Privacy Policy
Last Updated: July 8, 2024
Last Updated on July 8th, 2024 THIS PRIVACY POLICY ("PRIVACY POLICY") SETS FORTH THE MANNER OF COLLECTION, USE AND DISCLOSURE OF INFORMATION GATHERED ON THE WEB PORTAL . PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO USE THE SERVICES, OR ACCESSING THE WEB PORTAL YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE SAME, YOU MUST NOT ACCESS OR USE THE WEB PORTAL OR AVAIL ANY OF THE SERVICES. ACCESS AND USE OF THE WEB PORTAL ARE SUBJECT TO THE TERMS AND CONDITIONS ("TERMS") ACCESSIBLE ON THE WEB PORTAL. UNHU Technologies Private Limited , a private limited company with its registered office on the Ground Floor, Building E -304, Phase VIII- A, Industrial Focal Point, Chandigarh Sector 71, Rupnagar, S.A.S. Nagar (Mohali), Punjab, India, 160071 (hereinafter shall be referred to as “Company”, “UNHU”, “We”, “ Us”, “ Our” and terms of similar meanings) owns and operates a web-based benefits management portal ("Web Portal"). This Privacy Policy does not apply to the websites of Our business partners, corporate affiliates, or any other third parties, even if their websites are linked to the Web Portal. We recommend You review the respective privacy statements of the other parties with whom You interact. By accessing the Web Portal or otherwise using the Web Portal, You (hereinafter referred to as “You”, “Your”, “User”, “Guest/s” as applicable) expressly consent to Our collection, storage, use and disclosure of the Information ( as defined hereunder ) in accordance with the terms of this Privacy Policy. The Company, through the Web Portal provides a range of functionalities facilitating the management of Workers/Employees and other UNHU platform users. These services include but are not limited to, streamlined worker onboarding, onboarding service providers, initiating access to relevant benefit schemes, seamless communication through content dissemination and notifications, networking and engagement features, a rewards mechanism to incentivize desired actions of workers, and a comprehensive dashboard for tracking worker engagement and interests with data -driven insights (“Services”). As We update, improve and expand the Web Portal , this Privacy Policy may change at Our sole discretion without notice, so please refer to it periodically as You will be deemed to be governed by the terms of such modified Privacy Policy, as it comes into effect from time to time. By using Our Web Portal, You are deemed to have read, acknowledged and accepted all the provisions stated in this Privacy Policy, including any changes that We may make from time to time. Please note: all information in this privacy notice applies to You unless otherwise indicated. In this Privacy Policy the term ‘ Personal Data’ shall mean any data about an individual/ organization/ company who is identifiable by or in relation to such data. We encourage You to carefully peruse this Privacy Policy in conjunction with any supplementary and more detailed information that may be presented to You on various occasions when We gather or handle Personal Data on the Web Portal . This will ensure that You are cognizant of the methods and objectives underlying the processing of Your Personal Data. The terms capitalized and used herein but not defined shall have the meaning as ascribed to them in the Terms of Web Portal.
1. TYPE OF INFORMATION COLLECTED
a. When creating an account on the Web Portal, the Users are required to provide certain personal,
non-personal and other information, as indicated below (such information and correspondences hereinafter collectively referred to as “Information”):
- User Information. When you register on our Web Portal, we may collect personal information
such as your name, email address, phone number, and organization details. The organization details may include details regarding the workers or employees of the User, their personal and employment details and other necessary information required for performing the Services.
- Usage Data. We may collect information about how you interact with our Portal Services,
including your activity, preferences, awarding and utilization of rewards, and engagement with benefit schemes.
- Networking Information. The Web Portal allows you to create and share various forms of
content, including photos, training videos, audio, and texts. Any information or content you voluntarily choose to provide while using the Web Portal will be collected by the Company.
- Non-Personal Information. We collect non -personal information during Web Portal visits,
including domain, host, IP address, operating system, browser type, and internet service provider. This information is not personally identifiable.
- Permitted Information. Where you opt to provide any device permissions such as contact list,
photos, camera, location, microphone, SMS, storage, and phone calls, the Company may retrieve, retain and use the data sourced through such device permissions.
- Automatic Information. For enhanced Web Portal responsiveness, we utilize cookies and
electronic tools to gather data on individual interests. This includes server logs with details like web requests, IP addresses, browser type, language, date, time, and unique browser identifiers primarily for user authentication.
- Mobile. When accessing the Web Portal via mobile, we may obtain location and device
information, using it to provide service-related suggestions if needed.
- User Communications. Emails and other communications sent to us are retained to process
inquiries, respond to requests, and enhance services.
- Additional Information. Logs, location details, survey responses, and optional details such as
social background and affirmative action eligibility are also collected, along with information exchanged between U sers and the company, as well as data shared through linked social media accounts. Please note:
- The provided list is illustrative, not exhaustive.
- Publicly available information is not considered sensitive.
- We do not ensure the accuracy or moderation of such content but reserve the right to
remove offensive, discriminatory, or inappropriate material at our discretion.
b. We collect only the Information that We believe to be relevant and is required to provide effective
Services that You voluntarily elect to provide Us. You may, at any instance, choose not to provide Us with the Information. However, in such a case We may not be able to offer You (partially or entirely, as the case may be) the Services provided by Us. Additionally, We collect Your Information in order to record, support and facilitate the provision of Services to You, including, via third parties whom You agree to engage with Us through the use of the Web Portal, to assist You with insurance services, customer services, technical support issues, to follow up with You, to otherwise support Your relationship with Us and/or to prevent fraud and unlawful activities.
c. In case You choose to decline to submit any Information, We may not be able to provide You access
to the Web Portal or certain aspects of the Web Portal. We will not be liable and/or responsible for the denial of access to the Web Portal to You on account of the inadequacy of Information provided by You.
d. When You register with the Web Portal, We may contact You from time to time about updates of
Information to provide You such features that We believe may benefit/interest You.
2. USE OF INFORMATION
a. The collected information may be utilized, stored, and processed by Us to deliver, personalize,
measure, and enhance our products and Services and to establish and sustain a secure and trusted environment on the Web Portal, including compliance with our legal obligations and adherence to our policies.
b. You provide Us consent that we may process, share, or otherwise transfer your Personal Data with
Partners and other third parties for the purposes specified in this Privacy Policy , Terms and applicable laws. This includes trusted third parties who assist Us in operating Our Web Portal , conducting Our business, or servicing You. We may also release Your information when We believe release is appropriate to comply with the law, enforce Our Web Portal policies, or protect Ours’ or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
c. We reserve the right to use Your and/or your organisation’s name and non-personally identifiable
information for advertising purposes to attract more corporations, employers, and organizations using your brand name. This activity does not constitute a breach or violation of our policies, as it serves to enhance the visibility and reputation of our services within relevant industries.
d. We may process the Information You provide in the following manner:
- (i) Facilitating your access to various features within the Web Portal.
- (ii) Personalizing Your experience, enhancing Web Portal features, and improving user-
friendliness.
- (iii) Aggregating and anonymizing the gathered information to create statistical or analytical
insights tailored to the requirements of the User.
- (iv) Complying with our Privacy Policy and applicable laws in information processing.
- (v) Utilizing market research for product/service refinement and marketing purposes.
- (vi) Addressing criminal activities, fraud, and breaches of the Company's Terms.
- (vii) Analyzing information to suggest relevant products/services and improve Web Portal
functionality.
- (viii) Contacting you, customizing communication, and using provided email for updates and
information.
- (ix) Preventing fraud, and illegal activities, and protecting Web Portal security and integrity.
- (x) Allowing customized messages from professionals, and partners, and publishing user -
provided testimonials or reviews.
- (xi) Complying with legal obligations, and government authorities, resolving disputes, and
troubleshooting.
3. SHARING OF INFORMATION
a. To ensure the efficient operation of the Web Portal and delivery of Services through the Web
Portal, We may share your Personal Data and Information with Partners, administrators, vendors, agents, service providers, or affiliates in accordance with relevant laws.
b. We may avail third-party services to carry out tasks on Our behalf, such as hosting, data analytics,
and customer support. These service providers will only have access to Y our information as required to fulfil their duties and are bound to uphold the confidentiality of the information.
c. We partner with organizations or authorities pertinent to the various sectors to offer enhanced
services or enhance the Web Portal 's features. In these instances, your Personal Data may be shared with these entities solely for collaborative purposes.
d. If you engage with the networking features within the Web Portal, such as sharing multimedia
content and connecting with workers or employees, we may utilize the information generated through these interactions to enhance Your social networking experience within the Web Portal. Additionally, certain information related to Your activity within the Web Portal may be used for analytics purposes to improve the overall functionality and User experience of the networking feature.
e. In cases of business disposition, such as mergers , sales or business acquisitions, we may transfer
the collected information to the relevant third party.
f. The Company declares that it will not engage in any unauthorized use of Your Personal Data.
g. Access to Your Personal Data is restricted to employees requiring it for job responsibilities.
Disclosure circumstances include sharing with affiliates for internal business, and with third parties for legal, regulatory, or judicial requirements. In situations like mergers, acquisitions, or collaborations with third -party service providers and marketing partners, we ensure their obligation to safeguard Your Personal Data and comply with confidentiality commitments. Transfer of Personal Data beyond India's border adheres to pertinent data protection laws.
4. DATA RETENTION
a. Your information will only be retained by U s for the length of time necessary to fulfil Our legal
requirements or to fulfil O ur obligations to You. When there are legal reasons to maintain the information, like an ongoing contractual relationship or accounting needs, or when there is a legal storage need, like bookkeeping regulations, we are unable to delete Your information.
b. We retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it
was obtained and consistent with the applicable laws. The criteria for determining the duration for which We will keep Your Personal Data are as follows: (i) We will retain copies of Your Personal Data in a form that permits identification only for as long as it is necessary in connection with the purposes set out in this Privacy Policy, including for the length of time We have an ongoing relationship with You and provide the Web Portal to You; (ii) if there is a legal obligation to which We are subject to (for example, certain laws require Us to keep records of Your transactions for a certain period of time before We can delete them); or (iii) keeping in view the legitimate interests of the Company (litigation or regulatory investigations).
5. DATA SECURITY
a. We use reasonable security measures to protect Information from unauthorized access, maintain
data accuracy and help ensure the appropriate use/disclosure of Information. We host the Web Portal in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders.
b. We have implemented meticulous technical, organizational, and security protocols to avert the
inadvertent loss, misuse, or unauthorized access, alteration, or disclosure of Your Personal Data. Furthermore, access to Your Personal Data is restricted to individuals such as employees, agents, contractors, legal counsels and selected third parties, only when essential for legitimate business purposes and on a need- to-know basis. These authorized entities will exclusively process Your Personal Data based on Our explicit instructions and are strictly bound by rules of confidentiality.
c. Additionally, We have established comprehensive procedures to address any suspected data
security breaches. In situations where legal obligations dictate, We commit to promptly notify You and the relevant regulatory bodies of any suspected breaches.
6. DATA SECURITY OFFICER
The Company appoints a Data Security Officer (DSO) who is responsible for overseeing the security of our Users' information. The DSO is tasked with implementing and maintaining robust security measures to protect against unauthorized access, disclosure, alteration, or destruction of User data. Additionally, the DSO is responsible for ensuring compliance with relevant privacy laws and regulations. The DSO works in collaboration with our internal teams and external security experts to continuously assess and improve our security practices, including encryption protocols, access controls, and incident response procedures. For inquiries or concerns regarding information security, please contact anoop@unseenhumans.com. Our commitment to safeguarding the privacy and security of our Users' information is paramount, and the DSO plays a critical role in upholding this commitment.
7. LINKS TO THIRD-PARTY WEBSITES AND ADVERTISING
a. The Web Portal may include links to third -party applications/websites/web portals (“Third Party
Portals”). Such Third -Party portals or websites are governed by their respective privacy policies, which are beyond Our control. Once You leave our Web Portal , the use of any information You provide is governed by the privacy policy of the operator of the Third-Party Portal You are visiting. That policy may differ from Ours. If You can't find the privacy policy of any of these Third -Party Portals, You should contact the relevant third party directly for more information.
b. You consent to us to share any Personal Data or personally identifiable information to third party
websites/advertisers/ad-servers.
c. We may use third-party service providers to display ads on Our behalf across the internet and
sometimes on this Web Portal. They may collect anonymous information about Your visits to Our Web Portal. They may also use information about Your visits to this and other websites to target advertisements for goods and services.
d. This anonymous Information is collected through the use of standard technology used by most
major web portals or websites in the industry. No personally identifiable information is collected or used in this process.
8. LEGAL AGE
a. To use the Web Portal, individuals acting as employers must have attained the age of 18 years. In
the case of the User is an authorised representative of an organization, the authorized representative accessing the Web Portal must also have attained the age of 18 years. However, where local laws require that You must be older for the Company to be able to lawfully provide the services over the Web Portal to You then that older age shall apply as the applicable minimum age.
b. Where You are under the age of 18 (eighteen) years or the age of majority in Your jurisdiction, You
must use the Web Portal under the supervision of Your parents or legal guardians, wherein the parents or legal guardians shall be responsible for the Web Portal access.
9. COOKIES
a. Cookies are small files containing a small amount of data, including an anonymous unique
identifier, which are sent to your browser from a website and stored on your device's hard drive.
b. We utilize cookies to collect information for various purposes, including analyzing Web Portal
Services, User engagement, and measuring promotional effectiveness. Kindly note that c ertain features of the Web Portal may only be accessible through the use of cookies.
c. You have the option to instruct your browser to refuse all cookies or to indicate when a cookie is
being sent. However, please note that if you choose to decline cookies, you may not be able to use some portions of Our Web Portal, and certain features may not function as intended.
d. By using Our Web Portal and agreeing to this privacy policy, you consent to our use of cookies in
accordance with the terms outlined herein.
10. RIGHTS AND DUTIES OF THE USER
a. Users, having given consent, are entitled to request a comprehensive summary of their Personal
Data from the Company. This includes details about the processing activities undertaken and information about entities with whom their data has been shared.
b. Users possess the right to correct, complete, update, or erase their Personal Data unless its
retention is necessary for the original purpose or for legal compliance. The Company commits to erasing Personal Data upon User request unless specific legal obligations dictate otherwise.
c. Users have the right to access grievance redressal provided by the Company. However, U sers are
obligated to exhaust internal avenues for grievance resolution before approaching external bodies, such as the Data Protection Board of India or other legal proceedings before the courts, tribunals or any other authority.
d. When the processing of Personal Data is based on User consent, the User can withdraw that
consent at any time. The process for withdrawing consent should be as easy as the initial consent- giving process.
e. Users are obliged to comply with all applicable laws while interacting with the Company's services.
f. Users must refrain from impersonating another person when providing their Personal Data for any
specified purpose.
g. Users are required to provide full and accurate information without suppressing any material
details when submitting Personal Data for any documentation, unique identifiers, or proofs.
h. Users are prohibited from registering false or frivolous grievances or complaints with the Company
or the Data Protection Board of India or any other authority.
i. Users should furnish only information that is verifiably authentic while exercising the right to
correction or erasure under the provisions of the applicable law.
11. TERMINATION OR INACTIVATION OF ACCOUNT
a. In case of any cancellation/ inactivation / deletion, we request You to inform the Company about
Your intention to the Company in writing or call Our customer care phone number, or through any other option, if any, provided on the Web Portal.
b. You may terminate your use of the Web Portal at any time by submitting a termination request
through your point of contact to Us or the UNHU admin. Upon receiving the request, we will delete Your account and terminate Your access to the Web Portal. Upon receiving such a request, We will proceed to delete all information associated with the specific account, including, but not limited to, profile details, service history, media and chats, rewards, survey responses, and any other user- generated content.
c. Provided, the Company may continue to maintain transaction records for record-keeping purposes
and/or regulatory reasons. Deletion of the account or termination does not terminate your obligations undertaken prior to deletion or termination of the account. The Company may continue to retain a record of your activities or transactions made on the Web Portal for regulatory and archival purposes.
d. The Company reserves the right to terminate or suspend Your access to the Web Portal at any time
and for any reason with one month’s prior notice.
e. Upon disablement or deletion of the Web Portal User account, the User will be unable to log in and
access their account; however, some of the schemes availed of by their employees or affiliated App Users may still be valid depending on the terms and conditions of those schemes. Additionally, even if the User account is disabled or deleted, their employees or affiliated UNHU App users will continue to remain on the UNHU Platform as UNHU members, unless they explicitly request the Company for the disablement or deletion of their accounts.
f. There might be scenarios where We may not be able to execute account deletion, such as if there
exists an outstanding dispute, transactions suspected to be fraudulent, or unresolved claims attached to Y our account. Notwithstanding, upon resolution of the obstruction preventing deletion, the relevant information is promptly deleted and cannot be retrieved thereafter. We may continue to retain certain information if deemed necessary for regulatory complian ce, legitimate business interests like fraud preventio n, enhancing user safety and security or fulfilling our legal and contractual obligations.
g. For Users whose accounts have been disabled, these accounts can be re -enabled by either the
employer or the Company at their discretion, allowing the Users to access the Web Portal as before. However, Users whose accounts have been deleted will need to sign up again as new Users to regain access to the Web Portal.
12. NOTICE
a. Other than as consented hereof , every request made to the User for consent with regard to the
processing of the Personal Data shall be accompanied or preceded by a notice given by the Company to the User, informing the User of the Personal Data and the purpose for which the Personal Data is proposed to be processed. Further, the notice shall include the right to withdraw and the right to seek grievance redressal by the User.
b. The notice shall also include the manner in which the User may make a complaint to the Data
Protection Board as may be prescribed under the provisions of the law time being in force.
13. CONFIDENTIALITY AND SECURITY
a. Safeguarding the security and confidentiality of Your Personal Data holds paramount importance
for the Company, and substantial resources have been invested to ensure the protection and confidentiality of Your personal data. In engaging external service providers as processors, adherence to the Company's standards is mandated. Irrespective of the location of the transfer or storage of Your Personal Data, We undertake all reasonably necessary measures to ensure the secure preservation of Personal Data.
b. Notwithstanding any other provisions contained hereunder, User acknowledges that the
obligations related to confidentiality shall not pertain to any information which:
- (i) is in the public domain or comes into the public domain through no wrongful act on the
part of the Company; or
- (ii) is already known to the Company and/or its representatives as evidenced by their records
at the time of disclosure by the User; or
- (iii) is received by the Company and/or its representatives on a non-confidential basis from a
third party; or
- (iv) is received by the Company and/or its representatives from a third party without breach
of any agreement by the Company; or
- (v) is independently developed by the Company and/or its representatives without breach
hereunder; or
- (vi) is approved for release by written authorization of the User; or
- (vii) is required to be disclosed by applicable laws or regulations, order of the court of
competent jurisdiction or an appropriately empowered governmental, statutory or regulatory agency or under the rules of any stock exchange. In such a case of compelled disclosure, the Company will provide reasonable prior notice to the User and will request a protective order.
c. Our commitment extends to comply with the stipulations of the Information Technology Act, 2000
and Digital Personal Data Protection Act, 2023, and the associated Rules or any other laws for the time being in force , assuring the protection and preservation of Your privacy. By accepting the terms of this Privacy Policy, You expressly acknowledge that the standards and practices implemented by Us are reasonable and adequate for the protection of Your Personal Data.
14. SOCIAL MEDIA
a. The Company may manage channels, pages, and accounts on various social media platforms to
inform, assist, and engage with customers. The company actively observes and archives comments and posts on these channels pertaining to its operations, aiming to enhance the quality of its products and services.
b. The Company will not be communicating the following information shared by the User to the
Company through these social media platforms:
- sensitive data including (i) special categories of sensitive data meaning any information
revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation and (ii) other sensitive data such as criminal convictions and offences and national identification number ;
- excessive, inappropriate, offensive or defamatory content.
c. The Company is not responsible for any information posted by any person other than the Company
on the Web Portals or any social media platform. The Company is only responsible for its own use of the Personal Data received through such Web Portals.
15. ACCOUNT PROTECTION
The secret to Your account or profile is Your login credentials and password. You will be completely accountable for all actions taken using Your login, as well as for maintaining the security of Your password. Never give Your password or login credentials to anybody. You may lose significant control over Your personal information and may be subject to legally binding acts done on Your behalf if You disclose Your password or personal information with others. You are also solely liable for any actions taken under Your login. You should so change Your password right away if Your password has been compromised for whatever reason.
16. DISCLAIMER
a. The Company does not store any account-related information or any credit/debit card details. Our
Web Portal may utilize third-party payment gateways to facilitate secure transactions. When you make a purchase or payment through our Web Portal, you may be required to provide payment details such as credit/debit card information. Please note that we do not store any payment information on our servers. Your payment details are processed securely by our third -party payment service providers, and t heir use of your personal information is governed by their respective privacy policies. We encourage you to review the pr ivacy policies of these third -party providers to understand how Your information is handled during the payment process.
b. In case any Personal Data is shared by You with the Company, which is not requested by the
Company during registration, (whether mandatorily or optionally), the Company will not be liable for any information security breach or disclosure in relation to such information.
17. CONTACT INFORMATION
In case you have any grievances, questions, concerns, or requests regarding this Privacy Policy or Our data practices, please contact Us at contactus@unseenhumans.com. Thank You for using the Web Portal!
