1. Privacy Statement
You agree to peruse this Policy and hereby consent to collection and utilization of personal information procured by us. Usage of the Services on our Sites and the consent provided herein shall be deemed to be explicit consent to the collection and use of information.
2. Information We Collect
Personal information is defined in this Policy to include any information that can be used to identify, locate, or contact you. It includes and is not limited to your Name, Physical Address, Email address, Telephone/ Mobile number, and other identifying information. It also includes other information that may be associated with your Personal Information, such as your Location, IP Address, Preferences, or Interests. We may collect your personal information when you use our Sites to contact us, subscribe to our Publications or register for firm events, collectively referred to as “Services.”
From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. The legal basis for processing such data is compliance with legal obligations.
We may also gather generic, or non-personal, information from our Sites’ visitors automatically, which does not reveal a Site visitor’s identity. This includes the number and frequency of visitors to our Sites, the specific CrossTower Sites visited, and the Sites clicked on, your language preferences for accessing our Sites, your browser information and screen resolution, your device’s operating system, and your network service provider, among other information. We gather this information for limited internal purposes, such as to track, customize and improve user experience with our Sites or Services.
3. How We Use Your Information
We will primarily use your information to provide you access to, and facilitate your use of the Sites, contact with us, subscription to our publications and registration for firm events, where you access the Sites for those purposes. Except as otherwise stated in this Policy, we will only use your personal information solely for the purpose for which you submitted the information.
4. Purposes for Which We Seek Your Consent
We may also ask for your consent to process your personal information for a specific purpose that we communicate to you, for instance, to receive our newsletter and other such mailings you may be interested in. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop processing your personal information for that purpose.
5. How We Disclose or Share Your Information
We may disclose your personal information to member(s) of our group of companies (this includes our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this Policy.
We do not use or disclose personal information you provide on our Sites to any outside companies or parties except for third-party service providers who perform functions on our behalf relating to our provision of Services to you that you request through use of the Sites. We do not rent, sell, or trade any of our mailing lists. We provide you with the right to opt-out of receiving marketing and other discretionary communications, and to update, supplement or delete your personal information.
We may also be required to disclose your information in response to a lawful and enforceable request by law enforcement, judicial body, or other public authorities, or in connection with a legal obligation. In such instances, we will disclose your personal information upon receipt of a court order, or other lawful and enforceable process, or where otherwise required by law.
We reserve the right to report to law enforcement any information – including personal information – related to the use of our Sites that we determine was used to further any unlawful activity or activity we in good faith believe to be unlawful.
6. How We Protect Your Information
We employ reasonable and appropriate security measures to protect your personal information from loss, misuse, unauthorized access, alteration, disclosure, and destruction. While we strive to make your information as secure as possible, no transmission system or data network is completely secure. Therefore, by use of the Sites, you acknowledge that there are data security and privacy limitations inherent on the Internet, and that the security, integrity, and privacy of any and all information exchanged between you and us, cannot be guaranteed.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Steps taken to ensure data security:
All the user information can only be accessed by authorized users.
Users need to authenticate themselves with a username-password combination
7. How Long We Keep Your Information
We keep your personal information to enable your continued use of the Services, for as long as it is required to fulfil the relevant purposes described in this Policy, or as may be required by applicable law.
8. International Transfers of Your Information
To facilitate our operations we may transfer, store, and process your information with service providers based in India, and Bermuda. -
In cases where we need to transfer personal information outside India, we shall ensure that adequate safeguards, as required under applicable data protection legislation of the transferee country, will be implemented.
9. Your Privacy Rights
We will ensure that you can exercise your rights pertaining to your personal information, including rights as provided by applicable data protection laws. Where applicable and required under relevant law, we will reasonably endeavour to provide the following rights:
To have access to your personal information upon simple request – that is, you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account.
To have access upon simple request, and free of charge, the categories and
names of addresses of third parties that have received personal information for direct marketing purposes.
To obtain a rectification of your personal information should it be
inaccurate, incomplete, or obsolete.
To obtain the deletion of your personal information in the situations set
forth by applicable data protection law (the “right to be forgotten”).
To withdraw your consent to the data processing without affecting the
lawfulness of processing, where your personal information has been collected and processed based on your consent.
To object to the processing of your personal information (where it has been
collected and processed based on our legitimate interests) in which case we may ask you to justify your request by explaining to us your situation.
To request a limitation of the data processing in the situations set forth by
To have your personal information directly transferred by us to a third-party
processor of your choice (where technically feasible and when processing is based on your consent).
To non-discrimination, as defined under relevant law, in the Services or
quality of Services you receive from us for exercising your rights.
For deletion/ “right to be forgotten” requests, we will undertake a good faith effort to accommodate requests for deletion of personal information. However, these requests may be subject to the evaluation of additional factors, including disproportionate burden or expense, or the risk to the rights, including the privacy rights, of others.
Our Sites and Services are intended for adults and are not intended for or directed to anyone under 18 years of age. We therefore do not knowingly collect personal information from anyone under 18 years of age. If you are under 18 years of age, do not attempt to use the Site to access Services, and do not provide us any personal information about yourself.
12. Links to Other Sites
13. Grievance Officer
In accordance with the Information Technology Act, 2000 and the rules made thereunder, the name and contact details of the Grievance Officer are provided below. You may contact the Grievance Officer to address any discrepancies and grievances you may have with respect to your personal information with us. The Grievance Officer will redress your grievances expeditiously.
Name: Saurabh Singh
Email ID: email@example.com
14. Compliance Officer
You may contact the Compliance Officer to address any discrepancies you may have with respect to compliance.
Name: Rakesh Chanda
Email ID: Rakesh.firstname.lastname@example.org
15. How to Contact Us
If you have any questions regarding this Policy or our privacy practices, please contact:
CrossTower India Trading Pvt. Ltd.