Privacy policy for Strategic Fulcrums and various products

Last updated as of 21 October 2023

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Welcome to UnClock Life Management Application’s Legal Privacy Policy

The creator of this Privacy Policy ensures a steady commitment to Your privacy with regard to the protection of your invaluable information that you may share across this Website and application. This privacy policy contains information about both the Website and application. 

To provide You with uninterrupted use of the Website and application, We may collect and, in some circumstances, such as legal requirements disclose information about you with your permission. To ensure better protection of Your privacy, We provide this notice explaining Our information collection and disclosure policies, and the choices You make about the way Your information is collected and used.  

Index:

• Personal Information

• Information We Collect

• Our Use Of Your Information

• How Information Is Collected

• External Links on The Platform

• Cookies

• Google Analytics

• Google Adsense

• Your Rights

• Compliances 

• Confidentiality

• Other Information Collectors

• Our Disclosure of Your Information

• Accessing, Reviewing and Changing Your Profile

• Security

• Severability

• Amendment

• Consent Withdrawal, Data Download & Data Removal Requests

• Contact Us

This Privacy Policy shall be in compliance with the General Data Protection Regulation (GDPR) in effect from May 25, 2018, and any and all provisions that may read to the contrary shall be deemed to be void and unenforceable as of that date. If you do not agree with the terms and conditions of our Privacy Policy, including in relation to the manner of collection or use of your information, please do not use or access the Site or application. If you have any questions or concerns regarding this Privacy Policy, you should contact our Customer Support Desk at “Hello"at"WhifCal"dot"com”.

ANY CAPITALIZED WORDS USED HENCEFORTH SHALL HAVE THE MEANING ACCORDED TO THEM UNDER THIS AGREEMENT. FURTHER, ALL HEADING USED 

HEREIN ARE ONLY FOR THE PURPOSE OF ARRANGING THE VARIOUS PROVISIONS OF THE AGREEMENT IN ANY MANNER. NEITHER THE USER NOR THE CREATORS OF THIS PRIVACY POLICY MAY USE THE HEADING TO INTERPRET THE PROVISIONS CONTAINED WITHIN IT IN ANY MANNER.

INFORMATION WE COLLECT

We are committed to respecting Your online privacy. We further recognize Your need for appropriate protection and management of any Personal Information You share with us. Depending on the need for application and services it provides, we may collect the following information: 

1. In certain cases we may collect - Personal data including but not limited to Name, Phone Number, Email ID, and Address.

2. Information collected through permission derived by the Website and application for Location access, and storage permissions etc.

3. Tracking Information such as, but not limited to the IP address of your device and Device ID when connected to the Internet. This information may include the URL that you just came from (whether this URL is on the Website and application or not), which URL you next go to (whether this URL is on the Website and application or not), your computer or device browser information, and other information associated with your interaction with the Website and application;

4. Details of Website and application usage for analytics.

This privacy policy also applies to data we collect from users who are not registered as members of this Website and application, including, but not limited to, browsing behaviour, pages viewed etc. We also collect and store personal information provided by You from time to time on the Website and application. We only collect and use such information from you that we consider necessary for achieving a seamless, efficient and safe experience, customized to your needs including: 

1. To enable the provision of services opted for by you;

2. To enable the viewing of content in your interest;

3. To communicate the necessary account and service-related information from time to time;

4. To allow you to receive quality customer care services and data Collection;

5. To comply with applicable laws, rules and regulations;

Where any service requested by You involves a third party, such information as is reasonably necessary by the Firm to carry out Your service request may be shared with such third party.

We may also use contact information internally to direct its efforts for service improvement but shall immediately delete all such information upon withdrawal of your consent for the same through the ‘unsubscribe’ button on such a communication channel or through a reply sent to “Hello “at” WhifCal“dot"com”.

To the extent possible, we provide You with the option of not divulging any specific information that you wish for us not to collect, store or use. You may also choose not to use a particular service or feature on the Website and application and opt-out of any non-essential communications from the Website and application. 

Further, transacting over the internet has inherent risks which can only be avoided by you following security practices yourself, such as not revealing account/login related information to any other person and informing our customer care team about any suspicious activity or where your account has/may have been compromised.

OUR USE OF YOUR INFORMATION

The information provided by you shall be used to provide and improve the service for you and all users.

1. To provide you with services on your request.

2. For maintaining an internal record.

3. For enhancing the Services provided.

4. For maintaining record under the legal and statutory provisions.

For more details about the nature of such communications, please refer to our Terms of Service. Further, your data and Sensitive Personal data may be collected and stored by Us for internal record. 

We use Your tracking information such as IP addresses, and or Device ID to help identify you and to gather broad demographic information and make further services available to you. 

We will not sell, license or trade Your personal information. We will not share your personal information with others unless they are acting under our instructions or we are required to do so by law. 

Information collected via Our server logs includes users' IP addresses and the pages visited; this will be used to manage the web system and troubleshoot problems. We also use third-party analytics, tracking, optimization and targeting tools to understand how users engage with our Website and application so that we can improve it.

HOW INFORMATION IS COLLECTED

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. If the same is not identified to you, you have the right to request us to elucidate the purpose of collection of said personal information, pending the fulfilment of which you shall not be mandated to disclose any information whatsoever. 

We will collect and use your personal information solely to fulfil those purposes specified by us, within the scope of the consent of the individual concerned or as required by law. We will only retain personal information as long as necessary for the fulfilment of those purposes. We will collect personal information by lawful and fair means and with the knowledge and consent of the individual concerned. 

Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

EXTERNAL LINKS ON THE PLATFORM

The Website and application may include advertisements, hyperlinks to other Website and applications or resources. We have no control over any other Website and application or resources or contents available on these other Website and applications, which are provided by companies or persons other than Us. You acknowledge and agree that we are not responsible for the availability of any such external sites or resources, and do not endorse any advertising, services/services or other materials on or available from such Website and application or resources. You acknowledge and agree that We are not liable for any loss or damage which may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, services or other materials on, or available from, such Website and applications. These external third-party Website and applications and resource providers may have their privacy policies governing the collection, storage, retention and disclosure of Your Personal Information that You may be subject to. We recommend that you enter the Website and application and review its privacy policy.

COOKIES

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. By continuing to browse the site, you are agreeing to our use of cookies. Cookies contain information that is transferred to your computer’s hard drive. You can set your browser to refuse all or some browser cookies, or to alert you when Website and applications set or access cookies. If you disable or refuse cookies, please note that some parts of this Website and application may become inaccessible or not function properly. A list of the type of cookies we use is as follows;

1. Strictly necessary cookies. These are cookies that are required for the operation of our Website and application. They include, for example, cookies that enable you to log into secure areas of our Website and application, use a shopping cart or make use of e-billing services.

2. Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Website and application when they are using it. This helps us to improve the way our Website and application works, for example, by ensuring that users are finding what they are looking for easily.

3. Functionality cookies. These are used to recognize you when you return to our Website and application. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

4. Targeting cookies. These cookies record your visit to our Website and application, the pages you have visited and the links you have followed. We will use this information to make our Website and application and the advertising displayed on it more relevant to your interests. We may also share this information with third-parties for this purpose.

Please note that third-parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website and application.

GOOGLE ANALYTICS

We use Google Analytics to help us to understand how you make use of our content and work out how we can make things better. These cookies follow your progress through us, collecting anonymous data on where you have come from, which pages you visit, and how long you spend on the site. This data is then stored by Google to create reports. These cookies do not store your personal data. 

The information generated by the cookie about your use of the Website and application, including your IP address, may be transmitted to and stored by Google on servers in the United States. Google may use this information for the purpose of evaluating your use of the Website and application, compiling reports on Website and application activity for us and providing other services relating to Website and application activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using this Website and application, you consent to the processing of data about you by Google in the manner and for the purposes set out above. 

The Google Website and application contains further information about Analytics and a copy of Google's privacy policy pages. 

YOUR RIGHTS

Unless subject to an exemption, as well as based on the nature of the application you use, you have some or all of the following rights concerning your data: 

1. The right to request a copy of your data which we hold about you; 

2. The right to request for any correction to any personal data if it is found to be inaccurate or out of date;

3. The right to withdraw Your consent to the processing at any time;

4. The right to object to the processing of personal data;

5. The right to complain about a supervisory authority. 

6. The right to obtain information as to whether personal data are transferred to a third country or an international organization.

Where you hold an account with any of our services, you are entitled to a copy of all personal data which we hold concerning you. You are also entitled to request that we restrict how we use your data in your account when you log in or through a setting in the application.

COMPLIANCES

Indian Compliances

1. This legal agreement is an electronic record in terms of the Indian Information Technology Act, 2000 and rules there under as applicable and the amended provisions about electronic records in various statutes as amended by the Indian Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.

2. This legal document is published in accordance with the provisions of Rule 3 (1) of the Indian Information Technology (Intermediaries guidelines) Rules, 2011 and Rule 4 of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 of Information Technology Act, 2000 amended through Information Technology Amendment Act, 2008 that require publishing the Terms of Use and practices for access and usage of any functional Website and application.

GDPR & Privacy Rights

Lawful Basis for Processing Personal Data: In compliance with the General Data Protection Regulation (GDPR), we are committed to being transparent about the lawful basis under which we collect, store, and process personal data. The following outlines the specific lawful bases we rely upon for processing different categories of personal data:

1. Consent

• We obtain your clear and explicit consent for specific processing activities, such as:

  • Sending marketing communications (e.g., newsletters, promotional offers)

  • Processing sensitive personal data (e.g., health information)

  • Sharing data with third-party partners for specific purposes

2. Performance of a Contract

• We process personal data necessary to fulfill our contractual obligations to you, such as:

  • Processing orders and payments

  • Providing customer support

  • Managing account information

3. Legal Obligation

• We process personal data to comply with applicable laws and regulations, such as:

  • Maintaining financial records

  • Responding to legal requests from authorities

4. Legitimate Interests

• We may process personal data based on our legitimate interests, provided we have considered your rights and ensured that such processing does not override them. Examples include:

  • Preventing fraud and security threats

  • Analyzing website traffic and user behavior to improve our services

5. Vital Interests

• • In rare cases, we may process personal data to protect the vital interests of individuals, such as in emergency situations involving health or safety.

6. Public Task

• • If we are carrying out a task in the public interest or exercising official authority, we may process personal data for that specific purpose.

Additional Information

• • We retain personal data only for as long as necessary for the purposes for which it was collected.

  • We take appropriate technical and organizational measures to protect personal data from unauthorized access, use, disclosure, alteration, or destruction.

  • You have various rights regarding your personal data, including the right to access, rectification, erasure, restriction of processing, data portability, and objection. They are outlined below

  • If you have any questions or concerns about our processing of your personal data, please contact us using the information provided in this privacy policy.

We are committed to protecting your privacy and handling your personal data in compliance with GDPR principles. 

The General Data Protection Regulation or GDPR gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help Users take advantage of those rights. As available and as applicable, except as limited under applicable law, the rights afforded to individuals are:

1. Right of access- You have the right to access the personal data we hold about you. You can exercise this right by contacting us at the address below. We will respond to your request within 30 days of receipt.

2. Right to rectification – You have the right to request that we rectify any inaccurate or incomplete personal data we hold about you. You can update your email address directly through your account settings or by contacting us at the address provided below.

3. Right to erasure- You have the right to request that we erase your personal data in certain circumstances, such as if the data is no longer necessary for the purposes for which it was collected or if you withdraw your consent. You can exercise this right by contacting us at the address below. We will process your request within 7 working days, but we aim to stop processing your data as soon as possible.

4. Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data, You can exercise this right by contacting us at the address below.

5. Right to object – the right to object to us processing your personal data on grounds relating to your particular situation. Along with the right to object to your personal data being processed for direct marketing purposes, You can exercise this right by contacting us at the address below. 

6. Right to Restriction of Processing - You have the right to request that we restrict the processing of your personal data in certain circumstances, such as if you believe that the data is inaccurate or if you have objected to our processing of your data. You can exercise this right by contacting us at the address below.

7. Right to data portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another part’s service, You can exercise this right by contacting us at the address below.

8. Right not to be subject to automated decision-making, the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

Data Transfer and Safeguards

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including India & other countries. This is necessary for providing our services, account support, fraud prevention, & product improvement needs.

India is not currently considered by the European Union to have adequate safeguards for personal data. To ensure your data remains protected, we rely on the following mechanisms to transfer your data safely and securely:

Additional Security Measures: We implement robust technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, anonymization, and access controls.

You have the right to object to the transfer of your personal data to India. You can exercise this right by contacting us at the address provided below. Please note that if you object to the transfer, we may not be able to provide you with certain services.

We regularly review the adequacy of the safeguards in place for data transfers to India and will update this Privacy Policy if necessary.

Data Retention and Deletion

We are committed to storing your personal data only for as long as necessary for the purposes for which it was collected and processed.

Your data may be retained for a maximum of 90 days after you delete your account. This allows us to maintain adequate records for potential security investigations and fraud prevention purposes. After this period, your data will be securely deleted unless:

• We are required to preserve it by law (e.g., legal request from authorities)

• It is necessary to resolve disputes or protect our legal rights

We regularly review our data retention periods and update them as needed to ensure compliance with applicable data protection regulations, including the GDPR's Storage Limitation Principle.

Data Security and Employee Training

We take the security of your personal data seriously and have implemented various technical and organizational measures to protect it from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: We encrypt your personal data both in transit and at rest.

• Access controls: We restrict access to your personal data to authorized personnel only on a need-to-know basis.

• Regular security audits: We conduct regular security audits to identify and address any potential vulnerabilities in our systems.

In addition to these technical measures, we are committed to raising awareness among our employees about their role in protecting personal data. We provide regular training on the following topics:

• GDPR compliance: Our employees are trained on the General Data Protection Regulation (GDPR) and their obligations to comply with its requirements.

• Data security best practices: Employees learn about best practices for handling personal data securely, such as avoiding unauthorized access, phishing scams, and data breaches.

• Incident reporting: Our employees are trained on how to identify and report potential data security incidents promptly.

• Subject access requests: We train our employees on the process for handling subject access requests from individuals under the GDPR.

Our internal policies regarding data security and employee training are regularly reviewed and updated to ensure they remain effective and compliant with applicable data protection regulations.

Data Protection Responsibilities

While we are not required to appoint a Data Protection Officer (DPO) under Article 37 of the GDPR due to the nature and scale of our data processing activities, we remain committed to protecting your personal data and fulfilling our data protection obligations.

We have assigned specific responsibilities for data protection within our company to ensure compliance with GDPR requirements. These responsibilities include:

• • Handling subject access requests

  • Conducting data protection impact assessments (DPIAs)

  • Implementing and monitoring data protection policies and procedures

  • Cooperating with supervisory authorities

If you have any questions or concerns about our data protection practices, please contact us at the address provided below.

We regularly review and update our data protection measures to ensure they remain effective and compliant with applicable regulations.

Objection to Data Transfer and Service Options

While we strive to respect your rights regarding data transfer, please note that given we limit information we collect to strictly essential information for us to provide you with account information, maintain security, and prevent fraud. If you object to the transfer of it to India, we may not be able to provide you with the full functionality of our services.

In such cases, we offer the following options:

Partial Refund: If you have an ongoing subscription, we may offer a prorated refund based on the remaining duration of your subscription, subject to our standard refund policy.

Service Suspension: You may choose to temporarily suspend your service until you withdraw your objection or find an alternative solution. During suspension, your account information will be retained for a limited period, but you will not have access to the service's features.

Alternative Arrangements: If feasible, we may explore alternative arrangements to provide you with limited service functionality without involving data transfer to India. However, this may not always be possible due to technical and operational constraints.

We encourage you to contact us to discuss your specific concerns and explore the available options. We are committed to working with you to find a solution that respects your data rights while ensuring the continued provision of our services.

Please note that we may not be able to offer full refunds in cases where objection to data transfer significantly impacts our ability to deliver the services as intended.

We appreciate your understanding and cooperation in this matter.

CONFIDENTIALITY

You further acknowledge that the Website and application may contain information that is designated confidential by us and that you shall not disclose such information without our prior written consent. Your information is regarded as confidential and therefore will not be divulged to any third party, unless if legally required to do so to the appropriate authorities. We will not sell, share, or rent your personal information to any third party or use your e-mail address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed services, and you retain sole discretion to seek for discontinuation of such communications at any point in time. 

OTHER INFORMATION COLLECTORS

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties, whether they are on our Website and application or other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. To the extent that we use third party advertisers, they adhere to their privacy policies. Since we do not control the privacy policies of the third parties, you are subject to ask questions before you disclose your personal information to others. 

OUR DISCLOSURE OF YOUR INFORMATION

We may host surveys for survey creators for our Website and application who are the owners and users of your survey responses. We do not own or sell your responses. Anything you expressly disclose in your responses will be disclosed to survey creators. Please contact the survey creator directly to better understand how they might share your survey responses.

Information collected will not be considered as sensitive if it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005, any rules made thereunder or any other law for the time being in force.

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting and foregoing), we may be forced to disclose information to the government, law enforcement agencies or third parties. Therefore, although we use industry-standard practices to protect your privacy, we do not promise, and you should not expect, that your personally identifiable information or private communications would always remain private. We do however assure you that any disclosure of your personally identifiable information shall be personally intimated to you through an email sent to your provided email address.

As a matter of policy, we do not sell or rent any personally identifiable information about you to any third party. However, the following describes some of the ways that your personally identifiable information may be disclosed: 

1. External Service Providers: There may be several services offered by external service providers that help you use our Website and application. If you choose to use these optional services, and in the course of doing so, disclose information to the external service providers, and/or permit them to collect information about you, then their use of your information is governed by their privacy policy.

2. Law and Order: We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as intellectual property rights, fraud and other rights. We can (and you authorize us to) disclose any information about you to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability. 

ACCESSING, REVIEWING AND CHANGING YOUR PROFILE

You can review and change the information you submitted except Email ID. An option for facilitating such change shall be present on the Website and application and such change shall be facilitated by the User. If you change any information, we may or may not keep track of your old information. We will not retain in our files information you have requested to remove for certain circumstances, such as to resolve disputes, troubleshoot problems and enforce our terms and conditions. Such prior information shall be completely removed, based on time and nature of the purpose and system, from our databases, including stored ‘back up’ systems. If you believe that any information, we are holding on to you is incorrect or incomplete, or to remove your profile so that others cannot view it, the User needs to remediate, and promptly correct any such incorrect information.

SECURITY

We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by members inside and outside the Firm. We follow generally accepted industry standards to protect the Personal Information submitted to us and information that we have accessed.

However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you provide won’t be intercepted while being transmitted to the Firm over the Internet. 

SEVERABILITY

Each paragraph of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other paragraphs herein except where otherwise expressly indicated or indicated by the context of the agreement. The decision or declaration that one or more of the paragraphs are null and void shall not affect the remaining paragraphs of this privacy policy.

AMENDMENT

Our Privacy Policy may change from time to time. The most current version of the policy will govern our use of your information and will always be on the Website and application. Any amendments to this Policy shall be deemed as accepted by the User on their continued use of the Website and application. 

CONSENT WITHDRAWAL, DATA DOWNLOAD & DATA REMOVAL REQUESTS

To withdraw your consent, or to request the download or delete your data with us for any or all our services at any time, please email to“Hello"at"WhifCal"dot"com”.

CONTACT US

If you have any questions or concerns regarding this privacy policy, you should contact us.