, per applicable law in India.
• Right to non-discrimination: Your exercise of any of the rights stipulated in this section will not result in any discrimination against You in relation to the Services provided by Us to You.
• Use of consent Manager: You are permitted to give, manage, review, or withdraw Your consent provided to Us to process Your Personal Information through a ‘consent manager’. A consent manager is an entity that is registered with the Data Protection Board of India. The consent manager is accountable to You and can assist You in providing or withdrawing Your consent which You provided to Us to process Your Personal Information, on Your behalf. Such consent managers must comply with the obligations imposed on them as may be prescribed by the Central Government.
• Your privacy controls: You have certain choices regarding the Personal Information We collect and how it is used:
  a. Your device may have controls that determine what information We collect. For example, You can modify permissions on Your Android/iOS device or browser to remove any permissions that may have been given. However, We do not guarantee the continuation of some of Our Services or Platform features if any such controls are exercised.
  b. You can also request to delete or erase the Personal Information processed and stored with Us from Our servers, in the manner provided herein.

8. Your Duties

•  The applicable laws prescribe certain duties that You must adhere to. As part of Your duties, You need to ensure that You:
  a. Adhere to all the applicable laws for the time being in force while exercising Your rights;
  b. Do not impersonate any other person at the time of providing Your Personal Information;
  c. Do not suppress any material information while providing Your Personal Information for any document, unique identifier, proof of identity or proof of address issued by the State or any of its instrumentalities;
  d. Do not register false or frivolous grievances or complaints with Us or the Data Protection Board; and
  e. Furnish only verifiably authentic Information when exercising Your Right to erasure.

9. Security and Measures:

• We have reasonable security measures and safeguards in place to protect Your privacy and Personal Information from loss, misuse, unauthorized access, disclosure, destruction, and alteration of the information in compliance with applicable laws and we are compliant with standards set out in the International Organisation for Standardisation.
• As long as You access and/or use the Platform (directly or indirectly), it is Your obligation, at all times, to take adequate physical, managerial, and technical safeguards, at Your end, to preserve the integrity and security of Your data which shall include and not be limited to Your Personal Information.
• We or any of Our partners do not assume any liability or responsibility for disclosure of Your Personal Information due to errors in transmission, unauthorized third-party access, or other causes beyond Our reasonable control. You understand and acknowledge that We cannot ensure or warrant the security of any Personal Information You transmit to Us or guarantee that Your Personal Information may not be accessed, disclosed, altered, or destroyed by a breach of any of Our security measures and safeguards. In the event of any actual or suspected security incident, including data breach, We will take all measures required to be undertaken under applicable laws. You play an essential role in keeping Your Personal Information secure. You shall not share Your Personal Information or other security information of Your Account with anyone. We have undertaken reasonable measures to protect Your rights of privacy concerning Your usage of the Platform controlled by Us and Our Services. However, We shall not be liable for any unauthorized or unlawful disclosures of Your Personal Information made by any third parties who are not subject to Our control. In the event of any actual or suspected security incidents, including data breaches, We will take all measures required to be undertaken under applicable laws.

10. For how long do We retain Your Personal Information?

• We ensure that Your Personal Information, which is in Our possession or under Our control, is destroyed and/or anonymized as soon as per applicable law (if mandated) it is reasonable to assume that (i) the Purpose for which that Personal Information was collected is no longer being served by the retention of such Personal Information; and (ii) retention is no longer necessary for any other reason including the Applicable law.

11. Grievance redressal

• In case of any grievances, complaints or concerns with respect to Our Platform or Services, You can contact Our Grievance Redressal Officer at Email: grievance@anuntatech.com
• By lodging a complaint, You agree to provide complete support to the grievance redressal officer and such reasonable information as may be sought from You. We aim to resolve the complaints as soon as possible.
• The grievance redressal officer shall acknowledge Your grievances, or complaints or concerns with respect to Our Platform or the Services, within 96 hours of receipt of the same and shall endeavour to redress the same at the earliest.
• If You have exhausted Your opportunity of redressing Your grievances concerning Your Personal Information with Us and You are not satisfied with the resolution, You may raise Your concern to the Data Protection Board of India.
• While You have the right to raise complaints with both the Firm and the Data Protection Board of India, please note that, registering false or frivolous complaints with the Data Protection Board is a punishable offence.

12. Changes to the Privacy Policy

• We reserve the right to amend this Privacy Policy from time to time to ensure that this Privacy Policy is consistent with any developments to the Platform and Services, the way We use Your Personal Information and any changes to the applicable laws including applicable data protection laws. We will make the updated Privacy Policy available on the Platform. We will notify You of any changes to this Privacy Policy by way of an email. You will be required to provide Your consent and acceptance to the updated Privacy Policy before You can continue accessing the Platform and the Services after such change. We encourage You to visit the Platform from time to time to ensure that You are well informed about Our latest policies concerning personal data protection. All communications, transactions and dealings on the Platform shall be subject to the latest version of this Privacy Policy in force at the time.
• You may determine if any such revision has occurred by referring to the date on which this Privacy Policy was last updated.

13. Questions

• If You have any questions or concerns about this Privacy Policy or in relation to Our Platform, You may contact Us at marketing@anuntatech.com for clarifications.