SKOOTR GLOBAL PRIVATE LIMITED
Skootr Global Private Limited (hereinafter referred to as the, “Skootr”, “Company”, “It” “We”, “Us” or “Our”) is inter-alia engaged in the business of finding, establishing, managing, operating and providing managed and serviced offices, co-working spaces, business centres and plug and play services (hereinafter referred to as the “Services”).
This Policy describes
the type of information that Skootr may collect from you when you access or use the website, www.skootr.com (hereinafter referred to as the “Website”), including but not limited to the personal information shared by you for enquiring about the Services, rendering real estate consultancy, applying for jobs with Skootr, etc.; and
the practices for collecting, using, maintaining, protecting and disclosing the information followed by Skootr.
This Policy applies only to the Personal Information (defined herein below) collected by Skootr during your use of the Website, through e-mail and through other electronic communications sent through the Website. This Policy does not apply to the information that you provide to, or that is collected by, any third party, such as social media networks, property consultants, job portals, etc. Skootr encourages you to consult directly with such third parties regarding their privacy practices. Your Personal Information shall be processed and stored subject to your explicit consent, which shall be obtained at the time, when Skootr collects your Personal Information.
This Policy is also applicable to you irrespective of (i) if you access the Website outside India; (ii) if you are a national of European Union/ European Economic Area. The rights and obligation of the users residing in the European Union shall be governed in accordance with the European Union’s General Data Protection Regulation (EU GDPR) and users residing in countries falling outside European Union shall accrue rights and obligations as have been provided by the law of their country of their residence.
By accessing or using the Website, you agree to this Policy and you consent to the collection, use, retention and disclosure of your Personal Information by Skootr in accordance with this Policy.
In the event, you do not provide the Personal Information required by Skootr, Skootr may not be able to provide the complete use or access to the Website or the Services provided thereto.
If you have any queries or concerns regarding this Policy, you may contact us at email@example.com.
2. WHAT INFORMATION DOES SKOOTR COLLECT?
Skootr respects your privacy and are committed to protecting it in all respects from any unlawful disclosure. In order to enrich and facilitate your access and use of the Website, Skootr collects the following information from and about you including:
Information about your internet connection, the equipment you use to access the Website and your usage details
No information which is freely available and accessible in the public domain or is furnished to any authority, organization, department or public at large through no act or default by Skootr under any law for the time being in force shall be considered as Personal Information or “Sensitive Personal Information”, as the case may be.
Personal Information is collected by Skootr, either directly from you and/or automatically as you access or use the Website.
3. HOW SKOOTR COLLECTS INFORMATON
Skootr collect information from you in the following manner:
Directly from you when you provide it to Skootr; and/or
Automatically, as you navigate through the Website (information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies).
3.1) Information that you provide to Skootr directly:
Skootr uses the information that you provide to Skootr to enhance the functionality as well as improve the quality of the Website and Services, and to personalize your experience while using the Website. Skootr also uses the information to display relevant advertising, to provide support to you, communicate with you or comply with the legal obligations of Skootr.
For Service Enquiries: In case you make an enquiry in respect of the Services rendered by Skootr, Skootr collects the following personal information: your full name, email address, mobile number, name of your employer and other personal information.
For Property Consultants and Developers: In case you are a property consultant: In case you are or are employed with a property consultant; and you make an enquiry for the Services rendered by Skootr, Skootr collects the following information: your full name, email address, mobile number, name of your employer, designation, location, password and other personal information.
For Job Applications: When you apply for a job at Skootr, Skootr will ask you to provide us with Personal Information about yourself, so that Skootr can evaluate your application. The Personal Information that Skootr collects about you may include: name, address, email address, telephone, other contact information, employment details, including previous employment background,designation, work experience, employment references, salary and other compensation requests, education qualification,financial information including salary, tax information, benefits. Further, you may also share certain Personal Information that Skootr may have not specifically requested, for example your CV may contain information about your hobbies and social preferences.
For avoidance of any doubt, it is clarified that Skootr does not request or require Sensitive Personal Information regarding religion, health, sexual orientation or political affiliation.
3.2) Information that Skootr collects through Data Collection Technologies
Skootr may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Website, and about your use of the Website, even if you use the Website without registering or logging in.
Usage Information: Details of your use of the Website, including traffic data, location data, logs and other communication data and the resources that you access and on or through the Website.
Computer Device Information: Information about your computer, internet connection and mobile devices, including your IP address, operating systems, platforms, browser type, other browsing information (connection, speed, connection type, etc.), device type, device’s unique identified, mobile network information and device’s telephone number.
Mobile device IDs: Unique mobile device identifier (eg: IDFA or other device IDs on Apple devices like the iPhone or iPad), if you are using the Website on a mobile device, Skootr may use mobile device IDs (the unique identifier assigned to a device by the manufacturer), instead of cookies to recognize you. Skootr may do this to store your preferences and track your use of the Website. Unlike cookies, mobile device IDs cannot be deleted. Advertising companies may use device IDs to track your use of the Website, track the number of advertisements displayed, and measure advertising performance and display advertisements that are more relevant to you. Analytics companies may use mobile device IDs to track your usage of our Website.
Your preferences: Your preferences and setting such as time zone and language.
Your activity on the Website: Information about your activity on the Website, such as your search queries, domain names, search results selected, number of clicks, pages viewed and the order of those pages, how long you visited the Website, the date and time you used the Website, error logs, and other similar information.
Your searches and other activities: The search terms you have looked up and results that you selected.
Your browsing information: How long you used the Website and which features you used.
A cookie is a small text file that is stored on your computer that enables us to recognize you (for example, as a registered user) when you visit our website, store your preferences and settings, enhance your experience by delivering content and advertising specific to your interests, perform research and analytics, track your use of the Website, and assist with security and administrative functions. Cookies may be persistent or stored only during an individual session.
A pixel tag (also called a web beacon or clear GIF) is a tiny graphic with a unique identifier, embedded invisibly on a webpage (or an online ad or email), and is used to count or track things like activity on a webpage or ad impressions or clicks, as well as to access cookies stored on users' computers. Skootr uses pixel tags to measure the popularity of our various pages, features and services. Skootr may also include web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics.
Flash cookies operate differently than browser cookies and cannot be removed or blocked via web browser settings.
A cookie is not used to gather your Personal Information without your knowledge but instead to record information on site browsing which can be read directly by Skootr on your subsequent visits and searches on the Website. All cookies have expiration dates in them that determine how long they stay in your browser.
By default, cookies are not installed automatically (with the exception of those cookies needed to run the Website, and you are informed of their installation by a notification). Skootr will require your authorization before implanting any other kind of cookies on your hard drive. To avoid being bothered by these routine requests for authorization and to enjoy uninterrupted browsing, you can configure your computer to accept our cookies automatically.
3.4) Anonymous Data
Skootr may anonymize information collected from you through the Website or via other means, including via the use of third-party web analytic tools. As a result, Skootr’s use and disclosure of aggregated anonymized information is not restricted by this Policy, and it may be used and disclosed to others without limitation.
4. HOW SKOOTR STORES, PROCESSES AND SHARES INFORMATION?
Skootr collects the above Information from you only to provide better and efficient services through the Website. The Information furnished by you enables Skootr to improve the Website and provide you the most User-friendly experience while you transact with Skootr for getting newly developed and/or customized written content as per your specifications and requirements. The service and the Website depend on the information sought and Skootr may use the above said information to, maintain, protect, and improve the services (including advertising services). However, the Website shall retain the data uploaded by you on the Website for record keeping purposes.
The Information so collected varies from individual to individual and hence, may be stored with different data controllers and processors associated with Skootr, depending upon the processing requirement.
Skootr takes appropriate security measures to protect against any unauthorized access, alteration, modification, disclosure or destruction of data uploaded and stored by you. These include internal reviews of our 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 personal data. Skootr has implemented appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to your information and to maintain data security. These safeguards take into account the sensitivity of the information that Skootr collects, processes and stores and the current state of technology. Skootr follows generally accepted industry standards to protect the personal information submitted to Skootr, both during transmission and once we receive it.
All information gathered on Website is securely stored behalf of Skootr on third-party infrastructure provider Amazon Web Services. The database is stored in an encrypted form and processed on the servers provided by Amazon Web Services; with the access to the servers being password-protected and strictly limited. You can find more information about “Amazon Web Services” security practices at https://aws.amazon.com/security/. However, as effective as the security measures maintained by Skootr are, no security system is impenetrable. Skootr cannot guarantee the security of Skootr’s database, nor can Skootr guarantee that the information supplied to Skootr by you will not be intercepted while being transmitted to Skootr over the Internet. Internet is an ever evolving medium. Skootr may change this Policy from time to time to incorporate necessary future changes. Of course, Skootr’s use of any information that Skootr gathers will always be consistent with the policy under which the information was collected, regardless of what the new policy may be.
Skootr assumes no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your personal information secure. You should not share your username, password, or other security information for your account with anyone. If Skootr receives instructions using your username and password, Skootr will consider that you have authorized the instructions.
Skootr hereby explicitly informs you that any information uploaded, shared or put on the Website by you shall be viewable and accessible for record-keeping, analysis and verification by the third party authorized by us for the purpose of providing the Services including the use of the Website. Skootr takes all reasonable measures to protect any and all information collected by Skootr and the same is shared with third party sub-contractors only for the purposes of the completing the contractual transaction between Skootr and us.
5. HOW SKOOTR USES THE INFORMATION?
We use the information we collect from and about you for a variety of purposes, including:
5.1) contacting you to understand your requirements for the Services, including sharing prospective terms for the Services;
5.2) organizing physical demonstration of the Services offered;
5.3) sharing notifications in relation to the Services;
5.4) Process and respond to your queries;
5.5) Provide you with customer support;
5.6) Understand your usage (how you use the Website, what features you like, etc.), improve the content and features of the Website;
5.7) Diagnose technical problems;
5.8) Send you communications that you have requested or that may be of interest to you by way of emails, or courier, or registered post, or telephone calls, or any other mode of communication;
5.9) Generate and review reports and data about, and to conduct research on the user base and Service usage patterns;
5.10) Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
5.11) to assist you in password retrieval and policy changes;
5.12) to preserve history as governed by existing law or policy.
5.13) to send information including confirmations, technical notices, updates, security alerts and support and administrative messages;
5.14) to communicate about promotions, upcoming events, and other news about products and services offered by us;
5.15) to meet any applicable law, regulation and legal process;
5.16) in response to law enforcement authority or other governmental official request;
5.17) to detect, prevent, or otherwise address fraud, security or technical issues;
5.18) to protect against harm to our rights, property or safety, our users or the public as required or permitted by law;
5.19) disclosure may also be required for our audit or to investigate a complaint or security threat;
5.21) Notify you about changes to the Website;
5.22) recruitment, selection, evaluation and appointment of job candidates (temporary or permanent) for the job you have applied for and for subsequent job opportunities
5.23) general HR administration and management
5.24) job application analysis such as verification of your employment reference(s) that you have provided, background checks and related assessments; and
5.25) For any other purpose with your consent.
6. HOW SKOOTR SHARES THE INFORMATION
6.1) General Disclosures
Skootr may disclose the information that Skootr collects or you provide, as described in this Policy, in the following ways:
6.1.1) To Skootr’s contractors, service providers and other third-parties whom Skootr uses to support Skootr’s business (e.g. property consultants, security service providers, house-keeping service providers, interior designers, etc., lessors, developers) and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which Skootr discloses it to them.
6.1.2) To third parties to market their products or services to you if you have consented to receive the promotional updates. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
6.1.3) To fulfil the purpose for which you provide it.
6.1.4) For any other purpose disclosed by us when you provide the information.
6.2) Legal Purposes
Skootr may share your information when Skootr believes in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. Skootr may also share your information to investigate and address threats or potential threats to the physical safety of any person, to investigate and address violations of this Policy, or to investigate and address violations of the rights of third parties and/or to protect the rights, property and safety of the Company, its employees, users, or the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations on account of legal request such as subpoena, court order or government demand to comply with the law.
6.3) Contractual Rights
Skootr may be required to disclose your Personal Information to enforce or apply our terms and conditions and other agreements.
Skootr may share your Personal Information in any other manner as may have been consented to by you.
6.5) Customer Testimonials / Comments / Reviews
From time to time, Skootr may post customer testimonials on the Website, which may contain personal information such as your name and designation. Skootr will always obtain the customers' consent prior to posting their names along with their testimonials
7. DATA ENCRYPTION
All the Personal Information transmitted and stored in Skootr’s server is fully encrypted.
8. CORRECTING THE INFORMATION
8.1) Skootr will take reasonable steps to accurately record the Personal Information that you provide to Skootr and any subsequent updates. In case you wish to review, update, and correct the Personal Information that Skootr maintains about you, or you wish to delete the Personal Information about you that is inaccurate, incomplete, you may do so by contacting the Privacy Officer (described in the Section below).
8.2) Subject to the applicable law, your right to review, update, correct, and delete your Personal Information may be limited:
8.2.1) Where the rights or safety of another person or persons would be encroached upon; or
8.2.2) If the information requested relates to any pending or threatened legal proceedings between you and Skootr.
8.2.3) Your right to review, update, correct, and delete your information is subject to Skootr’s records retention policies and applicable law, including any statutory retention requirements.
9. RIGHTS UNDER EU GDPR
The European Union General Data Protection Regulation (EU GDPR) has provided the below rights to the EU residents. You may exercise below mentioned rights as and when Skootr obtains or holds personal information about you, access personal information Skootr holds about you, and to obtain its correction, update, amendment or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations:
9.1) Right to access or rectify your information:
You have the right to request Skootr to access, rectify or delete your information stored with Skootr. You can ask Skootr to verify whether Skootr is processing personal information about you. You can ask Skootr to rectify Skootr’s records if you believe they contain incorrect or incomplete information about you. The right to access or rectify your information can be requested at firstname.lastname@example.org (hereinafter referred to as the “Designated Email Id”)
9.2) Right to restrict processing
You have the right to restrict processing of your personal information in circumstances where you:
9.a.1) Contest the accuracy of the personal information;
9.a.2) Prefer to restrict its use rather than having it erased;
9.a.3) Believe that Skootr no longer needs the Personal Information for the purpose of processing, but you may require Personal Information for establishment, exercise or defense of legal claims;
9.a.4) Have objected to processing, pending the verification of that objection. Please note that Skootr will duly inform you before revoking the restriction on processing.
Restriction to processing can be requested at the Designated Email Id.
9.3) Right to object to processing
You have the right to object to the processing of your information by Skootr on grounds pertaining to your particular situation, but only to the extent that the processing is not necessary for:
9.3.1) The performance of a task carried out in the public interest or in the exercise of any official authority vested in Skootr; or
9.3.2) The purposes of the legitimate interests pursued by Skootr or by a third party.
If you make such an objection, Skootr will cease to process the personal information unless Skootr can demonstrate compelling legitimate grounds including but not limited to:-
For the processing which override your interests, rights and freedoms, or if the processing is for the establishment, exercise or defence of legal claims. You can object to processing of your Personal Information by sending your objections at Designated Email Id.
9.4) Right to object to processing for direct marketing purpose
You have the right to object to the processing of your Personal Information by Skootr for direct marketing purposes including profiling. If you make such an objection, then Skootr will cease to process your Personal Information for this purpose. You can object to processing by sending your objections at Designated Email Id.
9.5) Right to object for scientific or historical research purposes or statistical purposes:
You have the right to object to the processing of your Personal Information by Skootr for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. You can object to processing by sending your objections at Designated Email Id.
9.6) Right to data portability:
Where you have provided Personal Information to Skootr, you can ask Skootr to transmit that Personal Information (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
9.7) Right to erasure:
You have the right to erase/ delete your Personal Information without undue delay in circumstances where:
9.7.1) Personal information is no longer necessary in relation to the purpose for which they were collected or processed;
9.7.2) You withdraw consent on which processing is based;
9.7.3) You object to the processing under certain data protection rules;
9.7.4) Processing is for direct marketing purposes and the Personal Information have been unlawfully processed;
9.7.5) Personal Information have to be erased for compliance with a legal obligation.
Please note that there are certain exclusions of the right to erasure. Such exclusions include where processing is necessary:
(a) For exercising the right of freedom of expression and information;
(b) For compliance with a legal obligation; or
(c) For the establishment, exercise or defence of legal claims.
You may direct deletion of your information by requesting at Designated Email Id.
9.8) Right to withdraw consent:
Your participation and all the survey invitations are always voluntary, and you can withdraw consent at any time. Withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. You can withdraw your consent by:
9.8.1) Sending your request to Designated Email Id; or
9.8.2) Selecting the opt-out link given in each email invitation.
9.9) Retaining and deleting your personal information
Skootr does not delete your Personal Information in its own discretion. You are responsible for and control the time periods for which you wish to retain this information. You can delete your Personal Information by sending your request at Designated Email Id. Please note that your Personal Information shall not be retained thereafter. However, Skootr may retain your information for compliance with a legal obligation to which Skootr is subject, or in order to protect your vital interests or the vital interests of another natural person.
10.TERMINATION OF ACCOUNT
You can close/terminate your account by visiting your profile settings page on the Website. Skootr may retain information about you for the purposes authorized under this Policy unless prohibited by law. Thereafter, Skootr will either delete your Personal Information or de-identify it so that it is anonymous and not attributed to your identity. For example, Skootr may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Website or to comply with legal obligations.
11. TO CONTACT SKOOTR’S PRIVACY OFFICER
If you have an enquiry or a complaint about the way Skootr handles your Personal Information, or seek to exercise your privacy rights in relation to the Personal Information that Skootr holds about you, you may contact Skootr’s Privacy Officer as follows:
By Email: email@example.com
By Mail: 12th Floor, Tower B, Building 9,
By Mail: 12th Floor, Tower B, Building 9,
Gurugram – 122022
For the purposes of the GDPR, Skootr’s Privacy Officer is also Skootr’s Data Protection Officer (DPO).
While Skootr endeavours to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, Skootr requests that you make your complaint in writing to our Privacy Officer, by mail or email as above. Skootr will acknowledge your formal complaint within 10 working days of receipt.
If Skootr does not resolve your privacy complaint to your satisfaction, you may proceed with the legal remedy in accordance with the law of the jurisdiction applicable upon you.