Privacy Notice

1. What is 2 Shabd?

2 Shabd is the platform to let you know someone as their friends and family do. Our Website (located at https://2shabd.com) or “Platform” provides information about us and allows individuals to sign-up as 2 Shabd Users.

The profile that 2 Shabd Users are able to create is referred to in this Privacy Notice as "User profile". User profile is by default not accessible to the public.

We are headquartered in Pune, India. For more information about 2 Shabd journey, please see the “About” section of our Website.

2. How does this Privacy Notice apply to me?

This Privacy Notice only applies to personal information we collect as a controller from:

• individuals, or representatives of individuals that sign up to use our 2 Shabd services - our “2 Shabd Users";
• individuals that visit and interact with User profiles (“profile Visitors”);
• individuals who respond to our surveys, marketing materials or participate in trade promotions or competitions that we may run from time to time.

This Privacy Notice, applies to the processing of personal information by 2 Shabd as a controller. When we talk about 2 Shabd acting as a “controller”, we mean that 2 Shabd determines the purpose and the means of the processing (i.e. we make decisions about how we will handle your personal information).

If you provide us with information about another person (if, for example, you are a representative of an individual), you must provide them with a copy of this Privacy Notice and let that other person know that we use their personal information in the ways set out in this Privacy Notice.

3. What personal information do we collect?

The personal information that we may collect about you broadly falls into the following categories:

• Information you provide voluntarily: When you sign up to become a 2 Shabd User, use or interact with our 2 Shabd services or staff, visit our Platform, visit a User profile, respond to a survey or participate in a trade promotion we may ask you to provide personal information voluntarily. For example, we can ask you to provide your email address, name, username, and marketing preferences. You may also provide personal information voluntarily if you respond to our surveys, marketing materials, or through your participation in trade promotions and competitions we may run from time to time.
• Information that we collect automatically: When you visit our Platform, use our 2 Shabd services, interact with a User profile, respond to a survey or participate in a trade promotion we collect certain information automatically from your device. As of this moment, we only collect the information about which profiles you visited. This information is required so that the user whose profile you visited can see you listed under their "Visitors" section.
  
  Further, we may undertake automatic scanning of User profiles and stories to determine if any content should be removed or any User profiles should be suspended in line with our Community Standards and/or Terms of Service.
• Children's data: Our services are not intended for use by children under the age of 18 (the “Age Limit”). If you are under the Age Limit, please do not use the 2 Shabd services and do not provide us with your personal information. If you are a parent or guardian and you are aware that an individual (of whom you are a parent or guardian) under the Age Limit has provided us with personal information, please contact us. We will, upon notice or discovery, take all reasonable efforts to erase or destroy any personal information that may have been collected or stored by us about that individual.
• Recruitment: In future, when we begin with our hiring, if you apply for a role at 2 Shabd, then the personal information will only be collected, used and accessed for recruitment purposes only. The data will be retained for a maximum of two years and will then be anonymized for statistical purposes.

4. Why do we collect your personal information?

In general, we will use the information we collect for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. These include:

• To provide and deliver the 2 Shabd services and to assess, maintain and improve the performance and functionality of the 2 Shabd services.
• To provide customer support and to process and respond to a request, complaint or Intellectual Property Report or Counter Notice that you may have made.
• To monitor the usage of the 2 Shabd services and to detect, prevent and address technical issues.
• To verify your identity and to detect fraud and potential fraud, including fraudulent use of the 2 Shabd services.

5. Legal basis for processing personal information

We will only use your personal information when you have given us clear permission to process your data for a specific purpose.

6. Who may we disclose your personal information to?

We DO NOT disclose your personal information to anyone.

7. Disclosure of personal information to other countries

We DO NOT disclose your personal information to any country other than the one where our servers are located.

8. How do we use cookies and similar tracking technology?

We DO NOT use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you.

9. How long do we retain your personal information?

We retain your personal information until you delete your account.

10. How do we secure your personal information?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

In addition, we limit access to your personal information to our employees. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Therefore, we have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. What are your rights in relation to personal information?

You have the following data protection rights - If you wish to access, correct or update your personal information, you can do so at any time by updating your account section.

Depending on the country which you live in and the laws that apply to you, you may also have additional data protection rights. If you are resident in the UK or the European Economic Area, these rights include:

• To delete your personal information. You can do so at any time by choosing the delete option on any of your published stories or delete your account.
• To object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by connecting with us on support@2shabd.com.
• To opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time by connecting with us on support@2shabd.com. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12. Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with us using the contact details provided under the Contact Us heading below. We will confirm receipt of your complaint and, if we believe necessary, we will open an investigation.

We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, then we will contact you with the result as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may contact the local privacy and data protection authorities in your jurisdiction.

13. Changes to This Privacy Notice

We may update our Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy notice, it is your responsibility to check this page now and then for any changes.

Your continued use of the Platform after any changes to the Privacy Notice is taken as your acceptance of the revised policies. If you do not agree with the changes, we ask you to please stop using 2 Shabd and delete your account.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

14. Contact

If you have any questions about this Privacy Notice, our privacy practices or if you would like to make a request about any personal information we may hold about you, including correction of personal information, please contact us:

• By email using: support@2shabd.com
• By visiting this page on our Platform: 2shabd.com/contact.php
• By post at Jaglen Platforms Pvt Ltd, 204, Sapphire Chambers, First Floor, Suite #1075, Baner Gaon, Pune, Haveli, Maharashtra, India, 411045.

2 Shabd

Jaglen Platforms Pvt Ltd