This Privacy Policy (“Policy”) describes the policies and
procedures on the collection, use, disclosure and protection of
your information when you use our website located at
www.whistle.in.net, or the Whistle mobile application
(collectively, “Whistle Platform”) made available by Novanta
Minutes Private Limited (“Whistle”, “Company”, “we”, “us” and
“our”), a private company established under the laws of India
h a v i n g i t s r e g i s t e r e d o f f i c e a t 2 / 4 6 A S r e e j e s h
Road ,Kizhakambalam Kochi, 683562. The terms “you” and
“your” refer to the user of the Platform. The term “Services”
refers to any services offered by Whistle whether on the Platform
or otherwise.
Please read this Policy before using the Whistle Platform or
submitting any personal information to it. This Policy is a part of
and incorporated within, and is to be read along with, the Terms
of Use.
SCOPE OF PRIVACY POLICY
By using the Platform and the Services, you agree and consent to
the collection, transfer, use, storage, disclosure and sharing of
your information as described and collected by us in accordance
with this Policy. !If you do not agree with the Policy, please do not
use or access the Platform.
POLICY CHANGES
We may occasionally update this Policy and such changes will be
posted on this page. If we make any significant changes to this
Policy we will endeavour to provide you with reasonable notice of
such changes, such as via prominent notice on the Platform or to
your email address on record and where required by applicable
law, we will obtain your consent. To the extent permitted under
the applicable law, your continued use of our Services after we
publish or send a notice about our changes to this Policy shall
constitute your consent to the updated Policy.
LINKS TO OTHER WEBSITES
The Platform may contain links to other websites. Any personal
information about you collected whilst visiting such websites is
not governed by this Policy. Whistle shall not be responsible for
and has no control over the practices and content of any website
accessed using the links contained on the Platform. This Policy
shall not apply to any information you may disclose to any of our
service providers/service personnel which we do not require you
to disclose to us or any of our service providers under this Policy.
INFORMATION WE COLLECT FROM YOU
Device Information: In order to improve your app experience and
lend stability to our services to you, we may collect information
or employ third party plug-ins that collect information about the
devices you use to access our Services, including the hardware
models, operating systems and versions, software, file names and
versions, preferred languages, unique device identifiers,
advertising identifiers, serial numbers, device motion
information, mobile network information, installed applications
on device and phone state. The information collected thus will be
disclosed to or collected directly by these plug-ins and may be
used to improve the content and/or functionality of the services
offered to you.
USE OF COOKIES
Our Platform and third parties with whom we partner, may use
cookies, pixel tags, web beacons, mobile device IDs, “flash
cookies” and similar files or technologies to collect and store
information with respect to your use of the Services and third-
party websites.
Cookies are small files that are stored on your browser or
device!by websites, apps, online media and advertisements. We
use cookies and similar technologies for purposes such as:
•Authenticating users;
•Remembering user preferences and settings;
•Determining the popularity of content;
•Delivering and measuring the effectiveness of advertising
campaigns;
•Analyzing site traffic and trends, and generally understanding
the online behaviours and interests of people who interact with
our services.
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. We use
pixel tags to measure the popularity of our various pages,
features and services. We also may include web beacons in e-mail
messages or newsletters to determine whether the message has
been opened and for other analytics.
To modify your cookie settings, please visit your browser’s
settings. By using our Services with your browser settings to
accept cookies, you are consenting to our use of cookies in the
manner described in this section.
We may also allow third parties to provide audience
measurement and analytics services for us, to serve
advertisements on our behalf across the Internet, and to track
and report on the performance of those advertisements. These
entities may use cookies, web beacons, SDKs and other
technologies to identify your device when you visit the Platform
and use our Services, as well as when you visit other online sites
and services.
USES OF YOUR INFORMATION
•We use the information we collect for following purposes,
including:
i. To provide, personalise, maintain and improve our products
and services,
ii. To carry out our obligations arising from any contracts
entered into between you and us and to provide you with the
relevant information and services;
iii. To administer and enhance the security of our Platform and
for internal operations, including troubleshooting, data
analysis, testing, research, statistical and survey purposes;
iv. To provide you with information about services we consider
similar to those that you are already using, or have enquired
about, or may interest you. If you are a registered user, we
will contact you by electronic means (e-mail or SMS or
telephone or other internet based instant messaging systems)
with information about these services;
v. To understand our users (what they do on our Services, what
features they like, how they use them, etc.), improve the
content and features of our Services (such as by
personalising content to your interests), process and
complete your transactions, make special offers, provide
customer support, process and respond to your queries;
vi. To generate and review reports and data about, and to
conduct research on, our user base and Service usage
patterns;
vii. To allow you to participate in interactive features of our
Services, if any; or
viii.To measure or understand the effectiveness of advertising we
serve to you and others, and to deliver relevant advertising to
you.
ix. To carry out academic research with academic partners. We
may combine the information that we receive from third
parties with the information you give to us and information
we collect about you for the purposes set out above. !Further,
we may anonymise and/or de-identify information collected
from you through the Services or via other means, including
via the use of third-party web analytic tools. As a result, our
use and disclosure of aggregated and/or de-identified
information is not restricted by this Policy, and it may be
used and disclosed to others without limitation.
x. We analyse the log files of our Platform that may contain
Internet Protocol (IP) addresses, browser type and language,
Internet service provider (ISP), referring, app crashes, page
viewed and exit websites and applications, operating system,
date/time stamp, and click stream!data. This helps us to
administer the website, to learn about user behaviour on the
site, to improve our product and services, and to gather
demographic information about our user base as a whole.
DISCLOSURE AND DISTRIBUTION OF YOUR INFORMATION
We may share your information that we collect for following
purposes:
▪With Service Providers:!We may share your information with
our vendors, consultants, marketing partners, research firms
and other service providers or business partners, such as
Program Partners, Payment processing companies, to support
our business. For example, your information may be shared
with outside vendors to send you emails and messages or
push notifications to your devices in relation to our Services,
to help us analyze and improve the use of our Services, to
process and collect payments. We also may use vendors for
other projects, such as conducting surveys for us.
▪With Academic Partners:!We may share your information
with our academic partners for the purpose of carrying out
academic research.
▪For Crime Prevention or Investigation:!We may share this
information with governmental agencies or other companies
assisting us, when we are:
▪Obligated under the applicable laws or in good faith to respond
to court orders and processes; or
▪Detecting and preventing against actual or potential
occurrence of identity theft, fraud, abuse of Services and other
illegal acts;
▪Responding to claims that an advertisement, posting or other
content violates the intellectual property rights of a third
party;
▪Under a duty to disclose or share your personal data in order
to enforce our Terms of Use and other agreements, policies or
to protect the rights, property, or safety of the Company, our
customers, or others, or in the event of a claim or dispute
relating to your use of our Services.!This includes exchanging
information with other companies and organisations for the
purposes of fraud detection and credit risk reduction.
▪For Internal Use:!We may share your information with any
present or future member of our “Group” (as defined below)or
affiliates for our internal business purposes The term “Group”
means, with respect to any person, any entity that is
controlled by such person, or any entity that controls such
person, or any entity that is under common control with such
person, whether directly or indirectly, or, in the case of a
natural person, any Relative (as such term is defined in the
Companies Act, 1956 and Companies Act, 2013 to the extent
applicable) of such person.
▪With Advertisers and advertising networks:!We may work
with third parties such as network advertisers to serve
advertisements on the Platform and on third-party websites or
other media (e.g., social networking platforms). These third
parties may use cookies, JavaScript, web beacons (including
clear GIFs), Flash LSOs and other tracking technologies to
measure the effectiveness of their ads and to personalise
advertising content to you.!
While you cannot opt out of advertising on the Platform, you may
opt out of much interest-based advertising on third party sites
and through third party ad networks (including DoubleClick Ad
Exchange, Facebook Audience Network and Google AdSense). For
more information, visit www.aboutads.info/choices. Opting out
means that you will no longer receive personalised ads by third
parties ad networks from which you have opted out, which is
based on your browsing information across multiple sites and
online services. If you delete cookies or change devices, your opt
out may no longer be effective.
▪To fulfil the purpose for which you provide it.
▪We may share your information other than as described in this
Policy if we notify you and you consent to the sharing.
!
DATA SECURITY PRECAUTIONS
We have in place appropriate technical and security measures to
secure the information collected by us.
We use vault and tokenisation services from third party service
providers to protect the sensitive personal information provided
by you. The third-party service providers with respect to our
vault and tokenisation services and our payment gateway and
payment processing are compliant with the payment card
industry standard (generally referred to as PCI compliant service
providers). You are advised not to send your full credit/debit card
details through unencrypted electronic platforms. Where we have
given you (or where you have chosen) a username and password
which enables you to access certain parts of the Platform, you
are responsible for keeping these details confidential. We ask you
not to share your password with anyone. Please be aware that
the transmission of information via the internet is not completely
secure. Although we will do our best to protect your personal
data, we cannot guarantee the security of your data transmitted
through the Platform.
OPT-OUT
When you sign up for an account, you are opting in to receive
emails from the Platform.You can follow the “unsubscribe”
instructions in commercial email messages, but note that you
cannot opt out of receiving certain administrative notices, service
notices, or legal notices from Whistle.
If you wish to withdraw your consent for the use and disclosure
of your personal information in the manner provided in this
Policy or you want your data to be deleted, please write to us at
support@whistle.in.net. Please note that we may take time to
process such requests, and your request shall take effect no later
than 5 (Five) business days from the receipt of such request, after
which we will not use your personal data for any processing
unless required by us to comply with our legal obligations. We
may not be able to offer you any or all Services upon such
withdrawal of your consent.
GRIEVANCE OFFICER AND THE PLATFORM SECURITY
If you have any queries relating to the processing or usage of
information provided by you in connection with this Policy,
please email us at!support@whistle.in.net!or write to our
Grievance Officer at the following address:
The Grevience Officer
2/46A , Sreejesh Road, Kizhakambalam
Kochi,683562
If you come across any abuse or violation of the Policy, please
report to support@whistle.in.net
Further, please note that the Whistle Platform stores your data
with the cloud platform of Amazon Web Services provided by
Amazon Web Services, Inc., which may store this data on their
servers located outside of India. Amazon Web Services has
security measures in place to protect the loss, misuse and
alteration of the information, details of which are available at
https://aws.amazon.com/. The privacy policies adopted by
Amazon Web Services are detailed in https:aws.amazon.com/
privacy. In the event you have questions or concerns about the
security measures adopted by Amazon Web Services, you can
contact their data protection / privacy team / legal team or
designated the grievance officer at these organizations, whose
contact details are available in its privacy policy, or can also write
to our Grievance Officer at the address provided above.
