PRIVACY POLICY

This privacy policy (Privacy Policy) will help you understand what information we collect at the Company, why we collect it, how the Company uses it, including if and how we share the information with third parties, and the choices you have.     

Capitalized terms in this Privacy Policy would have their meaning as set out under the Terms of Use. This Privacy Policy is incorporated into and is subject to the Terms of Use. By accepting the Terms of Use, you expressly consent to our use, processing, transfer and disclosure of your personal information in accordance with this Privacy Policy. When we talk about “we,” “our,” or “us” in this Privacy Policy, we are referring to the Company. When we talk about “you” in this Privacy Policy, we are referring to the User.

By clicking on the "I Agree" button below, you expressly agree to the terms of this Privacy Policy, for your use of the Florence mobile application (the App) and for the collection, processing, storage, use, disclosure, transfer and otherwise handling of your data (including personal data, sensitive personal data, and credit information) in accordance with the terms contained below. Please note that you have the option to not provide your sensitive personal data to us, however, we will not be able to provide you with access to the App in case you elect to do so. If you do not wish to provide us with your personal or sensitive personal data, please do not use the App and uninstall it from your devices.        

We may revise the Privacy Policy from time to time. While we may not be able to separately notify you of the revisions each time that we make them, we will notify you and obtain your consent for any changes that we make to this policy when required under law. We encourage you to check this page periodically for modifications or revisions to the Privacy Policy to understand how it affects the use of your information. We will not be responsible for your failure to remain informed about such changes.

  1. INFORMATION WE COLLECT AND RECEIVE
  1. Personal Information Collected from You

The data that we collect from you may contain 'sensitive personal data or information' or 'personal information' as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (Data Protection Rules). The personal information which the Company will collect, store, use, process, and transfer may include but is not restricted to: name, gender, date of birth, bank account details, home address, email IDs, phone-numbers and other contact information of the User. With your consent, we may also collect documents that may serve as proof of identity and address, the details of your income and expenditure and personal information through surveys conducted by us. We may extract any and all identifiers from these documents and surveys, and use them for the Purposes mentioned below, in accordance with law. You are not required to provide your Aadhaar number for the use of this App and the submission of your Aadhaar number is entirely voluntary.  

Third parties such as credit information bureaus, payment gateways and our partner NBFC may also process your personal information separately. To the extent not specified in this Privacy Policy, any processing of your personal information by such third parties will be governed by the terms of their privacy policies, which are set out below and you may have to sign up to some of these policies:  

Equifax, Perfios, Karza, Apollo Finvest, Crif and Cashfree

  1. Other Personal or Sensitive Personal Information You Provide
  1. Retention

The information above would be collected and retained by the following entity:

Hora Education & Services Pvt Ltd

We will not retain any sensitive personal data or information for longer than is required for the purpose for which such data or information was collected, or may lawfully be used, or is otherwise required under any other law for the time being in force. We may retain anonymized data for as long as is required.

  1. Our Cookie Policy

We use cookies and similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies. Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit the App. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.

Some cookies are associated with your account and personal information in order to remember that you are logged in and which accounts you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things.

  1. PURPOSE OF COLLECTION

In addition to the purposes mentioned in Part A.2 above, the Company may process information including sensitive personal data or information concerning you both internally and externally (so far as reasonably necessary) for the purposes mentioned below (the purposes in A.2 and contained below together Purposes).

You have the option to refrain from disclosing your sensitive personal data or information to the Company. You will also have the option of withdrawing consent previously provided to the Company. However, exercising this option will hamper the Company's ability to provide you with any or all of the features of the App.

  1. Purposes.

We use personal information of Users for the following purposes:

This Privacy Policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable User of the App.

  1. YOUR CHOICES

1.        Your Data

You provide us with instructions on what to do with your data. You have many choices and control over your data. For example, you may provision or deprovision access to the App, enable or disable third party integrations, manage permissions, change retention and export settings and transfer or assign your data.

2.        Access to Personal Data or Information

You will have the right, upon request, to access and review the personal information provided by you and held by the Company. Upon discovering that the information provided is inaccurate or deficient in any manner, you will have the right to request suitable changes or amendments to such information, which may be provided by the Company, when feasible.

3.        Other Choices

In addition, your mobile device may provide you with choices around how and whether location or other data is collected and shared. The Company does not control these choices, or default settings, which are offered by makers of your mobile device's operating system.

  1. SHARING AND DISCLOSURE

The Company will not publish or disclose your personal information pertaining without your prior consent, unless it is required to do so in order to facilitate use of the App, or for the Purposes (as indicated in Part B), or if mandated by law, or if you have previously provided your consent. The Company may disclose personal information with its employees, officers, agents, consultants, business associates, contractors, attorneys, etc., on a need to know basis for the Purposes.

The Company will disclose any sensitive personal data and information if there is a legal requirement or if it is ordered to do so by a court of competent jurisdiction or to any government agency if required by law for the purposes of verification of identity, or for prevention, detection, or investigation of crime (including cyber incidents), or for prosecution or punishment of offences.

  1. TRANSFER

The Company may transfer personal information pertaining to you to third parties for the Purposes. You are expressly notified that the transfer may also be to foreign jurisdictions where your personal information may be processed by third-party service providers and vendors, or our group companies, in relation to the Purposes (as indicated in Part B).

  1. SECURITY

The Company ensures the confidentiality and security of the personal information and sensitive personal data and information provided by you by implementing comprehensive information security practices and standards as mandated by the Data Protection Rules. We have adopted the ISO 27001 security standard to protect the confidentiality and security of your information.

  1. GRIEVANCE OFFICER

If you have any concerns or questions in relation to this Privacy Policy, you may address them to our grievance officer whose name and email address are as follows:

                 Mr Karan Garg

    userpolicy@hora.ai

Hora Education & Services Pvt Ltd

G-92, Basement, Kalkaji, New Delhi- 110019