Privacy Policy

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 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 Of Information) Rules, 2011 Under Information Technology Act, 2000; That Require Publishing Of The Privacy Policy For Collection, Use, Storage And Transfer Of Sensitive Personal Data Or Information.

This Privacy Policy Is A Legally Binding Document Between You And Superfone (Both Terms Defined Below). 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 Application or Website Or By Other Means) And Will Govern The Relationship Between Superforne And You For Your Use Of The Application or Website.

Please Read This Privacy Policy Carefully. By Using This Application or 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 Application or Website. You Hereby Provide Your Unconditional Consent Or Agreement To Superfone As Provided Under Section 43a And Section 72a Of The Information Technology Act, 2000 And The Information Technology (Intermediary Guidelines) Rules, 2011.

TRUEGRIT TECHNOLOGIES PRIVATE LIMITED (referred as “Superfone” or “We” or “Us” or “Our") takes privacy very seriously. We know how important personal information is to the user of the Application (referred as "You" or "Your" or "Yourself" or "User") and by sharing this information We appreciate Your trust in Us.

By providing Your Information or by making use of the facilities provided by the Application, You hereby consent to the collection, storage, processing and transfer of any or all of Your Personal Information and Non-Personal Information by Us 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.

This Privacy Policy is intended to help the User fully understand what information We collect, why We collect it and how it is being managed. This document describes Our Privacy Policy. By visiting www.superfone.in and/or by downloading the Superfone application, the User is accepting all the terms, conditions, duties and liabilities that are described below. Capitalized terms that are not defined in this Privacy Policy shall have the same meaning as ascribed to them in our Terms of Service

This Privacy Policy lays out the following:

Collection and Storage of Information
Purpose for Collecting, Using, Storing and Processing of Information
Sharing and Disclosure of Your Information
Link to other websites
Security
Children’s Privacy
Data Protection Rights
Choice/Opt-Out
Data Retention
Security Measures and Safeguards
Updates to this Privacy Policy
Grievance Officer

COLLECTION AND STORAGE OF INFORMATION

The Information (which shall also include data) provided by You to Us or collected from You by Us may consist of "Personal Information" and "Non-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 name, address, contact number, e-mail addresses or other contact information, Information regarding Your transactions on the Application, Your financial information, 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 Application or any other Information that You provide during Your registration process, if any, on the Application.
Such Personal Information may be collected in various ways including during the course of You registering as a User on the Application, or availing certain services offered on the Application. Such instances include but are not limited to participating in any online survey or contest or otherwise or posting user reviews or otherwise doing business on the Application.
We may receive Personal information about You from third parties, such as social media services, commercially available sources and business partners. If You access the Application through a social media service or connect a service on the Application to a social media service, the information We collect may include Your account information associated with that social media service, any information or content the social media service has the right to share with Us, and any information You have made public in connection with that social media service. When You access the Application through social media services or when You connect Application to social media services, You are authorizing Us to collect, store, and use and retain such information and content solely for the Purposes (defined below) in accordance with this Privacy Policy.
We may also collect information other than Personal Information from You through the Application when You visit and / or use the Application. Such information may be stored in server logs. 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, IMEI and the Application You last visited before visiting the Application or the duration of Your stay on the Application 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. We 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 Application.
Please do note that Personal Information and Non-Personal Information may be treated differently as per this Privacy Policy.
You hereby represent to Us that: -

the Information You provide 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 Us.
Your providing the Information to Us and Our 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.

SuperFone and its officers, directors, contractors or agents shall not be responsible for the authenticity of the Information that You or any other user provide to Us. You shall indemnify and hold harmless SuperFone and its officers, directors, 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; provided, however, that 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. 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.

2. PURPOSE FOR COLLECTING, USING, STORING AND PROCESSING OF INFORMATION

We do not sell, transfer or rent Your personal information to third parties for their marketing purposes without Your explicit consent.

We do not voluntarily make this information available to third parties, nor does it use it for any other purpose, except as set out herein in this Privacy Policy.

SuperFone collects, uses, stores and processes Your Information for any purpose as may be permissible under applicable laws (including where the applicable law provides for such collection, usage, storage or processes in accordance with the consent of the User) and shall include the following:

to facilitate Your use of the Application;
to respond to Your inquiries or fulfil Your requests for information about the various services offered on the Application;
to provide You with information about services available on the Application and to send You information, materials, and offers;
to send You important information regarding the Application, changes in terms and conditions, user agreements, and policies and/or other administrative information;
to send You surveys and marketing communications;
to personalize Your experience on the Application by presenting advertisements, services and offers tailored to Your preferences;
to help You address Your problems incurred on the Application including addressing any technical problems;
if You avail of any service from the Application, to complete and fulfil the same.
to protect the integrity and for proper administering of the Application;
to conduct internal reviews and data analysis for the Application;
to improve the services and content on the Application;
to conduct academic research, surveys, analytical studies on various aspects including user behaviour, user preferences etc.;
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 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 Application or by Us; and
to enable a potential buyer or investor to evaluate the business of SuperFone.

[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 SuperFone or any person on its behalf, and the collection of Information is necessary for the Purposes.

3. SHARING AND DISCLOSURE OF YOUR INFORMATION

You hereby unconditionally agree, consent to and permit Us to transfer, share, disclose or part with all or any of Your Information, within and outside of the Republic of India to third party service providers / partners / banks and financial institutions for one or more of the Purposes or as may be required by applicable law.
You acknowledge and agree that, to the extent permissible under applicable laws, it is adequate that when We transfer Your Information to any other entity within or outside Your country of residence, We will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy.
We may share statistical data and other details (other than Your Personal Information) without Your express or implied consent to facilitate various programmes or initiatives launched by SuperFone, 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, analysing how Our services are used, providing services, 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 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. 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 use, storage, retention of such Personal Information including any 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.
We may also share Personal Information if We believe 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.
We and Our affiliates will share / sell some or all of Your personal information with another business entity should We (or Our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur that other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to Your Personal Information.

4. LINK TO OTHER WEBSITES

Our Application may provide links to other sites. These links are provided for Your convenience only and the provision of these links does not mean that sites are related or associated with Us. Please note that these sites have their own terms of use and privacy policy. You should check their privacy policy before You submit Your Personal Information or any other data with them. We don’t guarantee the content and the security of those sites.
We may have certain features on Our Application which may be hosted by third parties, Your interaction with such features shall be governed by the privacy policy of such third parties.
We shall not be responsible for any loss, damage, claim or expense caused as a result of You accessing these third-party sites and features.

5. SECURITY

We strive to ensure the security, integrity and privacy of Your Information and to protect Your Personal Information against unauthorized access or unauthorized alteration, disclosure or destruction. We make best effort to use adequate measures to prevent unauthorized access to Your Personal Information.
We reserve the right to conduct a security review at any time to verify Your identity. You agree to provide Us all the information that We request for the security review. If You fail to comply with any security request, We reserve the right terminate Your Account with Us and prohibit Your access to the Application.
We are not liable and cannot be held liable for any breach of security or for any actions of any third parties that receive Your Personal Information.
The trademarks, logos and service marks displayed on the Application ("Marks") are the property of SuperFone. You are not permitted to use the Marks without Our prior written consent.
Notwithstanding anything contained in this Policy or elsewhere, We 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 (defined below).

A "Force Majeure Event" shall mean any event that is beyond Our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, epidemics, pandemics, insurrection, war, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.

6. CHILDREN’S PRIVACY

Our Services are not available to children (persons under the age of 18 years). We recognize the need to protect the privacy of young children. We do not knowingly collect Personal Information relating to children and if You think that Your child has provided this kind of information on Our Application, We strongly encourage You to contact Us immediately and We will take reasonable steps to promptly remove or destroy such information.

7. DATA PROTECTION RIGHTS

You have certain choices available to You when it comes to Your Personal Information. Subject to any exemptions provided by the applicable laws, You may have the following rights:
1. Rectifying, correcting, updating and removing Your information:

You can access, edit, modify and/or update Your Personal Information by logging into Your user profile or You can write to Us via email or other means of communication in case You want to exercise Your data protection rights in respect of Personal Information stored or processed by Us to access, rectify, delete, port or restrict processing of such Personal Information. Upon receipt of a request and upon verification, We will remove the Personal Information in accordance with the Clause 9 of this Privacy Policy.

Accessing and updating or deleting Your information:

Our Services and related documentation on Our Application provide You with the ability to access, update and delete certain Personal Information from Your account, if any. We will provide You with information about whether We hold any of your Personal Information upon request. We will respond to such requests within a reasonable timeframe. Please note, however, that We may need to retain certain information for record keeping purposes, to complete Our Services and related obligations to You or to comply with Our legal obligations.

Object or restrict processing of Your information:

You have the right to: (i) object to Our processing of Your Personal Information; and/or (ii) request that We restrict the processing of Your Personal Information. You can log into Your user profile or You can write to Us via email or other means of communication in case You want to exercise any or all of these data protection rights.

If You have made any request in order to exercise any or all of the abovementioned data protection rights, SuperFone, on best effort basis, shall respond to You within 30 (thirty) days.

App name: Superfone
Developer company name: TrueGrit Technologies Pvt Ltd

Steps to request deletion of data:
1. Send an email to hello@superfone.in with subject "Data deletion request"
2. Provide your registered mobile number, your Superfone number, your Aadhar number & your business verification document details that were used to activate the service. Please clearly specify if you want ALL data to be deleted or only some data to be deleted
3. Our team will make a verification call to you and may need to do a 2-step verification to confirm your identity.
4. Once your request is verified, we will delete your data with 7 business days and you will receive a confirmation email after it is done.
5. Data once deleted cannot be recovered, details of data that will be deleted:
- All customer data, notes, tasks, reminders, tags and other data
- All activity data
- other data associated with your account
- your account will no longer be accessible
- Note: Call records, subscription, verification data, customer info to which you called or received calls will be maintained as they may be required to be submitted to relevant authorities as per Indian laws.

8. CHOICE/OPT-OUT

You agree and acknowledge that You are providing Your Information out of Your free will. You have an option not to provide or permit SuperFone 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 as may be notified to You. However, in such cases We may not be able to provide certain Services to You.

9. DATA RETENTION

We will retain Your Information for as long as Your Account is active or as needed to provide Our Services. We shall retain and use the Information collected by Us as necessary to comply with Our legal obligations, resolve disputes or for other Purposes. If You cancel/ deactivate/ unsubscribe Your account with Us, We are not under any obligation to retain Your Information. However, We may retain the Information pertaining to the User for the maximum period permitted under the law of the land from the date of deactivation of User’s Account.

10. SECURITY MEASURES AND SAFEGUARDS

SuperFone uses commercially reasonable technical and administrative security measures and safeguards to protect the confidentiality and security of the User’s Personal Information. However, since the internet is not a 100% secure environment, SuperFone on best effort basis ensures the security of any information the User transmits to Us and that the information may not be accessed, disclosed, altered, or destroyed by breach of any of Our physical, technical, or managerial safeguards. It is the User’s responsibility to protect the security of its login information including passwords. Please note that e-mails and other communications the User sends to Us through Our Application are not encrypted, and We strongly advise the User not to communicate any confidential information through these means.

The Personal Information accessed by SuperFone or any of its trusted and bona fides third party under this Privacy Policy or in relation to the Services shall be subjected to continuous security testing as may be determined by SuperFone. We also hereby acknowledge that We are in compliance with the reasonable security processes and procedures standard as recommended by the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 and such other laws as are applicable to Us.

11. UPDATES TO THIS PRIVACY POLICY

We may change the data privacy practices and update this Privacy Policy as and when the need arises, and the same will be made available on the Application. But Our commitment to protect the privacy of Application Users will continue to remain. We suggest that You regularly check this Privacy Policy to apprise yourself of any updates. Your continued use of Application or provision of data or information thereafter will imply Your unconditional acceptance of such updates to this Privacy Policy.

12. GRIEVANCE OFFICER

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Name: Nikhil Goenka

Address: Meadow in the sun, Owners court west, Kasavanahalli, Bangalore – 560035

Phone: 6361923687

Email: nikhil@superfone.in

Data Protection