This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the Rules made thereunder and the amended provisions pertaining to electronic documents/records in various statutes as amended by the Information Technology Act, 2000. This Privacy Policy does not require any physical, electronic, or digital signature.This Privacy Policy is a legally binding document between you and WOGOM. The terms of this privacy policy will be effective upon your acceptance of the same (directly or indirectly in electronic form, by clicking on the “I accept” tab or by use of the website or by other means) and will govern the relationship between you and WOGOM for your use of the Website (defined below).This document is published and shall be construed in accordance with the provisions of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000; which require publishing of the privacy policy for the collection, use, storage and transfer of sensitive personal data or information.Please read this Privacy Policy carefully. By using the website, you indicate that you understand, agree, and consent to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use this website. You hereby provide your unconditional consent or agreements to WOGOM as provided under Section 43A and Section 72A of the Information Technology Act, 2000.By providing us your Information or by making use of the facilities provided by the Website, you hereby consent to the collection, storage, processing, and transfer of any or all of your Personal Information and Non-Personal Information by WOGOM as specified under this Privacy Policy. You further agree that such collection, use, storage, and transfer of your Information shall not cause any loss or wrongful gain to you or any other person.WOGOM Private Limited and its affiliates (individually and/ or collectively, "WOGOM") is/are concerned about the privacy of the data and information of users accessing WOGOM’s website ("Website"). The terms "We" / "Us" / "Our" individually and collectively refer to each entity being part of the definition of WOGOM and the terms "You" / "Your" / "Yourself" refer to the users. This Privacy Policy is a contract between you and WOGOM, whose website you use or access or you otherwise deal with. This Privacy Policy shall be read together with WOGOM’s Terms of Use or other terms and condition of WOGOM.WOGOM has provided this Privacy Policy to familiarize You with:
The type of data or information that you share with or provide to WOGOM and that WOGOM collects from You.
The purpose for collection of such data or information from you.
WOGOM’s information security practices and policies.
WOGOM’s policy on sharing or transferring your data or information with third parties. This Privacy Policy may be amended / updated from time to time. Upon amending / updating the Privacy Policy, we will accordingly amend the date above. We suggest that you regularly check this Privacy Policy to apprise yourself of any updates. Your continued use of Website or provision of data or information thereafter will imply your unconditional acceptance of such updates to this Privacy Policy.
The "Information" (which shall also include data) provided by you to WOGOM or collected from you by WOGOM may consist of "Personal Information" and "Non-Personal Information".
Personal Information: “Personal Information” is Information collected that can be used to uniquely identify or contact you. Personal Information for the purposes of this Privacy Policy shall include, but not be limited to:
Your user name along with Your password.
Your name.
Your address.
Your telephone number.
Your e-mail address or other contact information.
Your date of birth.
Your gender.
Information regarding your transactions on the Website, (including sales or purchase history).
Your financial information such as bank account information or credit card or debit card or other payment instrument details.
Internet Protocol address.
Any other items of ‘sensitive personal data or information' as such term is defined under the Information Technology (Reasonable Security Practices And Procedures And Sensitive Personal Data Of Information) Rules, 2011 enacted under the Information Technology Act, 2000.
Identification code of your communication device which you use to access the Website or otherwise deal with WOGOM.
Any other Information that you provide during your registration process, if any, on the Website. Such Personal Information may be collected in various ways including during the course of you:
registering as a user on the Website.
availing certain services offered on the Website. Such instances include but are not limited to making an offer for sale, online purchase, participating in any online survey or contest, communicating with WOGOM’s customer service by phone, email or otherwise or posting user reviews on the items available on the Website.
otherwise doing business on the Website or otherwise dealing with WOGOM. We may receive Personal information about you from third parties, such as social media services, commercially available sources and business partners. If you access Website through a social media service or connect a service on Website to a social media service, the information we collect may include your user name associated with that social media service, any information or content the social media service has the right to share with us, such as your profile picture, email address or friends list, and any information you have made public in connection with that social media service. When you access the Website or otherwise deal with WOGOM through social media services or when you connect any Website to social media services, you are authorizing WOGOM to collect, store, and use and retain such information and content in accordance with this Privacy Policy.
Non-Personal Information: WOGOM may also collect information other than Personal Information from you through the Website when you visit and / or use the Website. Such information may be stored in server logs. This Non-Personal Information would not assist WOGOM to identify you personally. This Non-Personal Information may include:
Your geographic location.
details of Your telecom service provider or internet service provider.
the type of browser (Internet Explorer, Firefox, Opera, Google Chrome etc.).
the operating system of your system, device and the Website you last visited before visiting the Website.
The duration of your stay on the Website is also stored in the session along with the date and time of your access, Non-Personal Information is collected through various ways such through the use of cookies. WOGOM may store temporary or permanent ‘cookies' on your computer. You can erase or choose to block these cookies from your computer. You can configure your computer's browser to alert you when we attempt to send you a cookie with an option to accept or refuse the cookie. If you have turned cookies off, you may be prevented from using certain features of the Website.
Advertisements: WOGOM may use third-party service providers to serve ads on WOGOM’s behalf across the internet and sometimes on the Website. They may collect Non-Personal Information about Your visits to the Website, and Your interaction with our services on the Website. Please do note that Personal Information and Non Personal Information may be treated differently as per this Privacy Policy.
You hereby represent to WOGOM that:
The Information you provide to WOGOM from time to time is and shall be authentic, correct, current and updated and You have all the rights, permissions and consents as may be required to provide such Information to WOGOM.
Your providing the Information to WOGOM and WOGOM’s consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third party agreement, laws, charter documents, judgments, orders and decrees.
WOGOM officers, partners, employees, contractors or agents shall not be responsible for the authenticity of the Information that You or any other user provide to WOGOM. You shall indemnify and hold harmless WOGOM and itsofficers, partners, employees, contractors or agents and any third party relying on the Information provided by You in the event You are in breach of this Privacy Policy including this provision and the immediately preceding provision above.
Your Information will primarily be stored in electronic form however certain data can also be stored in physical form. We may store, collect, process and use your data in countries other than Republic of India but under compliance with Applicable Laws (“Applicable Laws” shall mean and include all applicable statutes, enactments, acts of legislature or the Parliament, laws, ordinances, rules, bye-laws, regulations, notifications, guidelines, policies, directions, directives and orders of any governmental authority, tribunal, board, court of India). We may enter into agreements with third parties (in or outside of India) to store or process your information or data. These third parties may have their own security standards to safeguard your information or data and we will on commercial reasonable basis require from such third parties to adopt reasonable security standards to safeguard your information / data.
Purpose for collecting, using, storing and processing your Information WOGOM collects, uses, stores and processes your Information for any purpose as may be permissible under Applicable Laws (including where the Applicable Laws provide for such collection, usage, storage or processes in accordance with the consent of the user) connected with a function or activity of WOGOM shall include the following:
to facilitate your use of the Website or other services of WOGOM.
to respond to your inquiries or fulfill your requests for information about the various products and services offered on the Website.
to provide you with information about products and services available on the Website and to send you information, materials, and offers from WOGOM.
to send you important information regarding the Website, changes in terms and conditions, user agreements, and policies and/or other administrative information.
to send you surveys and marketing communications that WOGOM believes may be of interest to you.
to personalize your experience on the Website by presenting advertisements, products and offers tailored to your preferences.
to help you address your problems incurred on the Website including addressing any technical problems.
for proper administering of the Website.
to conduct internal reviews and data analysis for the Website (e.g., to determine the number of visitors to specific pages within the Website).
to improve the services, content and advertising on the Website.
to provide value added services such as Single Sign On. Single Sign On shall mean a session/user authentication process that permits a user to enter his/her name or mobile number or e-mail address or any combination thereof and password in order to access multiple websites and applications.
to facilitate various programmes and initiatives launched by WOGOM or third party service providers and business associates.
to analyze how our services are used, to measure the effectiveness of advertisements, to facilitating payments.
to conducting academic research and surveys.
to protect the integrity of the Website.
to respond to legal, judicial, quasi judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law.
to conduct analytical studies on various aspects including user behavior, user preferences etc.
to permit third parties who may need to contact users who have bought products from the Website to facilitate installation, service and any other product related support.
to implement information security practices.
to determine any security breaches, computer contaminant or computer virus.
to investigate, prevent, or take action regarding illegal activities and suspected fraud.
to undertake forensics of the concerned computer resource as a part of investigation or internal audit.
to trace computer resources or any person who may have contravened, or is suspected of having or being likely to contravene, any provision of law including the Information Technology Act, 2000 that is likely to have an adverse impact on the services provided on any Website or by WOGOM.
to enable a potential buyer or investor to evaluate the business of WOGOM. [Individually and collectively referred to as ("Purposes")] You hereby agree and acknowledge that the Information so collected is for lawful purpose connected with a function or activity of WOGOM or any person on their respective behalf, and the collection of Information is necessary for the Purposes.
Sharing and disclosure of Your Information:You hereby unconditionally agree and permit that WOGOM may transfer, share, disclose or part with all or any of your Information, within and outside of the Republic of India to WOGOM itself and/or to third party service providers / partners / banks and financial institutions for one or more of the Purposes or as may be required by the Applicable Laws. In such case we will contractually oblige the receiving parties of the Information to ensure the same level of data protection that is adhered to by WOGOM under the Applicable Laws.You acknowledge and agree that, to the extent permissible under the Applicable Laws, it is adequate that when WOGOM transfers your Information to any other entity within or outside your country of residence, WOGOM will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy.WOGOM may share statistical data and other details (other than Your Personal Information) without your express or implied consent to facilitates various programmes or initiatives launched by WOGOM, its affiliates, agents, third party service providers, partners or banks & financial institutions, from time to time. We may transfer/disclose/share Information (other than Your Personal Information) to those parties who support our business, such as providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertisements, facilitating payments, or conducting academic research and surveys. These affiliates and third party service providers shall adhere to confidentiality obligations consistent with this Privacy Policy. Notwithstanding the above, we may use other third parties such as a credit/debit card processing company, payment gateway, pre-paid cards etc. to enable you to make payments for availing services on WOGOM. When you sign up for these services, you may have the ability to save your card details for future reference and faster future payments. In such case, we may share your relevant Personal Information as necessary for the third parties to provide such services, including your name, residence and email address. The processing of payments or authorization is solely in accordance with these third parties policies, terms and conditions and we are not in any manner responsible or liable to you or any third party for any delay or failure at their end in processing the payments.WOGOM smay also share Personal Information if WOGOM sbelieve it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of various terms and conditions or our policies.We reserve the right to disclose your information when required to do so by law or regulation, or under any legal obligation or order under law or in response to a request from a law enforcement or governmental agency or judicial, quasi-judicial or any other statutory or constitutional authority or to establish or exercise our legal rights or defend against legal claims.You further agree that such disclosure, sharing and transfer of your Personal Information and Non-Personal Information shall not cause any wrongful loss to you or to any third party, or any wrongful gain to us or to any third party.Links to third party websitesLinks to third-party advertisements, third-party websites or any third party electronic communication service may be provided on the Website which are operated by third parties and are not controlled by, or affiliated to, or associated with, WOGOM unless expressly specified on the Website.WOGOM is not responsible for any form of transmission, whatsoever, received by you from any third party website. Accordingly, WOGOM does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such third party websites, nor does WOGOM control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such third party websites. The inclusion or exclusion does not imply any endorsement by WOGOM of the third party websites, the website's provider, or the information on the website. The information provided by you to such third party websites shall be governed in accordance with the privacy policies of such third party websites and it is recommended that you review the privacy policy of such third party websites prior to using such websites.Security & RetentionThe security of your Personal Information is important to us. WOGOM strives to ensure the security of Your Personal Information and to protect Your Personal Information against unauthorized access or unauthorized alteration, disclosure or destruction. For this purpose, WOGOM adopts 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 WOGOM stores Your Personal Information. WOGOM shall adopt reasonable security practices and procedures as mandated under Applicable Laws for the protection of your Information. Provided that your right to claim damages shall be limited to the right to claim only statutory damages under Information Technology Act, 2000 and you hereby waive and release WOGOM from any claim of damages under contract or under tort.If you choose a payment gateway to complete any transaction on Website then your credit card data may be stored in compliance with industry standards/ recommended data security standard for security of financial information such as the Payment Card Industry Data Security Standard (PCI-DSS).WOGOM may share your Information with third parties under a confidentiality agreement which inter alia provides for that such third parties not disclosing the Information further unless such disclosure is for the Purpose. However, WOGOM is not responsible for any breach of security or for any actions of any third parties that receive Your Personal Information. WOGOM is not liable for any loss or injury caused to You as a result of You providing Your Personal Information to third party (including any third party websites, even if links to such third party websites are provided on the Website).Notwithstanding anything contained in this Policy or elsewhere, WOGOM shall not be held responsible for any loss, damage or misuse of Your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event (as defined below).A Force Majeure Event shall mean any event that is beyond the reasonable control of WOGOM and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer, computer system or computer network,computer crashes, breach of security and encryption (provided beyond reasonable control of WOGOM), power or electricity failure or unavailability of adequate power or electricity.While we will endeavor to take all reasonable and appropriate steps to keep secure any Personal Information which we hold about you and prevent unauthorized access, you acknowledge that the internet or computer networks are not fully secure and that we cannot provide any absolute assurance regarding the security of your Personal Information.You agree that all Personal Information shall be retained till such time required for the Purpose or required under Applicable Laws, whichever is later. Non-Personal Information will be retained indefinitely.User discretion and opt outYou agree and acknowledge that you are providing your Information out of your free will. You have an option not to provide or permit WOGOM to collect your Personal Information or later on withdraw your consent with respect to such Personal Information so provided herein by sending an email to the grievance officer or such other electronic address of WOGOM as may be notified to you. In such case, you should neither visit any Website nor use any services provided by WOGOM nor shall contact WOGOM.You can add or update your Personal Information on regular basis. Kindly note that WOGOM would retain your previous Personal Information in its records.Grievance OfficerIf you find any discrepancies or have any grievances in relation to the collection, storage, use, disclosure and transfer of Your Personal Information under this Privacy Policy or any terms and conditions or polices of WOGOM, please contact the following:For WOGOM:Mr. Nirav Patel, the designated grievance officer under Information Technology Act, 2000 E-mail: info@wogom.comThe details of the grievance officer may be changed by us from time to time by updating this Privacy Policy.Business / Assets Sale or TransfersWOGOM may sell, transfer or otherwise share some or all of its assets, including Your Information in connection with a merger, acquisition, reorganization or sale of assets or business or in the event of bankruptcy. Should such a sale or transfer occur, WOGOM will reasonably ensure that the Information you have provided and which we have collected is stored and used by the transferee in a manner that is consistent with this Privacy Policy. Any third party to which WOGOM transfers or sells as aforesaid will have the right to continue to use the Information that you provide to us or collected by us immediately prior to such transfer or sale.Further AcknowledgementsYou hereby acknowledge and agree that this Privacy Policy:
is clear and easily accessible and provide statements of WOGOM policies and practices with respective to the Information.
provides for the various types of personal or sensitive personal data of information to be collected.
provides for the purposes of collection and usage of the Information.
provides for disclosure of Information.
Provides for reasonable security practices and procedures.
For WOGOM’s European usersThe European General Data Protection Regulation (“GDPR”) imposes specific obligation on WOGOM with regard toitsrelationship with you. This annexure is an integral part of the Privacy Policy in order to demonstrate WOGOM’s compliance with the GDPR.For purposes of this Privacy Policy, “GDPR” means Regulation (EU) 2016/679, the General Data Protection Regulation, together with any addition implementing legislation, rules or regulations that are issued by applicable supervisory authorities. Words and phrases in this Privacy Policy shall, to the greatest extent possible, have the meanings given to them in Article 4 of the GDPR. In particular: (a) “Personal Data“ has the meaning to give it in Article 4(1) of the GDPR: “any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person,” but only to the extent such personal data pertain residents of the European Economic Area (EEA) or are otherwise subject to the GDPR. (b) “Personal Data Breach” has the meaning given to it in Article 4(12) of the GDPR: “[any] breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.” (c) “Processing” has the meaning given to it in Article 4(2) of the GDPR: “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;” (d) “Subprocessor” means any processor as defined in Article 4(8) of the GDPR: “[any] natural or legal person, public authority, agency or other body which processes personal data” on behalf of the Processor (including any affiliate of the Processor). (e) “Transfer” means to disclose or otherwise make Personal Data available to a third party (including to any affiliate or Subprocessor), either by physical movement of the Personal Data to such third party or by enabling access to the Personal Data by other means.In accordance with GDPR Article 28(1), WOGOM represents that it has implemented appropriate technical and organizational measures in such a manner that its Processing of Personal Data will meet the requirements of the GDPR and ensure the protection of the rights of the data subjects.In accordance with GDPR Article 28(2), WOGOM shall not engage any Sub-processor without prior specific or general written authorization of you. In the case of general written authorization, the WOGOM shall inform you of any intended changes concerning the addition or replacement of other Sub-processors and give you the opportunity to object to such changes. WOGOMshall also comply with the requirements for sub-processing as set forth in Article 28(4), namely that the data protection obligations set forth herein such be imposed upon the Sub-processor, so that WOGOM’s agreement with the Sub-processor contains sufficient guarantees that the Processing will meet the requirements of the GDPR.In accordance with GDPR Article 28(3), the following terms are incorporated in this Privacy Policy:
WOGOM shall only process the Personal Data only (i) as needed to provide the services, (ii) in accordance with the specific instructions that it has received from You, including with regard to any transfers, and (iii) as needed to comply with applicable law (in which case, WOGOM shall provide prior notice to You of such legal requirement, unless that law prohibits this disclosure).
WOGOM shall ensure that persons authorized to process the Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
WOGOM shall take all security measures required by GDPR Article 32, namely: (i) Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, WOGOM shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (a) the pseudonymisation and encryption of Personal Data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; (d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing. (ii) In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed. (iii)WOGOM shall take steps to ensure that any natural person acting under the authority of WOGOM who has access to Personal Data does not process them except on instructions from you, unless he or she is required to do so by EEA Member State law.
Taking into account the nature of the processing, WOGOM shall reasonably assist you by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of your obligation to respond to requests for exercising the data subject's rights.
Taking into account the nature of processing and the information available to WOGOM, WOGOM shall comply with (and shall reasonably assist Acme to comply with) the obligations regarding Personal Data Breaches (as set forth in GDPR Articles 33 and 34), data protection impact assessments (as set forth in GDPR Article 35), and prior consultation (as set forth in GDPR Article 36).
At Your discretion, WOGOM shall delete or return all the Personal Data to you after the end of the provision of services relating to Processing, and delete existing copies unless applicable EEA member state law requires storage of the Personal Data.
WOGOM shall provide you with all information necessary to demonstrate compliance with the obligations laid down in the GDPR, and allow for and contribute to audits, including inspections, conducted by you or another auditor mandated by WOGOM .
WOGOM shall immediately inform you if, in its opinion, an instruction infringes the GDPR other Union or Member State data protection provisions.
WOGOM shall not Transfer any Personal Data (and shall not permit its Sub-processors to Transfer any Personal Data) without your prior consent. WOGOM understands that you must approve and document that adequate protection for the Personal Data will exist after the Transfer, using contracts that provide sufficient guarantees (such as standard contractual clauses) unless another legal basis for the Transfer exists.WOGOM shall promptly and thoroughly investigate all allegations of unauthorized access to, use or disclosure of the Personal Data. WOGOM will notify you without undue delay in the event of any Personal Data Breach.WOGOM shall maintain all records required by Article 30(2) of the GDPR, and (to the extent they are applicable to WOGOM’s activities).WOGOM shall make them available to you upon request.