PRIVACY
POLICY
Last
updated April 27, 2023
This
privacy notice for Progressive AI Data Pvt. Ltd. (doing business
as Progenei) ('Progenei', 'we', 'us', or 'our'), describes how and why we might collect, store,
use, and/or share ('process') your information when you use our services ('Services'),
such as when you:
- Visit our website at https://www.progenei.com,
or any website of ours that links to this privacy notice
- Engage with us in other related ways, including
any sales, marketing, or events
Questions
or concerns? Reading this privacy notice will
help you understand your privacy rights and choices. If you do not agree with
our policies and practices, please do not use our Services. If you still have
any questions or concerns, please contact us at support@progenei.com.
SUMMARY
OF KEY POINTS
This
summary provides key points from our privacy notice, but you can find out more
details about any of these topics by clicking the link following each key point
or by using our table of contents below to find the section you are looking for.
What
personal information do we process? When
you visit, use, or navigate our Services, we may process personal information
depending on how you interact with Progenei and the Services, the
choices you make, and the products and features you use. Learn more about personal information you
disclose to us.
Do
we process any sensitive personal information? We do not process sensitive personal
information.
Do
we receive any information from third parties? We do not receive any information from third
parties.
How
do we process your information? We
process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your consent.
We process your information only when we have a valid legal reason to do so.
Learn more about how we process your
information.
In
what situations and with which types of parties do we share personal
information? We may share information in
specific situations and with specific categories of third parties.
Learn more about when and with whom
we share your personal information.
How
do we keep your information safe? We
have organisational and technical processes and procedures in place
to protect your personal information. However, no electronic transmission over
the internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorised third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information.
Learn more about how we keep your
information safe.
What
are your rights? Depending on where you are
located geographically, the applicable privacy law may mean you have certain
rights regarding your personal information. Learn more about your privacy rights.
How
do you exercise your rights? The
easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will
consider and act upon any request in accordance with applicable data protection
laws.
Want
to learn more about what Progenei does with any information we
collect? Review the privacy
notice in full.
TABLE
OF CONTENTS
1.
WHAT INFORMATION DO WE COLLECT?
Personal
information you disclose to us
In
Short: We collect personal information
that you provide to us.
We
collect personal information that you voluntarily provide to us when
you register on the Services, express an interest in obtaining
information about us or our products and Services, when you participate in
activities on the Services, or otherwise when you contact us.
Personal
Information Provided by You. The
personal information that we collect depends on the context of your
interactions with us and the Services, the choices you make, and the products
and features you use. The personal information we collect may include the
following:
- names
- email addresses
- usernames
- passwords
- debit/credit card numbers
- job titles
Sensitive
Information. We do not process sensitive
information.
Payment
Data. We may collect data necessary
to process your payment if you make purchases, such as your payment instrument
number, and the security code associated with your payment instrument. All
payment data is stored by CCAvenue. You may find their privacy notice link(s)
here: https://www.ccavenue.com/privacy.jsp.
All
personal information that you provide to us must be true, complete, and
accurate, and you must notify us of any changes to such personal information.
Information
automatically collected
In
Short: Some information — such as your
Internet Protocol (IP) address and/or browser and device characteristics — is
collected automatically when you visit our Services.
We
automatically collect certain information when you visit, use, or navigate the
Services. This information does not reveal your specific identity (like your
name or contact information) but may include device and usage information, such
as your IP address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country, location,
information about how and when you use our Services, and other technical
information. This information is primarily needed to maintain the security and
operation of our Services, and for our internal analytics and reporting
purposes.
Like
many businesses, we also collect information through cookies and similar
technologies.
2.
HOW DO WE PROCESS YOUR INFORMATION?
In
Short: We process your information to
provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your
information for other purposes with your consent.
We
process your personal information for a variety of reasons, depending on how
you interact with our Services, including:
- To facilitate account creation and authentication
and otherwise manage user accounts. We may process your information so you can create
and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to
the user. We may process your
information to provide you with the requested service.
- To respond to user inquiries/offer support to
users. We may process your
information to respond to your inquiries and solve any potential issues
you might have with the requested service.
- To fulfil and manage your orders. We may process your information to fulfil and
manage your orders, payments, returns, and exchanges made through the
Services.
- To save or protect an individual's vital
interest. We may process your information when
necessary to save or protect an individual’s vital interest, such as to
prevent harm.
3.
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In
Short: We only process your personal information
when we believe it is necessary and we have a valid legal reason
(i.e. legal basis) to do so under applicable law, like with your consent,
to comply with laws, to provide you with services to enter into
or fulfil our contractual obligations, to protect your rights, or
to fulfil our legitimate business interests.
If
you are located in the EU or UK, this section applies to you.
The
General Data Protection Regulation (GDPR) and UK GDPR require us to explain the
valid legal bases we rely on in order to process your personal information. As
such, we may rely on the following legal bases to process your personal
information:
- Consent. We may
process your information if you have given us permission
(i.e. consent) to use your personal information for a specific
purpose. You can withdraw your consent at any time. Learn more about withdrawing
your consent.
- Performance of a Contract. We may process your personal information when we believe it
is necessary to fulfil our contractual obligations to you,
including providing our Services or at your request prior to entering into
a contract with you.
- Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate
with a law enforcement body or regulatory agency, exercise or defend our
legal rights, or disclose your information as evidence in litigation in
which we are involved.
- Vital Interests. We may process your information where we believe it is
necessary to protect your vital interests or the vital interests of a
third party, such as situations involving potential threats to the safety
of any person.
If
you are located in Canada, this section applies to you.
We
may process your information if you have given us specific permission
(i.e. express consent) to use your personal information for a specific
purpose, or in situations where your permission can be inferred
(i.e. implied consent). You can withdraw your
consent at any time.
In
some exceptional cases, we may be legally permitted under applicable law to
process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and
consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is
necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating
with next of kin
- If we have reasonable grounds to believe an individual has been,
is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and the
collection is reasonable for purposes related to investigating a breach of
an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court
order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their
employment, business, or profession and the collection is consistent with
the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary
purposes
- If the information is publicly available and is specified by the
regulations
4.
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In
Short: We may share information in
specific situations described in this section and/or with the
following categories of third parties.
Vendors,
Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors,
service providers, contractors, or agents ('third
parties') who perform services for us or
on our behalf and require access to such information to do that work. We
have contracts in place with our third parties, which are designed to help
safeguard your personal information. This means that they cannot do anything
with your personal information unless we have instructed them to do it. They
will also not share your personal information with
any organisation apart from us. They also commit to protect the data they
hold on our behalf and to retain it for the period we
instruct. The categories of third parties we may share personal
information with are as follows:
- Product Engineering & Design Tools
We also may
need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with,
or during negotiations of, any merger, sale of company assets, financing,
or acquisition of all or a portion of our business to another company.
5.
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In
Short: We may use cookies and other
tracking technologies to collect and store your information.
We
may use cookies and similar tracking technologies (like web beacons and pixels)
to access or store information. Specific information about how we use such
technologies and how you can refuse certain cookies is set out in our Cookie
Notice.
6.
HOW LONG DO WE KEEP YOUR INFORMATION?
In
Short: We keep your information for as
long as necessary to fulfil the purposes outlined in this privacy
notice unless otherwise required by law.
We
will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is
required or permitted by law (such as tax, accounting, or other legal
requirements). No purpose in this notice will require us keeping your
personal information for longer than the period of time in which users
have an account with us.
When
we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymise such information, or,
if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is possible.
7.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In
Short: We aim to protect your personal
information through a system of organisational and technical security
measures.
We
have implemented appropriate and reasonable technical
and organisational security measures designed to protect the security
of any personal information we process. However, despite our safeguards and
efforts to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100% secure,
so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorised third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission
of personal information to and from our Services is at your own risk. You
should only access the Services within a secure environment.
8.
DO WE COLLECT INFORMATION FROM MINORS?
In
Short: We do not knowingly collect
data from or market to children under 18 years of age.
We
do not knowingly solicit data from or market to children under 18 years of age.
By using the Services, you represent that you are at least 18 or that you are
the parent or guardian of such a minor and consent to such minor dependent’s
use of the Services. If we learn that personal information from users less than
18 years of age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you
become aware of any data we may have collected from children under age 18,
please contact us at __________.
9.
WHAT ARE YOUR PRIVACY RIGHTS?
In
Short: In some regions, such
as the European Economic Area (EEA), United Kingdom (UK), and Canada, you
have rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any
time.
In
some regions (like the EEA, UK, and Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to request
access and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your personal
information; and (iv) if applicable, to data portability. In certain
circumstances, you may also have the right to object to the processing of your
personal information. You can make such a request by contacting us by using the
contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?' below.
We
will consider and act upon any request in accordance with applicable data
protection laws.
If
you are located in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If
you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing
your consent: If we are relying on your
consent to process your personal information, which may be express and/or
implied consent depending on the applicable law, you have the right to
withdraw your consent at any time. You can withdraw your consent at any time by
contacting us by using the contact details provided in the section 'HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?' below.
However,
please note that this will not affect the lawfulness of the processing before
its withdrawal nor, when applicable law allows, will it affect the
processing of your personal information conducted in reliance on lawful
processing grounds other than consent.
Account
Information
If
you would at any time like to review or change the information in your account
or terminate your account, you can:
- Log in to your account settings and update your user account.
Upon
your request to terminate your account, we will deactivate or delete your
account and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with
any investigations, enforce our legal terms and/or comply with applicable legal
requirements.
Cookies
and similar technologies: Most
Web browsers are set to accept cookies by default. If you prefer, you can
usually choose to set your browser to remove cookies and to reject cookies. If
you choose to remove cookies or reject cookies, this could affect certain
features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.
If
you have questions or comments about your privacy rights, you may email us
at support@progenei.com.
10.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most
web browsers and some mobile operating systems and mobile applications include
a Do-Not-Track ('DNT') feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities
monitored and collected. At this stage no uniform technology standard
for recognising and implementing DNT signals has been finalised.
As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online.
If a standard for online tracking is adopted that we must follow in the future,
we will inform you about that practice in a revised version of this privacy
notice.
11.
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In
Short: Yes, if you are a resident of
California, you are granted specific rights regarding access to your personal
information.
California
Civil Code Section 1798.83, also known as the 'Shine The Light' law,
permits our users who are California residents to request and obtain from us,
once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing
purposes and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit your
request in writing to us using the contact information provided below.
If
you are under 18 years of age, reside in California, and have a registered
account with Services, you have the right to request removal of unwanted data that
you publicly post on the Services. To request removal of such data, please
contact us using the contact information provided below and include the email
address associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on the
Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g. backups, etc.).
CCPA
Privacy Notice
The
California Code of Regulations defines a 'resident' as:
(1)
every individual who is in the State of California for other than a temporary
or transitory purpose and
(2)
every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All
other individuals are defined as 'non-residents'.
If
this definition of 'resident' applies to you, we must adhere to
certain rights and obligations regarding your personal information.
What
categories of personal information do we collect?
We
have collected the following categories of personal information in the past
twelve (12) months:
|
Category
|
Examples
|
Collected
|
|
A. Identifiers
|
Contact details, such as real
name, alias, postal address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol address, email
address, and account name
|
NO
|
|
B. Personal information
categories listed in the California Customer Records statute
|
Name, contact information,
education, employment, employment history, and financial information
|
NO
|
|
C. Protected classification
characteristics under California or federal law
|
Gender and date of birth
|
NO
|
|
D. Commercial information
|
Transaction information,
purchase history, financial details, and payment information
|
NO
|
|
E. Biometric information
|
Fingerprints and voiceprints
|
NO
|
|
F. Internet or other similar
network activity
|
Browsing history, search
history, online behaviour, interest data, and interactions with our and
other websites, applications, systems, and advertisements
|
NO
|
|
G. Geolocation data
|
Device location
|
NO
|
|
H. Audio, electronic, visual,
thermal, olfactory, or similar information
|
Images and audio, video or
call recordings created in connection with our business activities
|
NO
|
|
I. Professional or
employment-related information
|
Business contact details in
order to provide you our Services at a business level or job title, work
history, and professional qualifications if you apply for a job with us
|
NO
|
|
J. Education Information
|
Student records and directory
information
|
NO
|
|
K. Inferences drawn from
other personal information
|
Inferences drawn from any of
the collected personal information listed above to create a profile or
summary about, for example, an individual’s preferences and characteristics
|
NO
|
|
L. Sensitive Personal Information
|
NO
|
We
may also collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in
the context of:
- Receiving help through our customer support
channels;
- Participation in customer surveys or contests;
and
- Facilitation in the delivery of our Services and
to respond to your inquiries.
How
do we use and share your personal information?
More
information about our data collection and sharing practices can be found in
this privacy notice.
You
may contact us by email at support@progenei.com, or by referring to the contact details at the bottom
of this document.
If
you are using an authorised agent to exercise your right to opt out
we may deny a request if the authorised agent does not submit proof
that they have been validly authorised to act on your behalf.
Will
your information be shared with anyone else?
We
may disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Each service provider is
a for-profit entity that processes the information on our behalf, following the
same strict privacy protection obligations mandated by the CCPA.
We
may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration.
This is not considered to be 'selling' of your personal information.
Progressive
AI Data Pvt. Ltd. has not sold or shared any personal information to third
parties for a business or commercial purpose in the preceding twelve (12)
months. Progressive AI Data Pvt.
Ltd. has disclosed the following categories of personal information to
third parties for a business or commercial purpose in the preceding twelve (12)
months:
The
categories of third parties to whom we disclosed personal information for a
business or commercial purpose can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?'.
Your
rights with respect to your personal data
Right
to request deletion of the data — Request to delete
You
can ask for the deletion of your personal information. If you ask us to delete
your personal information, we will respect your request and delete your
personal information, subject to certain exceptions provided by law, such as
(but not limited to) the exercise by another consumer of his or her right to
free speech, our compliance requirements resulting from a legal obligation, or
any processing that may be required to protect against illegal activities.
Right
to be informed — Request to know
Depending
on the circumstances, you have a right to know:
- whether we collect and use your personal
information;
- the categories of personal information that we
collect;
- the purposes for which the collected personal
information is used;
- whether we sell or share personal information to
third parties;
- the categories of personal information that we
sold, shared, or disclosed for a business purpose;
- the categories of third parties to whom the
personal information was sold, shared, or disclosed for a business
purpose;
- the business or commercial purpose for
collecting, selling, or sharing personal information; and
- the specific pieces of personal information we collected about you.
In
accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or
to re-identify individual data to verify a consumer request.
Right
to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We
will not discriminate against you if you exercise your privacy rights.
Right
to Limit Use and Disclosure of Sensitive Personal Information
We
do not process consumer's sensitive personal information.
Verification
process
Upon
receiving your request, we will need to verify your identity to determine you
are the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we
can match it with information you have previously provided us. For instance,
depending on the type of request you submit, we may ask you to provide certain
information so that we can match the information you provide with the
information we already have on file, or we may contact you through a
communication method (e.g. phone or email) that you have previously
provided to us. We may also use other verification methods as the circumstances
dictate.
We
will only use personal information provided in your request to verify your
identity or authority to make the request. To the extent possible, we will
avoid requesting additional information from you for the purposes of
verification. However, if we cannot verify your identity from the information
already maintained by us, we may request that you provide additional
information for the purposes of verifying your identity and for security or
fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.
Other
privacy rights
- You may object to the processing of your personal
information.
- You may request correction of your personal data
if it is incorrect or no longer relevant, or ask to restrict the
processing of the information.
- You can designate an authorised agent
to make a request under the CCPA on your behalf. We may deny a request
from an authorised agent that does not submit proof that they
have been validly authorised to act on your behalf in accordance
with the CCPA.
- You may request to opt out from future selling or
sharing of your personal information to third parties. Upon receiving an
opt-out request, we will act upon the request as soon as feasibly
possible, but no later than fifteen (15) days from the date of the request
submission.
To
exercise these rights, you can contact us by email
at support@progenei.com, or
by referring to the contact details at the bottom of this document. If you have
a complaint about how we handle your data, we would like to hear from you.
12.
DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In
Short: Yes, if you are a resident of
Virginia, you may be granted specific rights regarding access to and use of
your personal information.
Virginia
CDPA Privacy Notice
Under
the Virginia Consumer Data Protection Act (CDPA):
'Consumer' means
a natural person who is a resident of the Commonwealth acting only in an
individual or household context. It does not include a natural person acting in
a commercial or employment context.
'Personal
data' means any information that is linked or reasonably linkable to an
identified or identifiable natural person. 'Personal data' does not
include de-identified data or publicly available information.
'Sale
of personal data' means the exchange of personal data for monetary
consideration.
If
this definition 'consumer' applies to you, we must adhere to certain
rights and obligations regarding your personal data.
The
information we collect, use, and disclose about you will vary depending on how
you interact with Progressive AI Data Pvt. Ltd. and our Services. To
find out more, please visit the following links:
Your
rights with respect to your personal data
- Right to be informed whether or not we are processing your personal
data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request deletion of your personal data
- Right to obtain a copy of the personal data you previously shared
with us
- Right to opt out of the processing of your personal data if it is
used for targeted advertising, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects ('profiling')
Progressive
AI Data Pvt. Ltd. has not sold any personal data to third parties for
business or commercial purposes. Progressive AI Data Pvt. Ltd. will
not sell personal data in the future belonging to website visitors, users, and
other consumers.
Exercise
your rights provided under the Virginia CDPA
More
information about our data collection and sharing practices can be found in
this privacy notice.
You
may contact us by email at support@progenei.com, by submitting
a data subject access request, or by referring to the contact
details at the bottom of this document.
If
you are using an authorised agent to exercise your rights, we may
deny a request if the authorised agent does not submit proof that
they have been validly authorised to act on your behalf.
Verification
process
We
may request that you provide additional information reasonably necessary to
verify you and your consumer's request. If you submit the request through
an authorised agent, we may need to collect additional information to
verify your identity before processing your request.
Upon
receiving your request, we will respond without undue delay, but in all cases,
within forty-five (45) days of receipt. The response period may be extended
once by forty-five (45) additional days when reasonably necessary. We will
inform you of any such extension within the initial 45-day response period,
together with the reason for the extension.
Right
to appeal
If
we decline to take action regarding your request, we will inform you of our
decision and reasoning behind it. If you wish to appeal our decision,
please email us at support@progenei.com. Within sixty (60) days of receipt
of an appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.
13.
DO WE MAKE UPDATES TO THIS NOTICE?
In
Short: Yes, we will update this notice as
necessary to stay compliant with relevant laws.
We
may update this privacy notice from time to time. The updated version will be
indicated by an updated 'Revised' date and the updated version will
be effective as soon as it is accessible. If we make material changes to this
privacy notice, we may notify you either by prominently posting a notice of
such changes or by directly sending you a notification. We encourage you to
review this privacy notice frequently to be informed of how we are protecting
your information.
14.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If
you have questions or comments about this notice, you may email us
at __________ or by post to:
Progressive
AI Data Pvt. Ltd.
Level
5, Block C, Green Boulevard Sector 62, Noida
Noida, Uttar Pradesh 201301
India
15.
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based
on the applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that
information, or delete it. To request to review, update, or delete your
personal information, please fill out and submit a data subject access request.