Privacy Notice

Last Updated on: June 21, 2024

We, Intangles Lab Private Limited (“Intangles”, “Company”, “we”, “us”, “our”) are the owners and developers of:

1. the Intangles website https://www.intangles.ai/ (the “Website”);
2. web-based automobile fleet management software called Inroute (the “Software”);
3. the Intangles mobile app called Inroute (the “App”); and
4. the telematics device (the “Intangles Solution”); collectively referred to as the “Platform”.

The Platform lets our Users monitor and manage their Vehicles remotely from anywhere in the world. Our Users use the Platform to make more informed decisions regarding their Vehicles.

We respect data privacy rights and are committed to protecting personal information collected on the Platform. This privacy notice (“Privacy Notice”) sets forth how we collect, use, store, process, transfer, share and protect the information that identifies or can identify you on this Platform.

PLEASE READ THIS PRIVACY NOTICE CAREFULLY. BY CONTINUING TO USE THE PLATFORM, PROVIDING US PERSONAL INFORMATION, YOU CONSENT TO OUR USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY NOTICE. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, YOU MAY WITHDRAW YOUR CONSENT OR ALTERNATIVELY CHOOSE NOT TO PROVIDE YOUR PERSONAL INFORMATION ON THE PLATFORM. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL TO intouch@intangles.com.

IF YOU ARE ACCESSING THE PLATFORM ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY NOTICE AND, IN SUCH AN EVENT YOUR USE OF THE PLATFORM SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL INFORMATION OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY NOTICE, THEN YOU SHOULD REFRAIN FROM USING THE PLATFORM.

This Privacy Notice is an electronic record in the form of an electronic contract being compliant and construed in accordance with data protection laws of the jurisdictions where we have our presence.

1. DEFINITIONS

a) Personal Information shall mean and include information that directly, indirectly, or in connection with other information, allows for the identification or identifiability of a natural person. Personal Information including but not limited to name, identification number, residential address, email address, contact number, emergency contact number, blood group, driver name, driver’s driving license number, etc.

b) Non-personal Information shall mean and include information of the Vehicle Information, engine information, chassis number, technical specifications, servicing details, test results, etc.

c) “User(s)”, “you”, “your”, “Customer” shall mean and include individuals, business organizations, commercial establishments, and their permitted users who use the Platform or who may share Personal Information to avail the services through the Platform.

 d) “Vehicle” shall mean and include automobile vehicles that have installed the Intangles Solutions.

 e) “Vehicle Information” shall mean and include information about the Vehicle such as the Vehicle registration number, Vehicle type, Vehicle’s performance, engine and diagnostic data, Vehicle GPS location, odometer readings.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

When the Company receives information from its Customer, the Company acts as a Processor and shall process data as per the instructions received by the Data Controller. If you have any questions related to the handling of your Personal Information by the Company or to exercise your rights, you can contact us at intouch@intangles.com. For Personal Information collected on behalf of Customer please refer to Clause 3 of this Privacy Notice.

We collect your Personal Information in the following cases:

a) Website: When you get in touch with us through our ‘contact us’ page on our  Website or subscribe to our blogs/newsletters, you are required to provide us with information including but not limited to your full name, e-mail address, company’s name, resume, job application details, mobile number etc.

b) Intangles Solution: When you purchase, use or install the Intangles Solution in your Vehicle, we may collect information, including but not limited to:

• Information of Vehicle owners: Vehicle owner’s name, email address, residential address;
• Vehicle related Information: Vehicle registration number and Vehicle location;
• Information of Vehicle driver: driver location, driver details (driver name, driver’s driving license number or equivalent identification, contact number, emergency contact number), blood group;
• Video telematics data: This technology provides real-time video recordings from cameras installed in the Vehicle which involves collection of driver performance information, driver behavior monitoring, in-vehicle CCTV footage etc.

c) User Account: To use our Platform, you must set up an account (“User Account”) with us. To create the User Account, you will be required to provide Personal Information including but not limited to name, address, phone number, email address, unique username, corporate name etc.

d) App: If you install or use our App, we may collect certain Personal Information from you including but not limited to your full name, email address, login ID, password, contact number, driver Details (driver name, driver’s driving license number or equivalent identification, contact number, emergency contact number), blood group, driver performance information, driver behavior monitoring, in-vehicle CCTV footage etc. We may also collect information of your device including but not limited to device name, model number, device type, IP address, operating system, device compatibility etc.

e) Employees and Job Applications: If you work with us or you are a job applicant and apply for a job at Intangles (“Applicant”), we collect your Personal Information you provide to us. We may collect Personal Information about you including but not limited to your name, resume, phone number, and email address.

f) Social media accounts: We may also collect, store and use your Personal Information when you (1) access our social networking handles operated by us on Facebook, Twitter, and/or LinkedIn (2) share our blogs through Facebook, Twitter, and/or Linkedin and (3) comment/ provide feedback/testimonials on such social networking handles.

g) Payment Information: You may have an option to make purchases through our Platform and we may collect certain information including but not limited to full name and email address to process your request. You will be required to provide certain payment information directly to our payment processing partners, including but not limited to your name, credit/debit card/bank information. We do not access, store or collect your credit/debit card information or payment related sensitive information.

3. WHAT PERSONAL INFORMATION DO WE PROCESS ON BEHALF OF THE CUSTOMER?

This section concerns the Personal Information of the User collected by the Customer, and such collection may be facilitated by us.

a) The Company as a Data Processor: The Customer sets the purpose and means of processing of such Personal Information. We process such Personal Information only on behalf of and on the instructions of the Customer and for the purpose of rendering our services to the Customer.

b) Customer Privacy Notice: If you are the User of the Platform and your Personal Information was shared with us by the Customer, the privacy notice of the Customer, on whose behalf we collect and process the Personal Information, will apply. This means that any enquiry, request, objection or complaint that you as a User may have in connection with the collection and/or processing of Personal Information that forms part of your Platform usage should be addressed to and resolved by the Customer.

c) Personal Information: Depending on the nature of services and Customer requirements the Company processes Personal Information on behalf of Customer/s.

d) When you purchase, use or install the Intangles Solution in your Vehicle, we may collect information, including but not limited to:

• Information of Vehicle owners: Vehicle owner’s name, email address, residential address;
• Vehicle related Information: Vehicle registration number and Vehicle location;
• Information of Vehicle driver: driver location, driver details (driver name, driver’s driving license number or equivalent identification, contact number, emergency contact number), blood group;
• Video telematics data: This technology provides real-time video recordings from cameras installed in the Vehicle which involves collection of driver performance information, driver behavior monitoring, in-vehicle CCTV footage etc.
• User Account: To use our Platform, you must set up an account (“User Account”) with us. To create the User Account, you will be required to provide Personal Information including but not limited to name, address, phone number, email address, unique username, corporate name etc.

Further, the Personal Information collected on behalf of the Customer, may differ based on the specific requirements, Intangles remains solely the data processor and the customer is responsible to provide adequate privacy notices. 

The Customer has complete control over the Personal Information and the Company processes the Personal Information on the Customer’s behalf.

• Customer Responsibility: The Customer represents that it has acquired all necessary consents and/or relies on other appropriate legal basis for the processing of Personal Information of end-Users. Customer confirms that end-Users have been informed about that their Personal Information is transferred to the Company as a processor and other third parties used by the Company for the provision of Services.

We will process the Personal Information for as long as we provide services to the Customer and the Customer maintains active accounts of such Users.

4. ACCURACY OF INFORMATION: 

User undertakes that he shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Information shared with us whether of its own or any third party. In the event the User is sharing any Personal Information on behalf of a third person, the User represents and warrants that he has the necessary authority to share such Personal Information with the Company, obtained a written consent from such third party and the Company shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Information shall be subject to the terms and conditions of this Privacy Notice.

5. WHAT DO WE DO WITH YOUR PERSONAL INFORMATION?

We use the Personal Information for the following purposes:

a) To inform you about our services and to respond to your request(s).

b) To provide you real time updates including those of the Vehicle, Vehicle performance and health, Vehicle maintenance, Vehicle error etc.

c) To provide video telematics data to our customers for the purpose of safety monitoring, to analyze performance of the driver, and investigate incidents.

d) To provide you real time updates of the driver, driver and Vehicle location, performance, cases of over speeding, unscheduled driving and stoppages etc.

e) To provide services to our customers where we process personal Information on behalf of customers.

f) To generate a driver scorecard based on various vehicle related metrics (Mileage , Idling Duration, Over Speeding Counts, Hard Braking) which are captured using to enable the Customer make decisions regarding incentives for performance and allocation of work.

g) For creation or development of business intelligence or data analytics in relation to the services provided by us.

h) To improve the services on our Platform.

i) To process job applications (if you apply for a position with our organization).

j) To maintain and manage our Platform.

k) To manage our relationship with you.

l) For internal record keeping.

m) To comply with our legal or statutory obligations.

n) To enable your access to the Mobile App and Website.

o) To send you transactional messages.

6. COOKIES

A cookie is a small piece of data stored on your computer or mobile device by your web browser (“Cookie/s”). We use Cookies to identify the users who visit our Website. We use Cookies to enhance the performance and functionality of our Website and App. Without the Cookies, certain functions may become unavailable or you would be required to login every time you visit the Website or App. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access all the functions of our Website correctly or at all.

a) Types of Cookies Used

• Permanent cookies – Permanent cookies help us recognize you as an existing user, so it’s easier for you to return to the website without signing in again. After signing in, the permanent cookies stay on your browser and will be read when you return to our sites. These remain on your computer/device for a pre-defined period.
• Session cookies – Session cookies only last for as long as the session exists (they get erased when the user closes the browser).

As for the domain to which it belongs, there are either:

• First-party cookies: These cookies are set by the web server of the visited page and share the same domain.
• Third- party cookies: These cookies are placed by third party on your device and may provide information to us and third parties about your usage of the website.
• Analytical Tools:
  • Google Analytics: We use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, text files that are stored on your computer and enable analysis of your use of the website. The information generated by the cookies about your use of the website are usually transferred to a server of Google in the US and stored there. We do not control third party cookies.  You can also prevent the data generated by the cookie and related to your use of the website to Google and the processing of these data by Google, by visiting the following link. (https://tools.google.com/dlpage/gaoptout).
  • Google Maps API: Google Maps API is a robust tool that can be used to create a custom map, a searchable map, check-in functions, display live data synching with location, plan routes, or create a mashup just to name a few. Google Maps API may collect information from You and from Your Device for security purposes. Google Maps API collects information that is held in accordance with its Privacy Notice. 
  • Mixpanel: Mixpanel is a business analytics service company. It tracks user interactions with web and mobile applications and provides tools for targeted communication with them. Data collected is used to build custom reports and measure user engagement and retention. Mixpanel collects the information in accordance with their data privacy notice.
  • Hotjar: Hotjar is a powerful tool that reveals the online behaviour and voice of your users. By combining both Analysis and Feedback tools, Hotjar gives you the ‘big picture’ of how to improve your site’s user experience. Hotjar collects the information in accordance with its Privacy Notice.

b) Use of Cookies

We use Personal Information captured through cookies to make your interaction with us faster and more secure. They may be used for the following purposes:

• Preferences –Cookies allow the Website to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in. Remembering your preferences enables us to personalize and display advertisements and other content for you.
• Security/Optimization – Cookies allow us to maintain security by authenticating users, preventing fraudulent use of login credentials and protect user data from unauthorized parties. We may use certain types of cookies to allow us to block many types of attacks, such as attempts to steal content from the forms present on the website.
• Processing –Cookies enable the website to work efficiently. Basis such cookies, we are able to deliver services that a website visitor expects, like navigating around web pages or accessing secure areas of the website.
• Advertising –We use cookies to make advertising more engaging for our users. Some common applications of cookies are made to select advertising based on what’s relevant to you, to improve reporting on campaign performance and to avoid showing ads you would have already seen. Cookies capture information about how you interact with the website, which includes the pages that you visit most.
• Communication –We may use information collected via cookies to communicate with you, for sending newsletters, seeking your opinion and feedback and providing you services and promotional materials.
• Analytics and Research –We may use cookies to better understand how people use our Offerings so that we can improve them.

c) Disabling Cookies

You can decide whether to accept or not to accept cookies. You can disable the cookies by adjusting the settings on your browser (see your browser Help for how to do this). Disabling cookies may affect the functionality of our website.

7. ANONYMISED DATA

We may anonymise and aggregate your Personal Information that we have collected (so that we can no longer identify you, directly or indirectly). We may use such anonymised information for purposes that include testing our IT systems, research, data analysis, improving our services and developing new products and features. We may also share such anonymised and aggregated information with others.

8. WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

We do not sell, rent, share, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Information in the following cases:

• Affiliates: We may provide your Personal Information to our affiliates to enable them to improve our services, provide feedback and respond to their queries.
• Service Providers: We may share your Personal Information with the service providers who work with us in connection with operating the Platform and/ or providing the service. All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Notice.
• Merger or Acquisition: We may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Platform, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.
• Legal and Regulatory Authorities: We may disclose your Personal Information in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.
• Security and Emergency Situations: We may also disclose Personal Information if we determine in good faith that disclosure is necessary to protect our rights, resolve legal conflict, enforce our terms and conditions, investigate fraud or protect our Users. We may also use or share your Personal Information in the event of an incident, or where we otherwise reasonably believe that the processing of your Personal Information will prevent or reduce any potential harm to you or others.

9. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION?

We endeavor to only collect such Personal Information that is necessary for the purposes indicated here, and to retain such Personal Information for no longer than is necessary for such purposes. The length of time Personal Information is retained, and criteria for determining that time, are dependent on the nature of the Personal Information and the purpose for which it was provided/ collected.

Subject to this section, we will try to delete your Personal Information upon reasonable written request for the same. Please note, however, that there might be latency in deleting Personal Information from our servers and backed-up versions might exist even after deletion. For more information on where and how long your Personal Information is stored, and for more information on your rights of erasure and portability, please contact intouch@intangles.com.

10. OUR SECURITY MEASURES AND STORAGE FACILITIES

Our Platform employs a number of current technology security measures to protect the security of Personal Information. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. All Personal Information is accessible only to authorized personnel. Although we provide appropriate firewalls and protections, we cannot warrant the security of Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events. You are required to be careful to avoid “phishing” scams, where someone may send you an e-mail that looks like it is from us asking for your personal information.

11. YOUR RIGHTS

Depending on the nature of your request, we may ask you to complete a Personal Information request form or seek certain details to verify the request. In certain cases, we may charge a fee for this service, but we will inform you at the time. All requests for Personal Information will be handled within a reasonable period of time. If you would like to exercise ANY of your rights, please contact us at intouch@intangles.com.

In accordance with applicable law, you have the following rights in respect of your Personal Information:

a) Right of access: You have the right to obtain access to your Personal Information. This includes the right to obtain:

• confirmation of whether we are processing your Personal Information;
• information about the categories of personal information we are processing, the purposes for which we process your Personal Information and information as to how we determine applicable retention periods;
• information about the categories of recipients with whom we may share your Personal Information and if those recipients are located in third countries; and
• a copy of the Personal Information we hold about you.

b) Right of portability: You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person.

c) Right to rectification: You have the right to rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay. However, you understand and agree that we do not hold any responsibility towards the accuracy or authenticity of the user information which you have submitted or we have collected through your use of our service.

d) Right to erasure: You have the right to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified. If you wish to not agree to this Privacy Notice, you can request us to delete your account with us by writing to us at the above mentioned email address. On receiving such deletion request, we will delete Personal Information about you that we have collected within a reasonable time.

e) Right to object: You also have the right to object to any processing based on our legitimate interests, at any time, where your objection is raised on grounds relating to your particular situation. In the event you decide to object to the processing of your Personal Information, we will stop processing Personal Information concerning you, unless we can demonstrate compelling reasons for continuing to process your Personal Information that override your interests, rights and freedoms, or where we process your Personal Information to establish, exercise, or defend our legal claims. You can object to direct marketing activities for any reason at any time.

f) Right to withdraw consent: We do not need your consent for all of the processing activities we undertake. However, if we rely on your consent as the lawful basis for our processing and you have provided such consent for the processing of your Personal Information, you have the right to withdraw your consent at any time. If you withdraw your consent this will not affect the lawfulness of our use of your Personal Information before your withdrawal. You can withdraw your consent to the processing of your Personal Information by writing to us using contact details provided at the end of this Privacy Notice. However, you will be required to cease further use of our service and the Platform as we may not be able to continue to provide you with the same without accessing the limited amount of Personal Information we collect, process and use.

g) Right to lodge a complaint: You also have the right to lodge a complaint to a competent data protection authority.

12. CHOICE AND OPT-OUT

We may send you communications including but not limited to (a) notices about your use of our Platform and services, including those concerning violations of use, (b) updates, (c) promotional information regarding our Platform, and (d) newsletters. You may opt out of receiving promotional emails and newsletters from us by following the unsubscribe instructions provided in those emails. Alternatively, you can opt out, at any time, by emailing intouch@intangles.com with your specific request.

13. INFORMATION FOR PHILIPPINES USERS:

• Applicability of Privacy Laws: The Data Privacy Act 2012 (“DPA”) and the Implementing Rules and Regulations of the Data Privacy Act of 2012 (“Rules”), apply to Us when we Process Personal Information provided by Users from Philippines.
• Method and Logic used for Automated Processing: The driver scorecard is generated by Intangles Solution based on various vehicle related metrics which are captured using the IoT device deployed on the particular vehicle. The metrics which are predominantly related to vehicle performance are as follows, Mileage (km/L), Idling Duration, Over Speeding Counts, Hard Braking. The metrics shared are illustrative and non-exhaustive.
• Consequences of Automated Processing: The decisions made through automated processing will not significantly impact the data subject’s rights. The following decisions can be made by Intangles customer (fleet owner) in the capacity of a PIC:
  • Incentives for performance
  • Allocation of work
• File a Complaint: If you feel that your personal information has been misused, maliciously disclosed, or improperly handled, or that any of your data privacy rights have been violated, you may file a complaint with the National Privacy Commission through their website: https://privacy.gov.ph.
• Inquiries: All requests for Personal Information will be handled within a reasonable period of time. If you would like to exercise ANY of your rights, please contact us at intouch@intangles.com.
• Privacy Registration Seal: You can find our Privacy Registration Seal here.

14. INFORMATION FOR CANADA USERS

• Applicability of PIPEDA: This Privacy Notice is subject to the Canada Personal Information Protection and Electronic Documents Act (the “PIPEDA”).
• Personal Information: Personal Information provided by Users of the Platform is information about an identifiable individual. Personal Information does not include business names and business contact information used in a commercial context.
• Accuracy of Personal Information: We will take reasonable efforts to ensure that Personal Information collected by us or on our behalf is accurate and complete.
• Withdrawal of Consent: As per the PIPEDA upon reasonable notice given by You about the withdrawal of Your consent given with respect to the collection, use or disclosure of Personal Information, We will inform You of the likely consequences of withdrawing this consent and will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the Personal Information, unless it is required or authorized under applicable laws.
• Transfer of your Personal Information outside of Canada: We will ensure that the transfer of Personal Information is as per the requirements of PIPEDA.
• Inquiries: If you have any concerns, enquiries or complaints related to your Personal Information. Please contact us intouch@intangles.com.

15. CALIFORNIA RESIDENT RIGHTS

• Applicability of Privacy Laws: We are bound by the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) for personal information provided by users from California on our Platform.
• Your Privacy Rights: As a California resident, you have specific rights regarding your personal information:
  • Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell.
  • Right to Delete: You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
  • Right to Opt-Out: You have the right to opt-out of the sale of your personal information. We do not sell personal information, but if this practice changes, we will update this policy and provide a clear opt-out mechanism.
  • Right to Non-Discrimination: You have the right to not receive discriminatory treatment for exercising any of your privacy rights.
• Exercising Your Rights: To exercise your rights, please contact us at intouch@intangles.com. We will respond to your request within 45 days as required by law. You can also designate an authorized agent to make a request on your behalf.
• Transfer of Your Personal Information: We will ensure that the transfer of personal information is in compliance with the CCPA/CPRA requirements. We do not sell, rent, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent.
• Inquiries and Complaints: If you have any concerns or complaints about our privacy practices or this Privacy Notice, you may contact us at intouch@intangles.com. We will respond to your concerns/complaints within a reasonable period. If you are not satisfied with how your complaint has been addressed, you have the right to lodge a complaint with the California Attorney General’s office if you believe we have not used your personal information in accordance with the CCPA/CPRA.

16. INFORMATION FOR EU AND UK INDIVIDUALS

• Applicability of Privacy Laws: Residents of the European Union (the “EU”) and United Kingdom (the “UK”) should note that this Privacy Notice has been updated in accordance with the requirements of the EU General Data Protection Regulation (the “GDPR”) and the UK GDPR, the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing (the “UK Privacy Laws”). As per the provisions of the GDPR and UK Privacy Laws we shall be considered the Controllers of the Personal Information collected as a result of your use / access of the Platform.
• Legal Basis (for EU residents and UK residents):We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal bases of consent, contract, or on the basis of our legitimate interests, provided that such interests are not overridden by your privacy rights and interests.
• Transfer of your Personal Information across borders (for EU Residents): The Personal Information we collect (of the EU and the UK residents) might be processed outside the EU and the UK at a secure center located in India. We collect and transfer Personal Information outside the EU and the UK in accordance with the provisions of the GDPR and the UK Privacy Laws. If you have questions, please contact intouch@intangles.com .
• Your Rights (For EU and UK Residents):
  • Right to Access: As an Individual, you have the right to access your Personal Data being processed by us and understand the purpose, recipients to whom your Personal Data has been disclosed and the envisaged period of retention of Personal Information.
  • Right to Rectification/Modification: You have the right to rectify any inaccuracy in your Personal Data obtained and being processed by us.
  • Right to Erasure: You have the right to get your Personal Data erased on grounds of completion of purpose, withdrawal of consent, unlawful processing of data or pursuant to exercise of right to restrict processing or any statutory requirement.
  • Right to Restriction of Processing: You have the right to require us to restrict processing of your Personal Data on grounds where you contest the accuracy of the Personal Data being processed and in case of unlawful processing among others.
  • Right to Data Portability: You have the right to receive your Personal Data collected and being processed by us in a structured, commonly used and machine-readable format and have the right to transmit such Personal Data to another controller without any hindrance from us when processing of Personal Data is based on consent and where processing is carried out by automated means.
  • Right to Object to Processing: You have the right to object to the processing of your Personal Data on grounds and if such Personal Data is being processed for direct marketing purposes.
  • Right to Lodge Complaints: Where you believe that we have violated or presented a potential risk to your right to privacy, you have the right to lodge a complaint with the supervisory authority under the applicable regulations.
  • Right to Withdraw Consent: You may at any time withdraw your consent by writing to us.
• Governing Laws: For any EU and UK residents, this Privacy Notice shall be governed respectively by the provisions of the GDPR and UK Privacy Laws.
• Inquiries or Complaints: UK residents have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity or also contact you for further information in relation to your request. If you would like to exercise ANY of these rights, please contact intouch@intangles.com.

17. INFORMATION FOR TURKISH USERS

• Applicability of Privacy Laws: We are bound by the Law on Protection of Personal Data No. 6698 (Turkish LPPD) for Personal Information provided by Users from Turkey on our Platform.
• Transfer of your Personal Information outside of Turkey: We will ensure that the transfer of Personal Information is as per the requirements of Turkish LPPD.
• Inquiries and Complaints: If you have any concerns or complaints about our privacy practices or this Privacy Notice, you may contact us at intouch@intangles.com. We will respond to your concerns/complaints within a reasonable period. If you are not satisfied how your complaint has been addressed, you have the right to lodge a complaint with the Turkish Data Protection Authority (KVKK) if you think we have not used your personal information in accordance with the Turkish LPPD.

18. INFORMATION FOR UAE USERS

• Applicability of Privacy Laws: We are bound by the Federal Decree by Law No. (45) of 2021 Concerning the Protection of Personal Data for Personal Information provided by Users from UAE on our Platform.
• Transfer of your Personal Information outside of UAE: We will ensure that the transfer of Personal Information is as per the requirements of the applicable privacy laws of UAE.
• Inquiries: If you have any concerns or complaints about our privacy practices or this Privacy Policy, you may contact us at intouch@intangles.com. We will respond to your concerns/complaints within a reasonable period.

19. INFORMATION FOR SAUDI ARABIA USERS

• Applicability of Privacy Laws: We are bound by the Personal Data Protection Law (“PDPL”) and the Implementing Regulation of the Personal Data Protection Law (“IR”) for Personal Information provided by Users from the Kingdom on our Platform.
• Transfer of your Personal Information outside of the Kingdom: We will ensure that the transfer of Personal Information is as per the requirements of the PDPL and its IR.
• Inquiries: If you have any concerns or complaints about our privacy practices or this Privacy Policy, you may contact us at intouch@intangles.com. We will respond to your concerns/complaints within a reasonable period.

20. INFORMATION FOR MEXICAN USERS

• Applicability of the Federal Law for the Protection of Personal Data (“LFPDPPP”): The LFPDPPP applies to Us when we Process Personal Information provided by Users from Mexico.
• File a Complaint: If you have any concerns about our handling of your personal data or believe your LFPDPPP rights have been violated, you have the right to lodge a complaint with the National Institute for Transparency, Access to Information and Personal Data Protection (INAI), the Mexican data protection authority.
• Inquiries: All requests for Personal Information will be handled within a reasonable period of time. If you would like to exercise ANY of your rights, please contact us at intouch@intangles.com.

21. INFORMATION FOR KENYA USERS

• Applicability of Privacy Laws: To the extent applicable to us, we are bound by the laws of Kenya, including the Data Protection Act, 2019, and any applicable data protection rules and regulations.
• Rights of individuals:

Individuals from Kenya have the following rights with regard to processing of their personal data.

• • Right to be informed
  • Right to access
  • Right to rectify
  • Right of erasure
  • Right to restriction of processing
  • Right to data portability
  • Right to object
  • Right against Automated Individual Decision Making

• Inquiries or Complaints: If you have any concerns or complaints about our privacy practices or this Privacy Notice, you may contact us at intouch@intangles.com. We will respond to your concerns/ complaints within a reasonable period.
• File a Complaint: If your concern/ complaint remains unaddressed or you are not satisfied with the response/ resolution, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) at odpc.go.ke.

22. INFORMATION FOR MALAYSIA USERS

• Applicable Privacy Laws: The Personal Data Protection Act 2010 (‘PDPA’) of Malaysia is the primary legislation of data to govern matters of data protection.
• Exercising Your Rights:

You can exercise the following rights under the PDPA:

• • the right of access to personal data;
  • the right to require a data user to correct personal data;
  • the right to withdraw consent to the processing of personal data;
  • the right to prevent processing likely to cause damage or distress; and
  • the right to prevent processing for direct marketing purposes.

• File a Complaint: If you are of the opinion that your personal data has been misused, then you may lodge a complaint online on the Commissioner’s website: https://daftar.pdp.gov.my/paduan.

23. CHILDREN’S PRIVACY

This Platform is not meant for any person below the age of 16 years. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and you become aware that a child has provided us with Personal Information, please contact us at the below mentioned email address. If we become aware that we have collected Personal Information from anyone under the age of 16, we take the necessary steps to remove such Personal Information from our servers without any undue delay.

24. LINKS TO OTHER WEBSITES/APPLICATIONS

Our Platform may contain links to other third-party websites/applications of your interest. This Privacy Notice does not apply to those websites. We do not have any control over such other websites/applications, and you will be accessing these websites/applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/applications and those are not governed by this Privacy Notice. We strongly recommend that you exercise caution and look at the privacy notice applicable to such websites/applications.

We use certain third-party services, such as Mixpanel, Google Maps and Hotjar, to provide our service. As a result of use of such services, certain additional information may be collected and processed by Mixpanel, Inc., Google LLC and Hotjar Ltd. in accordance with their own respective policies relating to privacy, which may be accessed from their respective websites, including the following URLs:

• Mixpanel- To access the applicable privacy notice click here;
• Google Maps- To access the applicable privacy notice click here;
• Hotjar- To access the applicable privacy notice click here;

25. GOVERNING LAWS AND DISPUTES

This Privacy Notice shall be construed and governed by the laws of India without regard to principles of conflict of laws. Any dispute arising, between you and us, shall be submitted to the arbitration to be conducted in Pune, India in the English language, in accordance with the rules of Arbitration and Conciliation Act of 1996, by a sole arbitrator, who shall be appointed by us, and the award made in pursuance thereof shall be binding on you and us. Subject to the arbitration provisions, you agree that the courts in Pune, India shall have exclusive jurisdiction over such disputes.

26. CHANGES TO THIS NOTICE

We may update this Privacy Notice from time to time and you are encouraged to check this Privacy Notice on a regular basis to be aware of the changes made to it.

27. CONTACT US AND GRIEVANCE REDDRESSAL

If you have any questions or concerns or grievances regarding this Privacy Notice, you can reach out to our appointed Data Protection Officer/ Grievance officer, Neil Unadkat via email at dpo@intangles.com.

Address: Intangles Lab Pvt. Ltd. 9th Floor, Orville Business Port, Viman Nagar, Pune, Maharashtra, India – 411014.