This Privacy Policy applies to ‘RTSM App’ (“Application”)

(Please note any reference to ‘Application’ should be inferred as a reference to the owner company of the Application as mentioned herein. The usage of such terminology as “We/ we” or “Our/ our" or “Us/ us”, or any such references directed towards ‘RTSM App’ shall be a direct reference to the Application and the owner company of the Application)

The Application recognises the importance of maintaining your privacy. We value your privacy and appreciate your trust in us. This privacy policy (“Privacy Policy”) describes how we treat the user information we collect via the Application. This Privacy Policy applies to current and former users (for the lawful duration of usage until explicit Application profile deletion) of our Application. It is further clarified that at all times the Privacy Policy shall be read together complimentarily with the User License Agreement [insert link for User License Agreement]

By browsing, visiting, accessing and/or using the services on our Application (or viewing and/or using any of the pages/ part of the Application on such other device(s) not owned by you), you as the user consent and agree to our privacy policy laid out herein. You also agree that the information furnished by you is lawful, true and correct and does not violate or infringe any laws. In case of any violations, infringement, furnishing of wrongful or unauthorized information, the Application (or its owner company as provided hereunder) shall not be liable for the same The Application is a property of Klusterz Innovation and Software Solutions, a private limited company incorporated and registered under the (Indian) Companies Act, 2013, and having its registered office at 258A, New Manglapuri, New Delhi – 110030.

USER INFORMATION COLLECTED BY US

Information We Collect Automatically.

Downloading and viewing the Application (to mean browsing without registration, i.e. creating an Application account/ Application profile, hereinafter used interchangeably to mean the main profile or account you will have to create on our Application to use the services provided therein, and not be restricted to mere downloading and viewing of the Application) does not require you to register for an Application profile or provide any Personal Information (as defined in Clause 1.2.2.) to us (subject to such limited usage of the Application as may be provided by the Application inter alia merely viewing the Application). In general, the Application will only gather certain generic information automatically. This generic information may include, inter alia, the internet address assigned to your device, the number and frequency of downloaded versions of the Application, and certain device information amongst other generic information. Generic information does not reveal the identity of the visitor. This type of aggregate data of generic information may enable us to figure out how often users use parts of the Application and the services provided therein without creating an Application profile or registering and using the full extent of services being provided by the Application.

Information You Provide to Us.

• We receive and store any information you enter into the Application or provide to us in any other way, in relation to the services being provided thereunder, =. You can choose not to provide us with certain information, though you may not be able to take advantage of certain service features thereof. It is hereby clarified that once you register under the main Application (as per the sign up protocols of the Application), and/or give us your Personal Information or parts of your Personal Information in any manner, you are no longer anonymous to us. It is hereby further clarified that our primary purpose in collecting Personal Information is to provide you with a safe, smooth, and efficient experience. We collect Personal Information about you that we consider necessary for achieving this purpose.

• Personally Identifiable Information:

  If you choose to access all services provided by our Application, you must register and create an Application profile as per the sign up protocols of the Application. Further, when you, (i) register with us on the Application to become a user (ii) choose to add information to your Application profile or (iii) create the Application profile in anyway, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you ("Personal Information"). Personal Information includes, but is not limited to, your name, company name (if applicable), phone number, email address and home and office postal addresses, as applicable. We use your Personal Information mainly to provide the services offer via the Application, and administer your inquiries along with providing you a customized user experience. You may register and subsequently use the services being provided via the Application (subject to first time sign up protocols as may be required by the Application, which may inter alia include providing explicit consent to this Privacy Policy and the terms as mentioned in the User License Agreement, included here by way of reference) directly from the Application (feeding in your details) or by logging into your Application profile with certain third party social media or social networking services ("Social Networking Site") (including, but not limited to, Facebook) via the Application. If you decide to register through a Social Networking Site (subject to first time sign up protocols as may be required by the Application, which may inter alia include providing explicit consent to this Privacy Policy and the terms as mentioned in the User License Agreement, included here by way of reference), we will extract some of the Personal Information which you have provided to the Social Networking Site (such as, but not limited to, your name, email address and other information you make publicly available via the Social Networking Site) from the account you have with the applicable Social Networking Site and use that information to create your Application profile. The specific information that we extract may depend on the privacy settings you have with the Social Networking Site. You hereby consent to our access to and collection of such Personal Information about you (upon providing your explicit consent to this Privacy Policy via your e-mail). We also collect the other information that you provide as part of registration, and the administration and personalization of your Application profile (such as, without limitation, pin code (on its own) and individual preferences) ("Non-Identifying Information"). We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide all access to the customised services on the Application and administer your inquiries. Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your pin code with your street address) in a way that enables you to be identified. Although it is hereby clarified that the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users of the Application to attempt to provide you with a better experience, to improve the quality and value of the Application as a whole and the services being provided therein and to analyse and understand how our Application along with the services being provided therein are used. We may also use the combined information without aggregating it to serve you specifically.

• It is hereby clarified to you that to be able to use all features/ services as provided in the Application you shall have to feed into the Application such third-party account credentials as may be required by Application for purposes of signing-in to such services and/ or otherwise (in order for you to take full advantage of the services being provided via the Application, you must provide registration information, including, but not limited to, an e-mail address and password being used on such third-party sites). You hereby agree and understand that some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your Application profile with us. For illustration- one such service may include the ability for you to automatically transmit Third Party Account Information seamlessly amongst various third party profiles or to automatically transmit information into your Application profile from your third-party accounts or vice versa.

• We may also request demographic information, unique identifiers and other location based information in order to provide you with a more personalized service. We might collect this as a part of a survey also. Further we may collect information about your location and calendar in order to provide you with a more personalized service.

• You are responsible for managing the flow of your private information from one third party service to another. If you post Personal Information online that is accessible to the public, that information becomes publicly available and can be collected and used by others, and further redistributed through the internet and other media channels. For purposes of illustration- if you push a private post from Facebook to a public blog, the private post will no longer be private. You may receive unsolicited messages from other parties in return which can not be monitored by the Application control mechanisms and/ or standard security features.

• Payment and billing information. We might collect your billing name, billing address and payment method in the circumstances where you want to purchase or get into any transaction through the services being provided via the Application. It is hereby clarified that we never collect your credit card number/ debit card number, or credit card expiry date/ debit card expiry date, or other details pertaining to your credit card/ debit card on our Application. Credit card/ debit card information will be obtained and processed by our online payment partner [insert online payment partner(s) name] in instances of there being any purchases for the inbuilt services pertaining to intra Application purchases in respect of the Application, and not any third party, other person, other entity whatsoever. All other such purchases or transactions entered into by you (with anyone apart from the Application directly) shall be governed by that third-party site’s policies on such transactions and purchases. It is strongly suggested and advised by us to read such policies of all third parties before entering into a monetary transaction or any such transaction(s) wherein there is sale-purchase of any goods or services or otherwise (For illustration – Facebook marketplace purchase transactions shall be governed by such relevant Facebook policies for the same even though they may be carried out via the services being provided by the Application).

Information Collected From Other Applications/ Websites.

Through cookies we place on your device, we may collect information about your online activity after you leave/ close our Application. This information allows us to improve the services being provided via the Application, simultaneously to customize your online experience on the Application, and/or otherwise, as described in this Privacy Policy. Further, We may collect information in relation to what third-party sites you use and other related analytics for the purpose of our artificial intelligence algorithm to improve user experience. We might also collect the type of mobile device you may be accessing the Application from, or the version of the operating system your device is running.

AGREED AND AUTHORISED WAYS TO COLLECT YOUR INFORMATION

• We collect information directly from you. We collect information directly from you when you download and register as per directions of the Application, subject to Clause 1.2.1.
• We collect information via other tools. We use tracking tools such as, but not limited to, ‘Google Analytics’, ‘Google Webmaster’, browser cookies and web beacons for collecting information about your usage of our Application.
• We get information about you from third parties. For example, but not limited to, if you use the integrated social media feature on our Application there may be inter-se exchange of certain Personal Information, Non-Identifying Information and Third-Party Account Information. The third-party social media site and the Application shall have certain information transmission relevant to you shared with us.

YOU SHALL HAVE ACCESS TO YOUR INFORMATION AT ALL TIMES We will provide you with the means to ensure that your Personal Information is correct and current. You may review and update this information at any time via the Application. You shall be able to:

• View and edit Personal Information you have already given us for the Application profile and/ or view and edit information related to or connected to certain Third Party Account Information and/ or view and edit certain Non-Identifying Information.
• Tell us whether you want us to send you marketing information and/ or what parts of it you would like to receive, or whether you want third parties to send you their marketing offers via your e-mail address provided to us via the Application.
• Sign up for additional electronic newsletters about our Application and/ or services provided therein.
• You can opt out of receiving our marketing emails or other such communications by us at any time. To stop receiving our promotional emails or third-party services’ promotional emails, please email to us at (or follow the procedure as prescribed in the following link); [insert email or such other link]. It may take about 10 (ten) days to process your request.

APPLICATION PROFILE INFORMATION

• Personal Information: We receive and store your [insert information which will be asked from the users like name, email, mobile number, street, city, state, pin code, country, ip address, profile name and photo, online status and status message or such other messages/ bio/ captions/ last seen status]. Personal Information, or parts of such Personal Information, may be made available to anyone who uses our Application (other users from your contacts or otherwise) subject to you authorizing all control through in-built settings of the Application, which will provide you the authority to manage all or parts of such information which should be made available for viewing purposes to other users. For a better user experience you may be asked to provide to us the phone numbers in your mobile address book on a regular basis, including those of both the users of our services provided in the Application, and your other contacts. You hereby confirm you are authorized to provide us such numbers.
• Your Messages and Multi-Media. We do not retain your messages in the ordinary course of providing our inbuilt services to you. Once your messages (including, but not limited to, your chats, photos, videos, voice messages, files, and share location information) are delivered, they are deleted from our servers (subject to such policies of third party service providers whereby their policies might be different from ours as to deletion of your messages). Your messages are stored on your own device. If a message being sent through a third party service or inbuilt service cannot be delivered immediately (for example, if you are offline), we may keep it on our servers for up to 30 days as we try to deliver it (subject to such policies of third party service providers whereby their policies might be different from ours as to days before deletion of your messages). If a message is still undelivered after 30 days, we delete it. To improve performance and deliver multi-media messages more efficiently, such as when many people are sharing a popular photo or video or other such media via the Application or via the services through such third party services being provided therein, we may retain that content/ media on our servers for a longer period of time.
• Your Connections. To help you organize how you communicate with others, we may create a favourites list of your contacts (or any other such equivalent storage list) for you, and you can create, join, or get added to groups and broadcast lists (or such other list) or such other features which provide a seamless user experience amongst different social media services and other third party services as well as inter se the different users of the Application. It is hereby clarified that all such features including, but not limited to, such groups and lists shall be associated with your main Application profile information and may be stored by us.
• Customer Support. You may provide us with information related to your use of our Application and the services, and thereby we may store such relevant information so we can provide you customer support. For example, you may send us an email with information relating to our Application performance or other issues.
• Other information which may be required/ be relevant by the Application/ for the Application but may not be covered herein (subject to terms of this Privacy Policy).

USE OF YOUR INFORMATION ON THE APPLICATION AND FOR SERVICES PROVIDED THEREIN

• Use Of Personal Information, Combined With Different Parts Of Non-Identifying Information And Third-Party Account Information Is Essential For A Seamless Good Quality User Experience. When you access our Application, we collect and store your Personal Information (combined with whole or different parts of Non-Identifying Information and Third-Party Account Information) which is provided by you or obtained by such authorised means as stated in this Privacy Policy. Our primary goal in doing so is to provide you a safe, efficient, smooth and customized experience in respect of the services being provided via the Application as well as to give you better services in the future. Further, your Personal Information combined with whole or different parts of Non-Identifying Information and Third-Party Account Information, is used to administer promotion(s), advertisements, contents, reply to queries of the various authorities in regard to your accessing of the Application and services availed by you. The unique nature of the Application and the services being provided therein mandate use of your information from various sources and the following is an non exhaustive list of uses for any kind of information you provide to us or is obtained by us (as per this Privacy Policy);
  • We use information to contact you: We might use the information related to you, to contact you;
  • We use information to respond to your requests or questions;
  • We use information to improve our products and services. We might use your information to improve or customize your experience with us. This could include, but not be limited to, displaying content based upon your preferences, providing personalised user experience etc;
  • We use information to look at Application and services trends and customer interests. We may use your information to make our Application and services provided therein better. We may combine information we get from you with information about you that we get from third parties;
  • We use information for security purposes. We may use information to protect our company, our users, and the Application;
  • We use information for marketing purposes. We might send you information about promotions or offers. We might also tell you about new features or products. These might be our own offers or products, or third-party offers or products we think you might find interesting;
  • We use information to send you transactional communications. We might send you emails or SMS about your Application profile;
  • We use information as otherwise permitted by law. The Application does not sell or rent your Personal Information to third parties without your explicit consent;
  • Your Contacts may be able to view and subsequently use your information if authorised by you. Other users of the Application, with whom you communicate, may store or reshare your information (including, but not limited to, your phone number or messages) with other persons or third parties on and off our Application and the services being provided therein. You can use the Application settings, and/ or such control features (or such other equivalent feature provided via the Application as well as control mechanisms provided for the services being provided therein), to manage what information the users of our Application and the services being provided therein get to view, with whom you wish to communicate and share information with.

SHARING OF YOUR INFORMATION

• Third parties and External Service Providers as Applicable.
  • We share information with third parties who help us manage the Application and run it successfully. It is hereby agreed by you that you understand that in some circumstances such third parties may be located outside of India.
  • Further, we work with third-party service providers to help us operate, provide, improve, understand, customize, support, and market our Application and the services being provided therein.
  • When we share information with third-party service providers, we require them to use your information in accordance with our instructions and terms of this Privacy Policy (always read with the User License Agreement) or with express permission from you.
  • When you use third-party services that are integrated within our Application and the services provided therein, they may receive information about what you share with them. For example but not limited to, if you use a data backup service integrated with our Services (such as, but not limited to, Google Drive), they will receive information about what you share with them. If you interact with a third-party service linked through our Application and the services being provided therein, you may be providing information directly to such third party(ies). Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services.
  • There may be a number of services offered by external service providers that help you use our Application. It is hereby clarified that, if you in any way choose to use these optional services, and in the course of doing so, disclose information to the external service providers, and/or grant them permission to collect information about you, then their use of your information is governed by their privacy policy.
• Advertising: We aggregate (gather data across all our user's Application profiles) Personal Information, and disclose such information in a non-personally identifiable manner to advertisers and other third parties for commercial purposes. However, in these situations, we do not disclose to these entities any information that could be used to identify you personally subject to disclosures such as your preferences and your general usage of the services provided via the Application. Certain information, such as, but not limited to, your name, email address, password, are never disclosed to marketing advertisers. We also combine certain data/ information amongst the different services provided by us and across devices of our users for these purposes. For example, depending on your Application profile settings (subject to such settings on such third party sites), we show you ads based on information procured by us about your interests, which we can derive from your use of the Application. We may use third-party advertising companies to serve ads on our behalf. Companies advertising on the Application whether on our behalf or such other third party companies, may employ cookies and action tags (also known as single pixel gifs or web beacons), to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous. 
• Other Corporate Entities: We may share much of our data with our affiliates, including personally identifiable information about you, that are committed to serving your online needs and related services, throughout the world. Our affiliates will follow privacy practices which are similar to ours. It is possible that we could merge with or be acquired by another business entity/person. Should such an event occur, you should expect that we would share some or all of your information in order to continue to provide the services via the Application. You will receive notice of such event (to the extent it occurs). 
• We may share information in order to comply with the law or to protect the Application. We will share information to respond to a court order or any requirement under the applicable law. We may also share your information with relevant legal authority if the appropriate government agency or investigative body requests the same. Alternatively, we might also share information as deemed fit by us in cases where we are investigating potential fraud by the users. 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
• We may share information with trusted legal partners. We may also provide certain parts or whole of your Personal Information to our business partners or other trusted entities for the purpose of providing you with information on certain services (or goods) we believe will be of interest to you. You can, at any time, opt out of receiving such communications via the Application.
• We may share your information for reasons not described in this policy. We will always reasonably inform you with an update to this Privacy Policy as and when it occurs.
• Social Networking Services: You may link your Application profile with certain social networking site(s) while making use of the Application and the services being provided therein. In these instances, with your permission and on your behalf, we will share information about your activities on such sites in furtherance of our services being provided via Application, which may include your Personal Information. Through the application of such services, as stated above, we also receive certain information (which may include certain other parts of your Personal Information) in accordance with the privacy settings you have set in your social networking site account.

USE OF COOKIES

We use data collection devices such as ‘cookies’ on the Application and under the services being provided therein to help analyse data in respect of web page flow or otherwise, measure promotional effectiveness, and promote trust and safety. It should be known by you ‘cookies’ are small files placed on your hard drive that assist us in providing the services via the Application. We also use cookies to allow you to enter your password and/ or other Personal Information less frequently during a session of usage or throughout the duration the Application is not logged out of explicitly by you. Cookies can also help us provide information that is targeted to your interests. You are always free to decline our cookies if your device or browser so permits, although in that case you may not be able to use certain features on the Application. Additionally, you may encounter "cookies" or other similar devices on certain areas/pages of the Application that are placed by third parties. We do not control the use of cookies by third parties. By using the Application and the services being provided therein and/or by providing your information, you consent to the collection and use of the information you disclose on the Application in accordance with this Privacy Policy.

CONTROL OF YOUR PASSWORD AND LOGIN INFORMATION

You are responsible for all actions taken with your login information and password, including without limitation any payments made to any other service provider/ third party/ other person via the Application. Therefore we do not recommend that you disclose your Application profile password or login information to any service provider/ third party/ other person. If you choose to share this information with third parties to provide you additional services, you are responsible for all actions taken with your login information and password and therefore should review each third party's privacy policy. If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions.

NO LIABILITY

• If you click on any of the links to third party websites as may be available through the services being provided via the Application, you may be taken to websites and/ or other applications we do not control. This Privacy Policy does not apply to the privacy policies or other such practices of such third-party sites/ applications. We strongly advice and suggest you to read the privacy policy of other websites/ applications carefully. We are not responsible for losses, loss of information, fraud or any kind of liability accruing from such third-party sites or applications or otherwise.
• Further, it is hereby clarified that except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you or obtain (as per the agreed authorisation under this Privacy Policy). To the extent that you disclose your information to other parties, on our Application (or on other applications and/ or sites accessed via the Application), 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 own privacy policies. Since we do not control the privacy policies of third parties, you are subject to ask questions and check their policies before you disclose your Personal Information to anyone except directly to us.
• You hereby understand that the Application does not accept any liability from the you at any time in respect of the use of the Application; and that in no event shall the owner company of the Application be liable to the User for any personal injury or any indirect, special, incidental, consequential, or exemplary damages arising out of, or in any way, relating to this agreement, or the use of or inability to use the software, including, without limitation, damages for lost profits, any other commercial or personal damages or losses, loss or corruption of data or failure or malfunction of any Device(s). The Application owner company shall not be liable to the you in contract, tort or otherwise. It is hereby agreed by the you that your sole remedy under this Agreement (along with the User License Agreement, read together with this Agreement at all times) is to cease use of the Application.

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. However, "perfect security" does not. You, therefore, agree that any security breaches beyond the control of our standard security procedures are at your sole risk.

OUR POLICY TOWARD CHILDREN

The services are not directed to persons under the age of 18 years. We do not knowingly collect personally identifiable information from children under 18 years. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [insert email address]. If we become aware that a child under 18 years has provided us with Personal Information, we will delete such information from our files.

GRIEVANCE OFFICER

In accordance with Information Technology Act, 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Mr. Nishant Shekhar
Phone: +91 7011312584
If for some reason you believe we have not adhered to these Privacy Policy principles, please notify us by email at [insert email address], and we shall do our best to determine and correct the problem promptly. Be certain the words ‘Privacy Policy’ are in the Subject line of such e-mail.

UPDATES TO THIS POLICY

Please note that our Privacy Policy is subject to change at any time without notice. The updates or any form of amendment to this Privacy Policy shall be informed to you via the Application almost simultaneously from when such update is implemented.

JURISDICTION

By browsing, visiting, accessing and/or using the services on our Application (or viewing any of the pages/ parts of the Application on such other device(s) not owned by you), any dispute over privacy is subject to this Privacy Policy and the terms of the User License Agreement (to be always read together). In addition to the foregoing, any disputes arising under this Privacy Policy shall be governed by the laws of India.