PRIVACY POLICY
Nudgeme Technologies Private Limited (and/or its affiliates) (“Company” or “we” or “us”, and their respective connotations) respects your privacy, and we are committed to protecting it through this privacy policy (“Privacy Policy”), and our compliance with all applicable laws and related regulations.
We have created this Privacy Policy to inform you of our policies regarding the collection, processing, management and disclosure of personal information (“Personal Information” or “Personal Data”, or any other similar term as per applicable laws), as well as the rights and choices you may have in relation to our use of your Personal Information. For any requests or inquiries in relation to this Privacy Policy, please see the ‘Contact Us’ section below.
The information on this page applies to the Personal Information we collect about your interactions, use, and experience with our website at ‘ www.nudgenow.com ’, and our proprietary platform called ‘Nudge’ (collectively, the “Platform”).
About our Services
We are engaged in the business of providing certain services through the Platform, including but not limited to services that help our Customer’s (defined below) maximize their user lifetime value and improve customer retention through personalised user experiences (“Services”).
About our Privacy Policy
The Platform gathers certain information with prior consent from the following: the users utilising the Platform to avail Services, i.e., companies and brands (“Customers”), and any other visitors of the Platform, with or without the intent of availing our Services (collectively “Users” or “You”, and its respective connotations).
This Privacy Policy is meant to help Users understand what information we collect, why we collect it, what information we disclose, and how Users can update, manage, export, and delete their information collected by us, including Personal Information. This Privacy Policy shall be read in conjunction with our terms of service and/or the relevant service agreement or order form signed between the Company and any person on whose behalf you will avail the Services, and applicable laws.
Your Consent
Our Services are intended for adults who have achieved the age of majority. You hereby confirm that you have read, understood, and agreed to the terms outlined in this Privacy Policy. By accessing or using the Platform, or by availing the Services, or by providing your consent when prompted, you hereby agree and acknowledge that you have read, understood and agreed to the terms as provided in this Privacy Policy once you provide your consent or continue using the Platform after this Privacy Policy is presented to you. By granting your assent to this Privacy Policy, you provide consent to the processing, use, collection and disclosure of Personal Information in the manner prescribed in this Privacy Policy.
We reserve the right to update or change our Privacy Policy at any time, and you are encouraged to review this Privacy Policy periodically. To inform you of any material changes to the manner in which we collect or process your information, including changes to this Privacy Policy, we will post the updated version on the Platform, with the revision date clearly indicated at the top. We will also make reasonable efforts to notify you of any such material changes.
Personal Information Collected
All information collected or used by the Company, including Personal Information, is with the Users’ consent or has been provided to the Company by a third-party on whose behalf the Users avail the Services (through such legitimate purpose or other adequate consent requirements to be satisfied by such third-party). The Company may also use information available in the public domain. When Users use or sign-up for the Platform, the Users may provide the Company with certain information, including Personal Information, voluntarily, depending on the nature of the Services being availed on the Platform. In addition, certain information may be automatically collected based on how the Platform is used.. The Users hereby consent to the collection of such information by the Company.
Information we automatically collect. We may also collect certain technical information by automatic means when you visit our website, such as IP address, browser type and operating system, referring URLs, your use of our website, and other clickstream data. We collect this information automatically through the use of various technologies, such as cookies.
User information collected by us may include (without limitation) the following:
Name;
Email ID;
Phone number;
Nationality, geolocation and time zone;
Referral source;
Marketing preferences, service communication preferences, and notification preferences;
Financial information (including billing address and limited information regarding payments);
Details about payments made between you and us; details of Services purchased from us;
Metrics on system or App feature use, including but not limited to the date of sign-up to the Platform, number of logins, and last login to the Platform;
IP address, browser type, operating systems, URLs;
Digital media including photos, videos, etc., if required;
Information related to Contributions (defined below); and
Data and Personal Information that you may choose to upload and/or feed into the Platform.
Incorrect information. If we have reasons to suspect that the information provided by any User is misleading, inaccurate, obsolete or incomplete, we reserve the right to refuse provision of the Services to such User at our sole discretion, and without incurring any liability to to Users or any third-party in this regard.
Use of Personal Information
Personal Information of Users is primarily used for providing the Services, billing and payment processing. We may also use such information for the following purposes:
To communicate with you (such as through email) about Services that you have signed up for and availed, changes to this Privacy Policy, changes to our terms of service, or important notices;
To keep you posted on new Services, upcoming events, offers, promotions and other information that we think will be of interest to you, in accordance with your marketing and notification preferences;
To ask you to participate in surveys, or to solicit feedback on the Services provided by us;
To set up and maintain your account, and to do all other things required for providing our Services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;
To understand how Users use our Services, to monitor and prevent issues, and to improve our Services;
To provide User support, and to analyse and improve our interactions with Users;
To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of the Company, its Users, third parties and the public at large;
To update, expand and analyse our records, identify new Users, and provide Services that may be of interest to you;
To analyse trends, administer the Platform, and track visitor navigations on the Platform, to understand what visitors are looking for and to better help them;
To make suggestions relevant to the User;
To improve and enable you to avail our Services, increasing efficiency of existing features, and developing new features;
To tackle issues relating to troubleshooting, quality control, and analytics;
To maintain records and provide you with an efficient, safe and customized experience while using the Services;
To comply with the applicable legal and regulatory requirements;
As we believe to be necessary or appropriate, and only as permitted under applicable law (a) to comply with legal process; (b) to respond to requests from government authorities; (c) to protect our operations, including in connection with investigating security incidents; or (d) to protect our rights, privacy, safety or property; (e) to transfer the data and the rights associated therewith to a third party as part of reorganization or a sale of the assets of any division of the Company or the entire Company itself;
We may use Personal Information of the Users to create non-identifiable and anonymized aggregate data for the purposes of marketing, research and analytical purposes;
If you provide to us any ideas, proposals, suggestions, recommendations or other materials (“Feedback”); and
In any other way consistent with this Privacy Policy, and to support the above activities.
Please note that we do not sell or trade your Personal Information to third parties.
Data Processed on behalf of Customers
In providing our Services, we may process data — including Personal Information — on behalf of our Customers, who act as data controllers. This data is referred to as “Service Data”. We process Service Data strictly in accordance with our agreements with Customers and applicable data protection laws. If your data has been submitted to us by a Customer and you wish to exercise any data protection rights, please contact the Customer directly.
Data Residency and Hosting
All data, including Personal Information, is hosted on secure servers located in India and/or the US, as applicable. We may use cloud service providers for data hosting, and all such providers are contractually obligated to adhere to strict data protection and security standards.
Sub-Processors
We may engage trusted third-party service providers (sub-processors) to help us provide and support our Services. These sub-processors may have access to Personal Information solely for the purpose of performing their functions and are contractually obligated to maintain its confidentiality and security.
Opt-out
Continued use of the Services and access to the Platform will constitute your acknowledgment of and consent to abide and be bound by this Privacy Policy, as modified by us from time to time. Users have the right to opt out of the Platform and/or Services at any time. In addition, the Users can, by sending an email to kanishka@nudgenow.com, inquire whether the Company is in possession of their Personal Information, and enforce their rights with respect to their Personal Information. For more information in relation to rights of a User under this Privacy Policy, please see the ‘User Rights’ section below.
Cookies
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser, only if you allow, that enables the sites or service providers’ systems to recognize your browser and capture and remember certain information.
We use cookies to understand and save your preferences for future visits, to advertise to you on other sites, and to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you delete or decline cookies, some features of our website or platform and our Services may not work or may not work as designed. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.
A banner asking you to accept our cookies policy will be displayed upon the first visit to the Platform (or the first visit after you delete your cookies). Unless you have adjusted your web browser setting so that it will refuse cookies and/or you have not accepted our cookies policy, our system will issue cookies when you visit our website or platform.
Retention of Personal Information
We retain your Personal Information, as managed by this Privacy Policy, for as long as you continue to use the Platform, have an account with us, for as long as is necessary to fulfil the purposes outlined in this Privacy Policy, and for as long as is necessary for compliance with applicable laws. You can ask us to close your account by contacting us at contact@nudgenow.com, and we will delete your Personal Information on request.
We may, however, retain Personal Information for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes of the Company.
Protection and Safety of Personal Information
The security of your Personal Information is important and we have implemented reasonably sufficient means to protect the same, including access controls and data encryption. However, no method of transmission over the internet, or method of electronic storage, is 100% secure, and we cannot guarantee its absolute security. We have implemented best industry practices and security policies, rules and technical measures to protect all information collected and processed by us and in our control, including Personal Information, from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
Notwithstanding anything contained in this Privacy Policy, we shall not be held liable for any loss whatsoever incurred by the Users or any third-party for any data loss or theft due to unauthorized access to the Users’ electronic devices through which the Users avail the Services, or through reasons solely attributable to the Users, including but not limited to Users failure to comply with our terms of service and this Privacy Policy.
When payment information is being transmitted on or through the Platform, it will be protected by encryption technology of a third-party payment services providers, including payment gateways. You agree, acknowledge and consent to such sharing of your information with third party service providers to process payments and manage your payment-related information.
There may be instances when you receive a seemingly legitimate looking e-mails from unknown sources, asking for your Personal Information such as your credit card details, bank account details, one-time passwords, etc. Please note, we will never ask for such information from you via e-mail. Such activities are usually carried on by unauthorized sources and are illegal in nature. In case of such suspicious activity, we advise you to not entertain the same, and report the same to the relevant authority at the earliest.
Storage and Transfer of Personal Information
All information collected by the Company, including Personal Information, shall be processed and stored in India and/or the US, as applicable, and the laws relevant to such jurisdictions will apply to the storage and processing of such data/information.
Disclaimers
The Platform may contain links to other websites. Please note that when Users click on one of these links, they are entering another website over which we have no control and for which we will bear no responsibility. These websites often require Users to enter and feed in their Personal Information. We encourage and recommend Users to read the privacy policies of all such websites as before engaging and/or feeding in their Personal Information. We shall not be liable for any breach of your privacy, unlawful use of your Personal Information, or loss incurred by your use of such websites or services. The inclusions or exclusions of such links on the Platform are not suggestive of any endorsement by the Company of such website or the contents of the website, and you may visit such websites at your sole risk.
You also may provide information to be published or displayed on publicly accessible areas of our Platform, or transmitted to other users of our Services or third-parties (collectively, "Contributions"). Your Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, you may set certain privacy settings for such information by logging into your account profile. Additionally, we cannot control the actions of other Users of our Services with whom you may choose to share your Contributions. Therefore, we cannot and do not guarantee that your Contributions will not be viewed by unauthorized persons. We may display this information on the Platform, while providing the Services, share it with businesses, and further distribute it to a wider audience through third party sites and services. You should be careful about revealing any sensitive details about yourself in such Contributions.
User Rights
As a User, the Company grants you complete control of the information submitted by you. The rights pertaining thereto are enumerated below:
Right to Access your Information that we have Collected. You have a right to request that we provide you with a copy of your Personal Information that we hold, and you have the right to be informed of: (a) a summary of your Personal Information which is being processed us; (b) the processing activities undertaken by us with respect to your Personal Information; (c) the data controller’s identity (i.e., information about persons who control the manner in which your Personal Information is processed); and (d) the entities or categories of entities to whom your Personal Information may be transferred.
Right of Rectification. You have a right to rectify your information in the profile section of the Platform, or request that we rectify inaccurate Personal Information, complete the incomplete Personal Information or update such Personal Information. We may seek to verify the accuracy of the Personal Information before rectifying it.
Right to Erasure. You can also request that we erase your Personal Information in limited circumstances where (a) it is no longer needed for the purposes for which it was collected, (b) you have withdrawn your consent (where the data processing was based on consent), (c) following a successful right to object (see right to object), (d) it has been processed unlawfully, or (e) to comply with any legal obligations of the Company.
Please note, we are not required to comply with your request to erase Personal Information if the processing of your Personal Information is necessary (a) for compliance with a legal obligation, or (b) for the establishment, exercise or defence of legal claims.
Right to Withdraw Consent. Users have the right to withdraw their consent at any time, when consent is given pertaining to Personal Information.
Right to Lodge a Complaint with the Local Supervisory Authority. You have a right to lodge a complaint with the Data Protection Board of India if you have concerns about how we process your Personal Information. However, in case of any such grievance, we ask that you attempt to resolve any issues with us first, although you have a right to contact the supervisory authority at any time.
Right to be Informed. Users have the right to be informed about third parties with whom their Personal Information has been shared.
Right to Unsubscribe. You have the option of opting-out of receiving future e-mails and newsletters from the Company at all times. We provide you with the opportunity to opt-out of receiving communications from us by choosing the appropriate options for unsubscribing under your emails. To opt-out, you can also send us a message at kanishka@nudgenow.com. Please note, however, that you generally cannot opt-out of Service-related announcements, e.g., if the Service is temporarily suspended or if delivery of a Service is delayed.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee, where permitted by applicable law, for instance, if your request is manifestly unfounded or excessive.
Specific Privacy Rights of California Residents
This Section for California residents supplements this Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”) of 2023.
The CCPA and the CPRA are California laws that provide its residents with certain rights over information about them, including notice about the categories of Personal Information We have collected from them in the preceding 12 (twelve) months and the purposes for which the information is used or disclosed, and correction of Personal Information.
In the preceding 12 (twelve) months, we may have collected the following categories of Personal Information (as defined under Cal. Civ. Code §1798.140(v)(1)):
Identifiers, such as your name, address, unique personal identifier, email, phone number, or similar identifiers.
Commercial information, such as information relating to transactions with us involving you.
Internet or other electronic network activity information, such as technical information, including the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, click-stream data, locale preferences, your mobile carrier, and system configuration information.
Geolocation data, such as geolocation, to the extent you have configured your device to permit us to collect such information.
Additional Privacy Rights for California Residents. In addition to the rights provided under Section 10, California residents are also entitled to the following rights:
Non-Discrimination. It is the right of California residents not to receive any discriminatory treatment from us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only the Users, or someone legally authorized to act on behalf of the Users, may make a verifiable consumer request related to their Personal Information. Users may also make a verifiable consumer request on behalf of their minor children. To designate an authorized agent, please contact us at contact@nudgenow.com and provide written authorization signed by the User and his/her designated agent.
Verification. To protect Users’ privacy, we will undertake the following steps to verify Users’ identity before fulfilling their request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative, which may include asking you for additional proof of identity and asking questions regarding your account and use of our Services.
California “Shine the Light” law. California’s “Shine the Light” law (California Civil Code Section 1798.83) permits Users of our Services who are California residents to request and obtain from us, once a year and free of charge, a list of third parties with whom we have shared any Personal Information belonging to any of our Users, for their marketing purposes. To make such a request, please contact us at contact@nudgenow.com.
If you are under 18 years of age and reside in California having a registered account with us, you have the right to request removal of unwanted data that you publicly post on our website or platform. 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 our website or platform, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
Do not track. As per California law, CalOPPA (California Business & Professions Code Section 22575(a)), it is required that We let You know how We respond to web browser Do Not Track (“DNT”) signals. DNT is a privacy preference that Users may set in their web browsers. Please acknowledge that We do not respond to such DNT requests at this time.
Response Timing. We are required to respond to any of the verifiable consumer requests to exercise these above rights within 45 (forty-five) days. Should we be unable to comply within 45 (forty-five) days, we will contact you and let you know whether we can complete your request or whether we need more time to complete your request with reason. Any disclosure we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.
Regarding information we disclose to third parties, you have the right to opt out of such disclosure at any time. You can exercise your right to opt out (or any other rights on our website or platform) by emailing us at contact@nudgenow.com.
Please note, the Company does not sell Personal Information, nor do we possess any actual knowledge of any sale of Personal Information.
Specific Rights in Other Jurisdictions
In addition to the rights above, you may also be entitled to other data protection and privacy rights under the laws applicable in your jurisdiction. You can exercise any and all of your rights by contacting us at contact@nudgenow.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request in instances where the same would impact the duty of confidentiality we owe to other Users, or if we are legally entitled to deal with a request in a different way.
Third-Party Integrations
Our Platform may include integrations with third-party services (e.g., social media logins, analytics tools, or payment gateways). Your interactions with these services are governed by their respective privacy policies. We do not control, and are not responsible for, the privacy practices of such third-party service providers.
Behavioural Advertising
We may partner with third-party advertising networks to display advertisements on our Platform or manage our advertising on other sites. These partners may use cookies or similar tracking technologies to collect information about your activities on our Platform and other websites to provide you with targeted advertising based on your browsing behaviour and interests.
Changes to Contact Information
If your contact information (such as email or phone number) changes, you are responsible for updating your profile on the Platform to ensure you receive critical privacy-related communications.
Do Not Track
Some browsers offer a “Do Not Track” feature that lets users signal their preference not to be tracked across websites. Currently, we do not respond to DNT signals as there is no universally accepted standard for such signals.
Grievance Officer
Any complaints, abuse or concerns with regards to content and or comment or breach of the terms in this Privacy Policy shall be immediately informed to the designated Grievance Officer as mentioned below in writing or through email signed with the electronic signature:
Name: Kanishka Thakur
Email: kanishka@nudgenow.com
Your use of the Platform and any dispute over privacy is subject to this Privacy Policy and our terms of service.
Contact Us
If there are any questions regarding this Privacy Policy, you may contact us at: