PRIVACY POLICY

Effective date: 16^th August 2017

We, Red Brick Lane Marketing Solutions Private Limited (“RBL”), are in the business of providing marketing and digital media advisory services, designing marketing programs and enabling cross device re-targeting and performing data analytics. We develop and distribute certain software applications (“App”), as well as develop small software packages or software development kits (“SDK”) which are used by certain website publishers, mobile app publishers or companies and other companies (“Independent Users”), for the purposes of utilizing the same in connection with developing and operating their own applications (“Independent Users Applications”), for tracking offline viewership of television programmes and advertisements (“Services”) and other user behavior.  This privacy policy covers the site www.zapr.in and our ZAPR SDK.

This RBL Privacy Policy addresses the terms and conditions relating to protection of the Information (as defined below) which may be accessed, collected and used by us from time to time, during the performance of the Services.  The RBL Privacy Policy also describes how we collect, use, share and secure the personal information you provide on our website www.zapr.com and our ZAPR SDK.   It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

By using this Website, App or Independent Users Application, you agree to accept the terms of this Privacy Policy.  By accessing or using this Website, App or Independent Users Application, you expressly consent to the Company’s use and disclosure of your Information in the manner described in this Privacy Policy. This Privacy Policy extends to users who visit the Website or use the App or the Independent Users Applications but do not transact business on the Website/APP/Independent Users Applications, as well as users who are registered and are authorized by the Website to transact business on the Website.

Acceptance and modifications

You expressly accept the terms of this RBL Privacy Policy when you use the Website/App/Individual User Application or the Services. Please cease your usage of the Website/App/Individual User Application or the Services immediately if you do not agree with the RBL Privacy Policy.

We may update this privacy policy to reflect changes to our information practices.  If we make any material changes we will notify you by email or by means of a notice on this Site prior to the change becoming effective.  We encourage you to periodically review this page for the latest information on our privacy practices.

Information that may be collected

The information that may be accessed and collected by us pursuant to the provision of our Services shall mean and include the following (“Information”):

• Information pertaining to your user account (such as name, email address, and phone number) with us including any personal information shared by you for the purposes of creating your user account;
• Contact information, such as name and email address, that you submit on our website when you request information about our Services or subscribe to our email mailing list;
• Data regarding the visitors to the Independent Users Application and their user behaviour;
• Data pertaining to media content playing close to you from time to time;
• Data pertaining to viewing of certain advertisements or television programmes; and
• Other information such as information about your visit, the nature of your internet connection, IP address, domain name, web browser, data collected via App, Google Advertising ID and related data, operating system, frequency and duration of use and contact details.
• We also automatically receive and track certain data about your mobile device (such as your device-type, device ID, installed software and language preference) or desktop interface, your taps and interests; and we may create a unique device or user ID for you so we can recognize you. In some cases, when you have consented to sharing your location data with a mobile app, we can automatically detect or infer your location using GPS, your IP address, watermarks and/or Bluetooth. Often your operating system will require you to grant us permission to access your GPS or Bluetooth settings; please refer to your device’s system settings regarding location services. You may opt-out of location based services at any time by emailing us at [email protected].
• We don’t knowingly collect data from anyone under the age of 13 and we do not direct any of our products or services at this age group. If we become aware that we have inadvertently captured any personal data about a person who is under 13 years of age, then we will take the appropriate steps to shut down the account of that person.

We may access, collect, store and use Information during the provision of our Services. This information may include Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, date/time stamp, and/or clickstream data. We may request for further information from time to time, and all such additional information made available to us shall become part of the Information.

RBL does not collect or store any of the personal contacts or photographs or videos or any other information stored on your device without your permission.  While RBL collects (or maps) frequency fingerprints for the purposes of providing the Services, RBL will not be privy to or collect any personal conversations (whether ambient, voice or data calls), or engage in any form of passive listening.

How information is collected

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

We may collect the Information automatically when we deliver the Services. An App may be made available to you (i) as a download directly from RBL; or (ii) as part of an Independent User Application that includes the App and which has been downloaded by you from (or otherwise provided to you by) an authorized distributor pursuant to an agreement with RBL.

While rendering the Services pursuant to the download of the App onto your device, we use a variety of technologies (such as an frequency fingerprinting) to automatically or passively record and collect Information, based on your access or usage of service or as a result of any Individual User Application interacting with the App (such as creating frequency fingerprints from the user’s device from time to time), in order to collect sample data for analyzing viewership of television programmes and advertisements.

We and our partners use technologies such as cookies, beacons, tags and scripts on certain pages of the Website to help analyze our webpage flow, measure promotional effectiveness, and promote trust and safety. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service, but we offer certain features that are only available through the use of these technologies.

We partner with third parties to either display advertising on our website or to manage our advertising on other sites.  Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests.  If you wish to not have this information used for this purpose of serving you interest-based ads, you may opt-out by clicking here.  Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Use of information collected

We may use the Information collected by us for purposes, including, and without limitation to:

1. Creation and maintenance of your user account for authorization and authentication of access to Services;
2. Storing, monitoring, processing and analyzing the data obtained from you for conducting analysis of such data along with data obtained from other users, to generate data pertaining to viewership of television programmes and television advertisements;
3. For sending advertisement requests as well as sending push targeted core advertisement contents while you open other web page / apps/ content;
4. Sharing the results of our analysis with our customers who may use it for purposes such as for personalizing content on their Independent User App based on the result of the data analysis shared by RBL;
5. Sharing data with third parties – key facts and how to opt-out
   We may share your information, such as your device and location information, with third parties including advertisers and partners, some of whom may use your data for the purposes of demographic, behavioral, and geographic ad targeting or to provide localized services. Additionally, some third parties (such as companies who advertise through our apps) may require you to provide your personal data in order to access their products, adverts and offers. Any third parties’ use of your personal data is governed by their own privacy policy. To learn more about behavioral advertising or to opt-out of some types of behavioral advertising for participating ad networks, you can visit the Network Advertising Initiative (http://www.networkadvertising.org/choices/) or the Digital Advertising Alliance (http://www.aboutads.info/choices/), and
6. As otherwise required or permitted by law.

We may use your IP address to help diagnose problems with our web servers, for the purposes of rendering the Services as well as to gather demographic information.

Disclosure of information

We may appoint an affiliate to perform Services for you in jurisdictions other than those where we are authorised to operate. In such instance, the Information may be accessed, collected, stored or used by such affiliates for the purpose of delivering the Services. The terms and conditions in this RBL Privacy Policy would also apply with respect to such affiliates.

We may disclose your Information for the purposes described, including without limitation: to access, record, collect, copy, store, process, analyze and use the Information to provide the Service, to develop, improve, extend and test the Service (and underlying technology platform), to design, develop and produce analysis; and to disclose, distribute and transmit the Information pertaining to the fingerprints and the aggregate result, and/or analysis to Independent Users, advertisers, advertising networks, content distributors and other RBL’s customers and service providers. By continuing to use the Website/App/Independent User Application, you continue to accept such disclosure and transfer of your Information.

We may also disclose Information for the following purposes:

• if we are requested, or become legally compelled, to disclose the existence or contents of any of the Information. In such cases, we shall provide you with written notice of such request or compulsion, but shall not be responsible to seek any protective orders, confidential treatment or any other remedy regarding the disclosure;
• in connection with dispute resolution, government or internal investigations, or other administrative proceedings;
• if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• in connection with any proposed or actual investments into, sale or merger of RBL or other transfer of any of our assets; or
• as may be otherwise required or permitted by law.

Information from RBL

In the provision of our Services, we may provide you with links to other sites that are owned or operated by third parties. We bear no responsibility whatsoever for the privacy practices of such sites and make no representations about such third-party sites or any information, services, products or materials found on them. We further disclaim any and all liability to maintain the security of any Information provided to or accessed by such third-party sites. We strongly recommend that you read the terms and conditions, and privacy statements of such third-party sites.

Security and information

We have stringent security measures (physical, electronic and managerial) in place to protect against the loss, misuse, and alteration of the information under our control. From time to time, we review our security procedures to consider appropriate new technology and methods The Website’s and App’s servers are accessible only to authorized personnel and your information is shared with employees and authorized personnel on a ‘need to know’ basis to complete the analysis of the data collected from you. We use adequate encryption at the time of collection and storage of any information from you in order to render the Information collected as undecipherable. The fingerprints collected can never be reconverted back into any audio due to the inherent privacy centered nature of the fingerprinting technology and algorithms used.

The security, integrity and confidentiality of your information are extremely important to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. In the event of a data breach affecting personal information, we will take appropriate steps to notify details of the breach. If you have any questions about the security of your personal information, you can contact us at [email protected].

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements, but no longer than 24 months in an identifiable form.

 User access and choice

Upon request we will provide you with information about whether we hold any of your personal information. If your personal information changes, or if you no longer desire our service, you may correct, update, or request deletion by contacting us at [email protected].  We will respond to your requests within a reasonable timeframe.  

Right to opt-out

The Website provides all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from RBL.  If you want to remove your contact information from all lists and databases of the Company, please email us at [email protected].

In the event your browser offers you a “Do not track” option for communicating your request to the operators of websites and web applications and services with respect to requesting RBL to stop tracking your online activities, we would stop recording and collecting any Information as well as refrain from contacting you. It is clarified that the Company can only control its own activities under the Do Not Track policy and shall not be responsible for any Information being availed or tracked or used on such Independent User Application. Further, RBL will not be able to initiate any action pursuant to activation of the ‘Do not track’ option by you on an Independent User Application and you would have to communicate the device information to RBL directly on the following: [email protected]

Social media widgets

Our website includes Social Media Features, such as the Facebook like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website.  These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly.   Social Media Features and Widgets are either hosted by a third party or hosted directly on our website.  Your interactions with these Features are governed by the privacy policy of the company providing it.

Applicable law

The terms of this RBL Privacy Policy are subject to all applicable laws, including the provisions of the (Indian) Information Technology Act, 2000 and the corresponding rules and regulations thereunder.

Grievance redressal

In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below:

Name: Deepak Baid

Email: [email protected]

Address: HAL 2nd Stage, Indiranagar, Bangalore 560038, Karnataka

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Queries on privacy policy

Should you have questions about this Privacy Policy, information collection, use and disclosure practices, please feel free to contact us through our Website or at the email address provided above. We will use reasonable efforts to respond promptly to requests, questions or concern regarding the use of your Information. Except where required by law, the Company cannot ensure a response to questions or comments regarding topics unrelated to this Privacy Policy.