Introduction

Vananam Rewards is dedicated to safeguarding your privacy when using our website and goods. In order to collect, utilize, and transmit Personal Data and Sensitive Personal Data for information we have about you, Vananam Rewards has established this Privacy Policy ("Policy"). This Policy outlines the requirements to ensure compliance with the relevant data privacy laws and regulations.

Vananam Rewards Private Limited, a Private Limited Company, its affiliates and subsidiaries commonly known as Vananam Rewards ("we," "us," or "our"), manages this website. When you use our mobile application (the "App"), our website (the "Site"), and other online products and services that link to this Policy (collectively, the "Service"), we may gather information about you. This privacy policy (the "Policy") explains how we may collect, use, and disclose information about our users. In this policy, we'll refer to users as "User," "you," or "your," as well as "Potential Customers" to refer to people who are looking at our website or contacting us for more information about our services, "Customer Company" to refer to our corporate client, and "Employee User" to refer to specific employees of Customer Company who use the App, the Site, and the Service through their employer.

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Your permission to our collection, use, and sharing of your personal information as set forth in this Policy is implied by your use of the Service. Being a global organization, we respect the privacy of data subjects and are committed to complying with all applicable data privacy laws and legislation, including but not limited to the EU General Data Protection Regulation 2016/679 and the California Consumer Privacy Act/California Privacy Rights. Protecting the privacy rights of data subjects and safeguarding their Personal Data is now being treated as a basic right of an individual and a legal requirement in many parts of the world. Rules, 2011 and other privacy laws that may be relevant insofar as they affect Vananam Rewards' data processing and business operations (collectively, the "Data Privacy Laws").

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We take your privacy seriously. If you have any questions about this Policy or about privacy at Vananam Rewards, please contact us at eve@vananam.com.

This privacy statement explains how we collect information, why we do it, what we do with it, and with whom we share it.

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• How to access and update such information.
• The decisions you can make regarding how We gather, utilize, and distribute your information.
• How We safeguard the data we maintain about you
• Without our express written consent, aggregate or scrape any content, data, or other information from the Website to be displayed alongside content from other websites or on a secondary site.
• If you access our Services through a third-party site, you might also be required to read and accept that site's terms of service and privacy policy.

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Definitions

The following definitions provide details on some of the terms used in the Policy:

Personal Data:

Personal data is any information about a "Data Subject" that can be connected or reasonably linked to a specific natural person. This could be anyone who can be identified, directly or indirectly, in particular by reference to an identifier like a name, an identification number, location information, an online identifier, or to one or more factors specific to that natural person's physical, physiological, economic, cultural, or social identity.

Sensitive Personal Data:

Described as any information revealing an identified or identifiable natural person's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or the processing of genetic information, biometric information for the purpose of uniquely identifying a natural person, data regarding health, or information concerning an individual's sex life or sexual orientation, and data relating to offenses, or criminal convictions.

In relation to residents of California, in addition to the aforementioned, the term also encompasses citizenship, national origin or ancestry, sexual orientation, sex (including gender, gender identity, and gender expression), pregnancy, childbirth, and medical conditions associated with the same, age, physical or mental disability, veteran status, and sex.

Process, Processes, Processed, or Processing: Any action, or series of actions, carried out on an individual's or an organization's personal data, sensitive personal data, or sets of those data, whether or not automatically, such as gathering, organizing, structuring, storing, retrieving, consulting, using, disclosing by transmission, disseminating, or otherwise making available, alignment or combination, restriction, erasure or destruction.

Consent: Any freely given, specific, informed, and unambiguous indication of the Data Subject's wishes by which the Processing of their Personal Data, Personal Information, and/or Sensitive Personal Data signifies agreement to the processing of their Personal Data, Personal Information, and/or Sensitive Personal Data through a statement or by a clear affirmative action.

Data Subject:

Refers to a specific natural person, i.e., a named or distinguishable natural person to whom the personal data relates. A legal representative (parent/guardian) would represent the data subject in cases involving minors or people with mental impairments.

The term "Data Subject" used in this Policy refers to Vananam Rewards' current and former employees, potential recruits, current, prospective, and former customers' people, current and former partners' and vendors' workers, website visitors, and subcontractors.

Vananam Rewards does not collect Personal Data/ Personal Information and Sensitive Personal Information from Data Subjects that are under the age of 18. For the purpose of CCPA/CPRA, Data Subject shall include California residents.

Data Controller: This phrase refers to a person or entity that (alone, jointly, or in common) decides the reasons why and how any personal data will be processed. References to the Data Controller in this Policy shall, if applicable, include Vananam Rewards and its affiliates.

DATA Processor

A data processor is a person or business that handles personal data on the data controller's behalf and at the latter's directions.

Third Party :

In relation to Personal Data or Personal Information or Sensitive Personal Data means any person other than the Data Subject, the Data Controller, or any Data Processor or other person authorized to process data for the Data Controller.

Personal Information we collect and process and how we use it

Information that we obtain from the client company

We obtain the following details via our sign-up form from Customer Companies that express interest in our service: full name, email address, company name, and phone number. We gather this data through a landing page that a customer company with an interest can visit by filling out forms on various directory services listed by our third-party provider.

Personal data we collect from employee users

We collect human resource (“HR”) information, and other information about Employee Users, from the Customer Company, and at the Customer Company’s option, such as: full name, email address, phone number or any other information that may be required from time to time. This Data is provided by the Customer Company’s HR department directly or indirectly by allowing Vananam Rewards to connect customer systems like HRMS, Single sign on systems etc, and is loaded and maintained in our system to allow for analytics. As noted above, we collect certain HR information about Employee Users directly from the Customer Company.

We get employee opinions from Employee Users when they vote on surveys, participate in text discussions with peers, or otherwise interact with peers on the App, Site, or System. Votes and comments made by employees are associated with their authors. We use certain tracking information ("Tracking Information") when a User visits our site. For tracking information, we make use of Google Analytics.

The following Tracking Information is collected: email address, device ID, IP address. We collect your email address, IP addresses and device information, directly through inclusion of their sdk/pixel or any other information which may be required from time to time. Tracking Information is collected via the Site and our web-applications, as well as via our iOS and android implementations.

Payment information

Your postal and email addresses may be included in the billing and financial information we gather if a third party is not paying for the service on your behalf. This information is needed to process your charges for Vananam Rewards services that demand payment. When your transaction is handled by a different company, Vananam Rewards may also obtain the invoicing and payment information you supply. Our Terms of Service outline the rules and conditions that apply to our fees and billing procedures. Please be aware that there might be extra rules if you open an account with a third-party payment processor.

Technical and usage information

We gather two types of usage data when you access our websites or use our services:

1. Specific technical information about your computer system or mobile device, such as your IP address and mobile device ID; and
2. Usage statistics regarding your interactions with the Service. This data is often gathered and analyzed via tracking technologies such browser cookies, mobile device software development kits, server log files, or web log files (collectively referred to as "Log Files"). Your user ID number(s) are associated with some of the cookies that the Service stores on your computer.

Cookies and automated information collection

We gather certain technical information when you use the Service in order to:

1. Analyze how our sites and services are used;
2. Give you a more customized experience; and
3. Control Reviews
4. Provide the service
5. You can limit the kinds of cookies you allow or have your web browser warn you when someone tries to put one on your computer.

Other sources

We may collect or receive information from other sources including third party information providers. This information will be used to supplement your profile - primarily to help you and your friends connect. It will be combined with other information We collect.

How we use the information we collect

In general, we collect, store, and use your information to provide you with a safe, smooth, efficient, and customized experience. For example, we may use information collected from you in any one or more of the following ways:

• Provide, maintain, and improve our Service.
• Provide and deliver the Service Customer Company requests and configures, process transactions and send you related information, including confirmations.
• Investigate system issues that impact our ability to provide the Service to Users.
• Send you technical notices, updates, confirmations, security alerts and support and administrative messages.
• Respond to your comments, questions and requests and provide customer service.
• Communicate to Customer Companies with you about products, services, offers, promotions, rewards, and events offered by Vananam Rewards and others, and provide news and information we think will be of interest to you.
• Monitor and analyze trends, usage, and activities in connection with our Service and improve and personalize the Service.
• Personalize and improve the Service, content or features that match user profiles or interests.
• Link or combine with information we get from others to help understand your needs and provide you with better service.
• Connect you with other users in your Contacts.

We will not sell, rent, or share Personal Data with third parties outside of our company without your consent, except in the following ways:

Law enforcement and internal operations

1. To respond to claims asserted against Vananam Rewards or to comply with the legal process (for example, discovery requests, subpoenas or warrants);

2. To enforce or administer our policies and agreements with users.

3. For fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or

4. To protect the rights, property, or safety of Vananam Rewards, its users or members of the general public.

5. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law.

6. However, nothing in this Privacy Policy is intended to limit any legal defences or objections that you may have to any third-party request to compel disclosure of your information.

Data recipients, transfer, and disclosure of Personal Information

Vananam Rewards does not share your Personal Information with third parties for their direct marketing purposes

If required by law, or if we have a good faith belief that using or disclosing your Personal Information is necessary to defend our rights, ensure your safety or the safety of others, carry out an investigation of potential fraud, or otherwise comply with the law, court order, or legal process, we retain the right to do so.

Business transfer

In the case of a merger, acquisition, reorganization, sale of assets, or bankruptcy, Vananam Rewards may sell, transfer, or otherwise distribute all of its assets, including your personal information. In such cases, Vananam Rewards will make commercially reasonable attempts to warn its users if their personal information is to be shared, transferred, and/or subject to a new privacy policy.

Third – parties

We occasionally hire other firms and individuals to execute operations or services on our behalf, such as software maintenance, data hosting, email message delivery, and so on. We are compelled to disclose your Personal Data with third parties in order for them to execute their functions. We take the appropriate precautions to guarantee that these third parties take your privacy as seriously as we do, such as engaging into Data Processing Addendum(s), EU Model Clauses, and/or ensuring these third-parties have EU-US and Swiss-US Privacy Shield certification.

How is my data protected?

To protect your personal information from unauthorized access, deletion, or alteration, we have implemented appropriate administrative, technological, and physical security measures. SSL encryption (https) while dealing with personal data, for example. Personal data is encrypted in transit and at rest using https/ssl/tls. Our database is encrypted, and everything sent over sftp is protected using PGP.

Password security for your account.

Changing the verification codes that some parties use to gain access.

Data is stored on safe, encrypted servers.

Limiting staff access to Personal Data, which is safeguarded by password logs and two-factor authentication.

Nondisclosure contracts with vendors

Consistent privacy and security training for employees

Retention and Disposal of Personal Data or Personal Information

1. User Data: 7 Years from the date of termination of contract

2. Employees data: 8 years as per Indian Companies Act

3. Financial data: 8 years as per Indian Companies Act

4. Audit logs: 1 Year

5. Other records: 3 Years

Children’s Personal Information

We knowingly do not assemble any personal data from minors under the age of 16. Please do not submit any personal information through our websites or services if you are under the age of 16.

In order to help implement this Policy, we encourage parents and other responsible adults to keep an eye on how their kids use the Internet and to teach them not to submit any personal data to the Websites or Services without their consent. Please contact us at eve@vananam.com if you have reason to suspect that a child under the age of 16 has supplied personal information to us through the Websites or Services, and we'll make commercially reasonable steps to have that information removed.

Your rights in relation to your information

• Access: You have the right to access information about the personal data we hold about you.
• Right to be informed about the data that we collect, process and store.
• Right to object to processing: You have the right to object to processing of your personal data.
• Rectification: You have the right to request rectification of inaccurate personal data held about you.
• Erasure: To the extent permitted by applicable data protection laws, you have the right to request erasure of personal data held about you.
• Request to restriction of processing: This enables you to request to restrict the processing of your personal data in certain circumstances.
• Rights in relation to automated decision-making, including profiling
• Portability: You have the right to obtain your personal data to enable you to reuse it.
• To exercise any of these rights, please email us at eve@vananam.com

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

1. The categories of Personal Data that we have collected about you.

2. The categories of sources from which that Personal Data was collected.

3. The business or commercial purpose for collecting or selling your Personal Data.

4. The categories of third parties with whom we have shared your Personal Data; and

5. The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient as per CCPA/CPRA.

Exercising Your Rights

Making Use of Your Rights

You must make us a request in order to use the rights outlined above.

provides enough details for us to be able to confirm that you are the person about whom we have obtained Personal Data (you will need to send an email from the relevant account or login information in order to do this), and (2) clearly expresses your request so that we can comprehend, consider, and respond to it. Every request that satisfies both of these requirements is regarded as a "Valid Request." Requests that don't fit these requirements might not get a response from us. To authenticate you and finish your request, we will only utilize the Personal Data you submit in a Valid Request.

You may submit a Valid Request by emailing eve@vananam.com

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to do, and we may request a copy of this written permission from your Authorized Agent when they make a request to exercise your rights on your behalf.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA/CPRA.

We will not discriminate against you for exercising your rights under the CCPA/CPRA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA/CPRA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA/CPRA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Complaints and Grievances

Any complaints or grievances received about our use of Personal Data, Personal Information or Sensitive Personal Data and any communications regarding enforcement of your privacy rights should be promptly directed to our Data Protection Officer Complaints.

Contact -

Attn: Data Protection Officer

Email ID - eve@vananam.com

Updates to Our Policy

We may amend or update our Privacy Policy. We will provide you notice of amendments to this Privacy Policy, as appropriate, and update the “Last modified” date at the top of this Privacy Policy. Please review our Privacy Policy from time to time.