LAST UPDATED: Saturday, December 12, 2020
TABLE OF CONTENTS
3 NAME AND ADDRESS OF THE CONTROLLER
5 COLLECTION OF GENERAL DATA AND INFORMATION
6 CONTACT POSSIBILITY VIA THE SERVICES
7 PRIVACY OF CHILDREN
8 CCPA PROVISON
10 ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA
11 RIGHTS OF THE DATA SUBJECT
12 DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)
13 DATA PROTECTION PROVISIONS FACEBOOK (VISITOR ACTION PIXEL)
14 DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF MAILCHIMP.
15 PAYMENT METHOD: DATA PROTECTION PROVISIONS ABOUT THE USE OF RAZORPAY AS A PAYMENT PROCESSOR
16 LEGAL BASIS FOR THE PROCESSING
17 THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY
18 PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
19 PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT; REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DAT
We are delighted that you have shown interest in the services of Inversa Technosoft Pvt Ltd (hereinafter referred to as “Inversa”, “we”, “us”, “our”) which are provided via Super Parent, Super Child and Super Child+ mobile website and mobile and desktop applications related, linked, or otherwise connected thereto (each an “App” and collectively the “Services”). Data protection is a particularly high priority for Inversa. The use of the Services of Inversa is possible without any indication of personal data; however, if a data subject wants to use special services via our Services, processing of personal data may become necessary. If the processing of personal data is necessary, and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA) and in accordance with the country-specific data protection regulations applicable to Inversa. Utilizing this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed through this data protection declaration, of the rights to which they are entitled.
As the controller, Inversa has implemented numerous technical and organizational measures to ensure the complete protection of personal data processed through our Services. However, Internet-based data transmissions may, in principle, have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
The data protection declaration of Inversa is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, among other things, the following terms:
- Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third-party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
NAME AND ADDRESS OF THE CONTROLLER
Controller for the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Inversa Technosoft Pvt Ltd,
#84, 4th floor, 22nd main, Banashankari 2nd stage, Bangalore 560070, Bengaluru, Karnataka 560061
COLLECTION OF GENERAL DATA AND INFORMATION
We collect personal data from you when you provide it to us directly and through your use of the Services. This information may include:
- Information you provide to us when you use our Services (e.g. your name, email, phone number, location data, relationship information between users (parent-child) and any information which you add to your account profile);
- Transaction and billing information (collected via our partner third-party payment processors), if you make any purchases from us or using our Services (e.g. credit/debit card details);
- We collect your children’s personal information through your consent which includes your children’s first, middle and last name, date of birth, age, gender. Your child’s device access times, device identifiers and serial numbers, search activity, messaging activity, and other information regarding your child’s interaction with an internet website, application, advertisement, device, or interactions with a device in general.
- Records of your interactions with us (e.g. if you contact our customer service team, interact with us on social media);
- Information you provide us when you enter a competition or participate in a survey;
- Information collected automatically, using cookies, and other tracking technologies (e.g. which pages you viewed and whether you clicked on a link in one of our email updates) and App usage data. We may also collect information about the device you use to access our Services; and
- Custom word lists you create to allow the Services to flag specific words of interest to you, e.g., preferred units of measurements
- Information you provide to us in relation to the desired preferences of the Services e.g., to schedule device access for your child’s device and related screen time allowance information)
- Other information necessary to provide the Services, for example we may access your location if you give us your consent.
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.
When using these general data and information, Inversa does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our Services correctly, (2) optimize the content of our Services as well as its advertisement, (3) ensure the long-term viability of our information technology systems and Services technology, (4) for analytics purposes, (5) to facilitate account creation and logon process, (6) request feedback (7) To inform the users (parent) about their child’s usage by sending monthly reports, recommendations, App usage trend (8) as necessary for basic functionality of the Services and account management (billing our clients) and, (8) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Inversa analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise and to achieve an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
CONTACT POSSIBILITY VIA THE SERVICES
The Services of Inversa contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
PRIVACY OF CHILDREN
The Services are not intended for children to submit Personal Information to us without receiving consent of their legal guardians. In compliance with the Children’s Online Privacy Protection Act (“COPPA”), please refer to the provisions below:
- The information we collect from your children and how we use it are detailed in section 5. (COLLECTION OF GENERAL DATA AND INFORMATION)
- We may share your children’s information (solely if necessary) with our service providers detailed below in Sections 12, 13, 14, and 15. You may contact us at firstname.lastname@example.org for more details about the privacy practices of our partner service providers.
- We may also disclose children’s information if required by the law or other appropriate authorities, for example, in response to a court summons or subpoena. We disclose information collected from children to facilitate the following: (i) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child; (ii) to protect the security or integrity of our Services; or (iii) enable us to take precautions against liability.
- We do not and will ensure not to collect more information than is necessary to provide the Services.
In accordance with the provisions of COPPA, you may upon request, review the children’s data we have collected from your child, and direct us to delete such data, and/or refuse us to allow any further collection or use of your children’s data. To exercise your rights, please contact us by email at email@example.com.
The California Code of Regulations defines a “resident” as:
- every individual who is in the State of California for other than a temporary or transitory purpose and
- 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, certain rights and obligations apply regarding your personal information.
if you are a resident of California, you are granted specific rights regarding access to your personal information.
Your California Privacy Rights
If you are a California resident, you have the following rights specifically under the California Consumer Privacy Act:
Right to Know. You have the right to know and see what data we have collected about you over the past 12 months, including:
(1) The categories of personal information we have collected about you;
(2) The categories of sources from which the personal information is collected;
(3) The business or commercial purpose for collecting your personal information;
(4) The categories of third parties with whom we have shared your personal information; and
(5) The specific pieces of personal information we have collected about you.
Right to Delete. You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same).
If you are under 18 years of age, reside in California, and have a registered account with the 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.).
Other Rights. 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 in this document.
Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.
To exercise your rights under the California Consumer Privacy Act, please contact us by either sending us an e-mail at firstname.lastname@example.org. Please provide your full name and e-mail address so that we may respond to your request as quickly as possible. You may be required to verify your identify before we fulfil your request. To do so, you will need to provide us with certain account information, such as your full name and email address. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization for the agent to act on your behalf. You will still need to verify your identity directly with us.
This Services ensures that data is encrypted when leaving the Services. This process involves the converting of information or data into a code to prevent unauthorised access. This Services follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods such as SSL are utilised to protect customer data when in transit to and from this Services over a secure communications channel.
Whilst we do everything within our power to ensure that personal data is protected at all times from our Services, we cannot guarantee the security and integrity of the information that has been transmitted to our Services.
ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
RIGHTS OF THE DATA SUBJECT
- Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us or another employee of the controller.
- Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing; the existence of the right to file a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may at any time contact our us or another employee of the controller.
- Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact us or another employee of the controller.
- Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing in accordance with Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Inversa, he or she may at any time contact our us or another employee of the controller. Inversa or another employee shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Inversa or another employee will arrange the necessary measures in individual cases.
- Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
The controller no longer needs the personal data for the processing, but they are required by the data subject for the establishment, exercise or Defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the conditions as mentioned above is met, and a data subject wishes to request the restriction of the processing of personal data stored by Inversa, he or she may at any time contact us or another employee of the controller. Inversa or another employee will arrange the restriction of the processing.
- Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used, and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided. As long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact Inversa or another employee.
- Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Inversa shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or Defence of legal claims.
If Inversa processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Inversa to the processing for direct marketing purposes, Inversa will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Inversa for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may directly contact Inversa or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
- Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Inversa shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact Inversa or another employee of the controller.
- Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact Inversa or another employee of the controller.
DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)
On this Services, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics, the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our Services from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyses the traffic on our Services. Google uses the collected data and information, among other things, to evaluate the use of our Services and to provide online reports, which show the activities on our Services, and to provide other services concerning the use of our Services for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyses the use of our Services. With each call-up to one of the individual pages of this Services, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our Services by the data subject. With each visit to our Services, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our Services at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
DATA PROTECTION PROVISIONS FACEBOOK (VISITOR ACTION PIXEL)
We use the “visitor action pixels” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”)) on our Services. This allows user behaviour to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads. Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
DATA PROTECTION PROVISIONS ABOUT THE APPLICATION AND USE OF MAILCHIMP.
PAYMENT METHOD: DATA PROTECTION PROVISIONS ABOUT THE USE OF RAZORPAY AS A PAYMENT PROCESSOR
On the Services, the controller has used Razorpay as an online service provider. Payments are processed via Razorpay and the data is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS) when processing payment.
The operator of the Razorpay component is Razorpay Software Private Limited, No. 22, 1st Floor, SJR Cyber, Laskar – Hosur Road, Adugodi, Bangalore.
If the data subject chooses “Razorpay” as the payment option in the online shop during the ordering process, we automatically transmit the data of the data subject to Razorpay. By selecting this payment option, the data subject agrees to the transfer of personal data required for payment processing.
The personal data transmitted to Razorpay is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order.
The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to Razorpay, in particular, if a legitimate interest in the transmission is given. The personal data exchanged between Razorpay and the controller for the processing of the data will be transmitted by Razorpay to economic credit agencies. This transmission is intended for identity and creditworthiness checks.
Razorpay will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfil contractual obligations or for data to be processed in the order.
The data subject has the possibility to revoke consent for the handling of personal data at any time from Razorpay. A revocation shall not have any effect on personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of Razorpay may be retrieved under https://razorpay.com/privacy/
LEGAL BASIS FOR THE PROCESSING
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example, in the case of inquiries concerning our services. If we are subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.
PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract. If the data subject requests for termination or terminates his Inversa Account, the personal data shall be retained for a period of 1 year from date of termination.
PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT; REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when we sign a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact us. We will clarify to the data subject whether the provision of the personal data is required by law, contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.