______________________________. (“Tercera”, “Company” “We”, “Us”), the sole proprietor and legal entity owning MSVgo, is committed to protecting your privacy. The contents of this privacy policy (“Privacy Policy”) along with the Terms and Conditions (“TOU”) available on the “MSVgo” application (“Application” / “Platform”) and website with the URL ___________________ (“Website”) shall be applicable to all users of the Application and the Website, and the services provided by us through the Application and Website (“Services”). By clicking on the “I accept” button, you accept this Privacy Policy and agree to be legally bound by the same. Please note that we do not collect personal or sensitive data collection prior to obtaining your consent of this Privacy Policy, in the manner specified above.

This Privacy Policy sets out a) the type of information collected from the users (“you”, “your”), including Personal Information and Sensitive Personal Data or Information relating to an individual; b) the purpose, means and modes of collection, usage, processing, retention and destruction of such information; and c) how and to whom we will disclose such information.

We respect your privacy and recognize the need to protect the Personal Information which you share with us. We would like to assure you that we follow appropriate and necessary standards when it comes to protecting your privacy for the Services. The terms ‘Personal Data’ and ‘Personal Information’ have been used interchangeably in this Privacy Policy. Furthermore, the terms ‘Personal Information’, ‘Personal Data’, ‘Sensitive Personal Data’ and ‘Information’ shall have the meaning ascribed to it under the applicable laws in India. For the purposes of this Privacy Policy, your IP address, web browser activity and history, and inventory of installed applications and your phone or contact book data shall be deemed to be personal or sensitive user data.

CONSENT

WHAT PERSONAL INFORMATION DO WE COLLECT?

By signifying your acceptance to the provisions of the Privacy Policy and by providing your Personal Information, you consent to the collection and use of such Personal Information in accordance with this Privacy Policy, including but not limited to your consent for sharing your Personal Information as per this Privacy Policy. You specifically agree and consent to us collecting, storing, processing, transferring and sharing information (including Personal Information) related to you with third parties as set out in this Privacy Policy.

All information, including Personal Information, disclosed by you shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/ misrepresentation/ fraud/ negligence, etc. of the information disclosed shall lie on us nor will we in any way be responsible to verify any information obtained from you.

You represent and warrant that any and all information, including but not limited to your Personal Information, is absolutely correct and complete in all aspects. You can also anytime withdraw the consent you provided by sending an email at [Insert e-mail address] and making a request for termination of services provided by us.

In case you do not provide your consent or later withdraw your consent, we request you not to access the Application / Platform or the Website, and use the Services and also reserve the right to not provide you any Services on the Application or the Website. In such a scenario, we may delete your information (Personal Information or otherwise) or de-identify it so that it is anonymous and not attributable to you.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect information about you to provide you with our Services, as well as optimize your experience on our Website and Application.

Customer Data: This is the data that is affirmatively provided to us by you at the time of creating a user profile on MSVgo. We then collect and store your first name, last name, and email address. The user is the owner and controller of this data and by virtue of providing it to us for the use of its services, processing rights for the said data are vested upon it, in accordance with the various clauses of this Policy.

Other Data: In addition to the data affirmatively provided by you, certain information is also automatically collected when you visit our Application or Website, or use any of our Services. We collect and store the usage information of every user obtained through various analytics tools. The user information collected includes:

• Content engagement: The time period for which the content provided through MSVgo is consumed by the users, as well as the pages, visited/viewed by them. List of users the content has been assigned to.
• The date on which any information is created, modified, or archived.
• All transactions done, clicks and behaviours by/of any user on the Platform.
• Monies paid or reserved for subscriptions, purchases, trials to us or to third parties selling Content on the Platform.
• Usage patterns, online behaviour patterns (clicks, click patterns, time spent on a page, time spent on a Content item or part thereof etc.) and purchase patterns of content by users.
• Users’ email addresses and first and last names as provided by them. This type of data is owned and controlled by us. Furthermore, third parties may also collect your information in connection with your use of the Services.

FOR WHAT PURPOSES IS YOUR PERSONAL INFORMATION USED?

We are committed to respecting the privacy of users and we use the personal data provided to us or generated by us only for the purposes that are strictly necessary for providing quality services to our users, and optimizing their overall experience at MSVgo. We never publicly disclose any Personal Information Related to financial or payment activities or any government identification numbers. Your personal information is used by us only for the following purposes:

• Providing Services: We require information such as your first name, last name, email address, and the content assigned to you for enabling us to recognize each unique user and user account and provide the relevant end service.
• Optimize user experience: We primarily use analytics tools to better understand consumer behavior and preference. The statistics so generated are helpful in understanding how our visitors can use this Application/ Platform and Website. We use this information in the aggregate to measure the use of the Platform and to administer and improve the same. This statistical data is interpreted by us in its continuing effort to present the Platform content that visitors are seeking in a format they find most helpful. We also use third-party cookies to analyze visitor trends and gather information such as the frequency with which our guests visit various parts of the websites, demographic information, etc, about our website as a whole. You agree that we or our third party service providers may collect your internet protocol address or other unique identifier for this purpose. Additionally, we may combine your visitor session information or other information collected through cookies, web beacons and other technical methods with any Personal Information In order to understand and improve your online experiences and to determine what products, promotions and services you prefer or are likely to be of interest to you.
• Marketing Communication: We also require information such as your email address and content engagement to approach you for any services similar to the ones currently being availed by you, or any other products, services, offers, and discounts provided by us that you might be interested in. We, either through ourselves or our affiliates or group companies may combine your internet protocol address with other Personal Information for Service-related activities, marketing, for market research purposes, including internal demographic studies, so we can optimize our products and services and customize the Application / Platform for you. Further, we use the same information or provide the same to third party contractors which are bound by the restrictions set out in this Privacy Policy to provide various value-added services, for market research, project planning, troubleshooting problems, detecting and protecting against error, etc. This enables us to ensure that you are provided with the best possible services during your time with us.
• Providing Customer Support/Service: We require information such as your email address to reach out to you in case of any queries or problems that you may have in the course of your use of our services.
• To enable content creators to optimize their content engagement: We also provide information such as user engagement and content consumption patterns to various content creators on our platform. This enables them to better understand the behavior of their customers and personalize their content for them accordingly.

We shall be entitled to retain your Personal Information only for such duration as may be required for the purposes specified hereunder and shall be used only in consonance with this Privacy Policy.

DISCLOSURE OF INFORMATION

• We will not sell your personal data to third parties.
• We will only disclose your personal data to third parties where you have provided us consent, and in the situations expressly set out in in this Policy. If you have consented to receiving marketing information from us, our strategic partners and business associates, we will be disclosing your personal data to them.
• Your personal data may be disclosed and shared within the Company affiliate or group companies only for the purpose mentioned above.
• Some or all information provided by you may also be shared with or transferred to other entities during negotiations for any mergers, acquisitions, sale, or purchase of assets. In the event of such sharing or transfer of personal data, we are unable to guarantee that the entity so acquiring your personal data shall accord the same level of protection to your data as is accorded by this Policy.
• We may disclose or share your personal data with third parties who provide necessary services to us, such as:-
  • service providers and data processors working on our behalf and providing services such as hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency check and address check, etc; and
  • our consultants and professional advisers (such as accountants, lawyers, auditors).
• We will also disclose your personal data to third parties in order to comply with legal obligations or industry requirements. This includes disclosures to legal, regulatory, governmental, tax and law enforcement authorities.
• Our website may have the functionalities to allow you to share your personal data with other third parties such as other users of our website. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the website.

COOKIES POLICY

Some of our web pages including our third-party service providers store and use “cookies” to better understand your browsing preferences and behavior and accordingly provide you with customized information to optimize your user experience on further visits to our Website or Application / Platform. Cookies are identifiers that are stored on your computer’s browser directory. They are created when you use your browser to visit our Application. They keep track of your movements within our Application, help you resume where you left off, remember your registered login and other functions. You can set your browser to notify you when you are sent a cookie, giving you the option to decide whether or not to accept it.[You may get cookies from our advertisers. We do not control these cookies, and once you have clicked on the advertisement and left our Application, our Privacy Policy no longer applies.]

We also use Google Analytics, a third-party website analytics tool, to collect website trends in an anonymous way, without identifying particular users. Google Analytics may then use cookies to collect certain information to compile these website trends. However, as mentioned above, any information so collected shall be duly anonymized such that it is not possible for us to identify individuals based on their website browsing behavior and preferences.

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

When you visit the Application / Platform or the Website, you agree that we or any of our partners/affiliates/group companies/subsidiaries/holding company/collection agents may contact you from time to time to provide the offers/information of such products/Services that we believe may benefit you or any other promotional or transactional information we wish to receive from you.

We may share your personal data with third parties to the extent that doing so is necessary for providing you with our Services. Therefore, your data may be shared with data centers, hosting services, or email marketing services.

Additionally, we may share or transfer your personal data with another entity in the course of a change in our ownership or corporate organization. Some or all information provided by you may also be shared with or transferred to other entities during negotiations for any mergers, acquisitions, sale, or purchase of assets. In the event of such sharing or transfer of personal data, we are unable to guarantee that the entity so acquiring your personal data shall accord the same level of protection to your data as is accorded by this Policy.

We may also be required to share your data in pursuance of any legal obligation accruing to us. We may then, in good faith, share your personal data if we are reasonably satisfied that doing so would be necessary for our compliance with the applicable law.

LINK TO THIRD PARTY WEBSITES

We may link to third-party websites. These third-party websites may collect information about you on those websites, and our Privacy Policy does not extend to such third party websites. We are not responsible for the content of these third-party websites or for the security of your information when you use the third-party websites. Please refer directly to the websites of such third parties and their privacy policies. You agree and acknowledge that we are not liable for the information published in search results or by any third-party website.

SECURITY MEASURES

We will be only using the information provided by you for the purpose(s) which you have consented to do under this Privacy Policy. We will not sell, trade or disclose to third parties any Personal Information derived from the registration for, or use of, any online service (including names, addresses and payment information) without your consent save and except to any of our affiliates or group companies for purposes in relation to the businesses of our affiliates or group companies and as may be required by legal process or in the case of imminent physical harm to any person).

Further, we will allow its affiliates to access the information for purposes of confirming your registration and providing you with benefits you are entitled to.

We will use reasonable security measures and safeguards and take appropriate steps to protect the information you share with us. We have implemented technology and security features and strict policy guidelines to safeguard the privacy of your Personal Information from unauthorized access and improper use or disclosure, in compliance with applicable laws. For this purpose, we undertake internal reviews of the data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store your Personal Information. We will continue to enhance our security procedures as new technology becomes available. We cannot however ensure or warrant the security of any information you transmit to us or guarantee that your Personal Information and/or information provided for availing the Services, Website, or Application may not be accessed, disclosed, altered or destroyed by a breach of any of our security measures and safeguards.

It is further clarified that you have and so long as you access and/or use the Application / Platform (directly or indirectly) the obligation to ensure that you shall at all times, take adequate physical, and technical safeguards, at your end, to preserve the integrity and security of your data which shall include and not be limited to your Personal Information.

SOCIAL NETWORKS

Our website and mobile or web-based applications may provide you with social plug-ins from various social networks (such as Facebook and Twitter). If you choose to interact with a social network, your activity on our website or via our mobile or web-based applications will also be made available to social networks such as Facebook and Twitter.

If you are logged in on one of the social networks during the visit of one of our websites or mobile or web-based applications, the social network might add this information to your profile. If you are interacting with one of the social plug-ins, this information will be transferred to the social network. In case you do not wish such a data transfer, please log off on your social network before you enter one of our websites or mobile or web-based applications.

We cannot influence this data collection and data transfer via the social plug-ins. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings.

PHISHING

Identity theft and the practice currently known as “phishing” are of great concern to Tercera. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your financial information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

DISCLAIMER

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE IN ANY EVENT FOR ANY SPECIAL, EXEMPLARY, PUNITIVE, INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES OF ANY KIND OR FOR ANY LOSS OF REPUTATION OR GOODWILL, WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE), EQUITY, STRICT LIABILITY, STATUTE OR OTHERWISE, SUFFERED AS A RESULT OF UNAUTHORISED OR UNINTENDED USE, ACCESS OR DISCLOSURE OF YOUR PERSONAL DATA.

YOUR RIGHTS

If you have any questions about the processing of your personal data or about our Policy, if you do not accept the amended Policy, if you wish to withdraw any consent you have given us at any time, or if you wish to update or have access to your personal data, you are welcome to contact us. The contact details are:

Attention to:

Email:

All requests for correction or for access to your personal data must be in writing. We will endeavor to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.

We may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.

In many circumstances, we need to use your personal data in order for us to provide you with services which you require or have requested. If you do not provide us with the required personal data, or if you do not accept the amended Policy or withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the services that you require or have requested.

We may charge you a fee for responding to your request for access to the personal data which we hold about you, or for information about the ways in which we have (or may have) used your personal data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time without requiring any consent from anyone. If our privacy policy changes in the future, it will be posted here and a new effective date will be shown. You should access our Privacy Policy regularly to ensure you understand our current policies. Your acceptance of the amended Privacy Policy shall signify your consent to such changes and agreement to be legally bound by the same. Please reference the privacy policy in your subject line. Tercera will attempt to respond to all reasonable concerns or inquiries on a best efforts basis within a reasonable period of time.

GRIEVANCE REDRESSAL

Users may reach out to us in case of any grievances, queries, or questions pertaining to this Privacy Policy through the support channel as under:

Email:

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