Last Updated on: 24th July 2024
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INTRODUCTION
This Privacy Policy describes how Atrox Fortuna (“we”, “us”, “our”) collects, uses, stores, shares, and protects your personal information when you visit or use our website, www.unwritten.deals (the “Platform”). We are a company based out of India and are committed to safeguarding your privacy in accordance with the Digital Personal Data Protection Act, 2023 (DPDPA) and the Information Technology Act, 2000 and its rules .
This Privacy Policy is an electronic record in the form of an electronic contract under the Information Technology Act, 2000 and does not require any physical, digital, or electronic signature .
By accessing or using our Platform, you consent to the collection, processing, storage, and sharing of your personal data as described in this Privacy Policy. If you do not agree with the terms of this policy, please do not use our Platform.
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DEFINITIONS
– “Data Principal” means the individual to whom the personal data relates.
– “Data Fiduciary” means Atrox Fortuna, which determines the purpose and means of processing personal data.
– “Data Processor” means any person or entity that processes personal data on our behalf.
– “Personal Data” means any information relating to an identified or identifiable natural person.
– “Processing” means any operation performed on personal data, whether or not by automated means.
– “Sensitive Personal Data” is a sub-set of personal information that is given a higher level of protection, such as information relating to racial or ethnic origin, political opinions, religion, health information, or biometric information .
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DATA PROTECTION PRINCIPLES
We promise to follow the following data protection principles:
– Lawfulness, Fairness, and Transparency: Our processing activities will have lawful grounds and we will always consider your rights before processing personal data.
– Purpose Limitation: Our processing activities will fit the purpose for which personal data was gathered.
– Data Minimization: We will only gather and process the minimal amount of personal data required for any purpose.
– Storage Limitation: We will not store your personal data for longer than is necessary for the purposes for which it was collected.
– Accuracy & Integrity: We will do our best to ensure the accuracy of data and maintain its security and confidentiality .
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TYPES OF PERSONAL DATA WE COLLECT
We may collect the following categories of personal information from you :
– Identity & Contact Data: This includes your name, email address, phone number, postal address, and any other information you provide us when creating an account, subscribing to our newsletter, or contacting us.
– Technical and Usage Data: When you visit our Platform, we automatically collect certain information about your device and usage, such as your IP address, browser type, operating system, geo-location data, time zone, and your interactions with the Platform (including pages viewed, links clicked, and search queries) .
– Transaction Data: If you engage in any transactions on our Platform, we may collect details about the transaction, including payment history and purchase information.
– Marketing and Communications Data: This includes your preferences for receiving marketing from us and your communication preferences.
– User-Generated Content: Any content, including comments, feedback, or messages you post on our Platform .
We do not actively request sensitive personal data (e.g., passwords, financial data) unless it is strictly necessary for providing a specific service, and we will always obtain your explicit consent before doing so .
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HOW WE COLLECT YOUR PERSONAL DATA
We collect personal data in the following ways:
– Directly from You: You provide most of your personal data when you register, create an account, subscribe, participate in surveys, or communicate with us (via email or the Platform’s contact forms).
– Automatically: As you navigate our Platform, we collect technical data automatically through the use of “cookies” and similar technologies.
– From Third Parties: We may receive personal data about you from our trusted partners, such as analytics providers or marketing partners, who have confirmed they have the legal grounds to share that information with us .
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COOKIES AND TRACKING TECHNOLOGIES
We and our third-party partners use cookies and similar technologies (such as web beacons and pixels) to analyze customer behavior, administer the website, and collect information about users . This is done to personalize and enhance your experience with us .
We use the following types of cookies:
– Necessary Cookies: These are required for you to use some important features on our website, such as logging in.
– Functionality Cookies: These make using our service more convenient and provide more personalized features.
– Analytics Cookies: These are used to track the use and performance of our website and services (e.g., Google Analytics) .
– Advertising Cookies: These are used to deliver advertisements relevant to you and to limit the number of times you see an advertisement. These may be placed by advertising networks with our permission .
You can control and manage cookies at your browser level. Choosing to disable cookies may hinder your use of certain functions. You can also opt out of targeted advertising by visiting the Digital Advertising Alliance’s opt-out portal or the Google Analytics opt-out page .
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HOW WE USE YOUR PERSONAL DATA
We use your personal data for the following purposes, on the basis of our legitimate interests, to fulfill a contract with you, or with your consent :
– To provide, operate, and improve our Platform, products, and services.
– To create and manage your account and provide customer support.
– To process transactions and send you related information, including confirmations and invoices.
– To communicate with you, respond to your queries, and provide updates about our services .
– To send you marketing communications, newsletters, and promotional offers that we believe may be of interest to you (you can opt-out anytime).
– To analyze Platform usage, measure promotional effectiveness, and conduct market research.
– To detect, prevent, and investigate fraudulent or illegal activities, and protect the security of our Platform .
– To comply with legal and regulatory obligations .
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SHARING AND DISCLOSURE OF YOUR PERSONAL DATA
We do not sell, rent, or trade your personal data with third parties for their marketing purposes. However, we may share your personal data in the following circumstances :
– With Service Providers: We share your personal data with trusted third-party service providers who perform services on our behalf, such as:
– Payment processors to handle transactions .
– Data analytics and marketing providers (e.g., Google Analytics, Meta Pixel) to understand user behavior and for advertising purposes .
– IT service providers, web hosting providers, and delivery partners .
– These service providers have access to your personal information needed to perform their functions but are contractually obligated to process it only on our behalf and in compliance with this Privacy Policy .
– With Affiliates and Business Partners: We may share your information with our partners, including affiliate networks (such as Rakuten, ShareASale, Impact) for the purpose of providing and managing affiliate offers. When you interact with these affiliate sites or services, you will be subject to their privacy policies .
– For Legal Compliance and Protection: We may disclose personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to:
– Comply with a legal obligation, subpoena, or court order .
– Enforce our Terms of Use or this Privacy Policy.
– Protect the rights, property, or safety of Atrox Fortuna, our users, or the public .
– In Business Transfers: If we are involved in a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction. You will be notified via email and/or a prominent notice on our Platform of any change in ownership or uses of your personal information .
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INTERNATIONAL DATA TRANSFERS
We primarily store and process your personal data within India. However, as we may use service providers located in other countries, your data may be transferred to, and processed in, countries outside of India . When we transfer your personal data, we ensure that appropriate safeguards are in place to protect your information and that the transfer complies with applicable data protection laws .
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DATA RETENTION
We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy and to fulfill our legal obligations . Once the purpose of processing is served, or when you withdraw consent, we will erase or anonymize your personal data, unless its retention is necessary for compliance with any law .
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YOUR DATA PRINCIPAL RIGHTS
Under the Digital Personal Data Protection Act, 2023, you have the following rights concerning your personal data :
– Right to Access: You have the right to request information about, and access to, the personal data we hold about you.
– Right to Correction: You have the right to request correction of inaccurate or incomplete personal data.
– Right to Erasure: You have the right to request the erasure of your personal data in certain circumstances.
– Right to Withdraw Consent: You have the right to withdraw your consent for processing your personal data at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal .
– Right to Grievance Redressal: You have the right to have your grievances redressed with respect to the processing of your personal data.
– Right to Nomination: You have the right to nominate another individual to exercise your rights in the event of your death or incapacity .
To exercise any of these rights, please contact our Grievance Officer using the contact details provided below. We will respond to your request in accordance with the applicable law.
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SECURITY PRECAUTIONS
We have implemented reasonable physical, electronic, and managerial procedures to protect the loss, misuse, and alteration of the information under our control . We use secure protocols for communication (such as HTTPS) and ensure that our data processing and storage systems are secure . However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security .
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LINKS TO OTHER WEBSITES
Our Platform may contain links to other websites, including our affiliate partners. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including their collection of your personal information. We encourage you to read the privacy policies of every website you visit .
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CHILDREN’S PRIVACY
Our Platform is not intended for use by children under the age of 18. We do not knowingly collect or process personal data from children without verifiable parental consent. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information from our records .
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CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Privacy Policy at any time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date at the top. You are advised to review this Privacy Policy periodically for any changes .
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GRIEVANCE REDRESSAL
In accordance with the DPDP Act and the Information Technology Act, 2000, if you have any questions, concerns, complaints, or wish to exercise your rights regarding this Privacy Policy or the processing of your personal data, please contact our Grievance Officer:
Email – ceo@atroxfortuna.com
We will strive to resolve your grievance at the earliest, within the timeframes prescribed by law.