Effective from  1 January 2019



1.        Background


1.1  Black Coat Technologies Private Limited, having its office at Plot No. 76 D, Udyog Vihar Phase-4, Gurgaon, Haryana -122001, India ("us", "we", or "our") operate the website India (the "Website") and an application named ‘India Nri’ & ‘India Nri Lawyer’ (the “App”). The Website and App, along with all associated software, design, servers, data, user inputs and associated services shall collectively be known as the “Platform”. The services we provide to you via the Platform shall be known as the “Services”.


1.2    Your privacy is very important to us. We respect your privacy and believe that we should clearly and transparently disclose our privacy practices to you. This privacy policy (the “Privacy Policy”) explains our policies regarding collection, use and disclosure of your personal information, personally identifiable information and other data collected from you when you use our Services. This Privacy Policy does not apply to any third-party websites or applications. Please note that you shall visit any third-party sites and apps at your own risk upon conditions laid down in their privacy policies, if any.


1.3    We may change, modify, amend, terminate or replace this Privacy Policy at any time at our discretion. If we change, modify, amend or terminate this Privacy Policy, such modifications will become effective immediately upon posting to the Website and/or App. We will notify you of material changes in advance by email or by notice when you log on to the Website or the App.


1.4    We will not use or share your information with anyone except as described in this Privacy Policy. We use your information for providing and improving the Services. By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy.


1.5    You agree to periodically review the current version of the Privacy Policy, as posted on the Website or the App. If you do not agree with the terms of this Privacy Policy, please do not use the Services.


1.6    This Privacy Policy is to be read with, and is an integral part of, our Terms of Use available at https://www.India Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use.


2.        Collection of Information


2.1    While using our Services, we may ask you to provide us with certain personally identifiable information (“PII”) that can be used to contact or identify you. PII includes, but is not limited to, your name, phone number, postal address, email address and other information that by itself, or in conjunction with other information, can be used to specifically identify you. However, PII does not include aggregated information that, by itself, does not permit identification.


2.2    Information that we collect when you use our Services includes:


(i)    Information provided by you

When you sign up and register with us through the Website and/or App, we ask you for certain information. This will includes your name, email address, mobile number, telephone number, details of company name & registration, company address, and details of legal mandates you wish to use our Services for.


Further, we ask you for certain information pertaining to each legal mandate that you may wish to list on our Platform. This includes information such as your location, gender, other details required for the service you may like to buy, which is critical for the provision of our Services (“Mandate Information”)


(ii) Log Data

With the help of third parties like Google and Facebook, we collect information that your browser or mobile device sends to them whenever you visit our Services ("Log Data"). This Log Data includes information such as your computer's Internet Protocol ("IP") address, geolocation and geospatial data, browser type and browser version. In case you are accessing the App, we may collect certain mobile device information such as device ID, model number, operating system, global positioning data, application, and other related information. We also collect data on the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, default language and user preferences, and other similar usage related statistics. We may assign each user of the Services unique identifiers to help keep track of future visits.


(iii)  Payment information

Our Services require you to make payments on the Platform. When you are making any payments, we collect billing details from you such as your name, name of company, billing address, contact number, payment method and IP address, and then redirect you to a secure payment service provider platform operated by our payments partner(s) Razorpay, Paytm etc and other payment partners which may be added time to time. We do not store any payment related information such as credit/debit card details and/or bank details.


(iv)   Advertising, Use of Cookies, and Other Tracking Technologies (Cookie Policy)

We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, we may collect certain information via our Sites through our advertising service providers. We or our vendors use several common online tracking tools to collect information about our users, such as browser cookies, web beacons, and other similar technologies. The information we collect includes IP addresses, the number of page visits, pages viewed via our Sites, search engine referrals, browsing activities over time and across other websites following your visit to one of our Sites or applications, and responses to advertisements and promotions on the websites and applications where we advertise. We do not permit third parties to advertise on our Site.

We also use certain information to:

·      Identify new visitors to our Sites;

·      Recognize returning visitors;

·      Advertise on other websites and mobile applications not affiliated with us;

·      Analyze the effectiveness of our advertisements;

·      Better understand our audience, customers, or other Site visitors; and

·      Determine whether you might be interested in new products or services.


(v)  Controlling Our Tracking Tools.

Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Sites. If you block or delete cookies, not all of the tracking that we have described in this policy will stop. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.


(vi)   Controlling Online Interest-Based Ads.

We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on other companies’ websites. These ads may be based on information collected by us or third parties. For example, your geographical location may be used to target an ad for people in your area. These ads may also be based on your activities on our Sites or on third party websites.



(vii)Information received from others

We may combine information about you that we already have with information we obtain from other sources, to provide you a better end user experience or to improve the quality of our Services. Examples of information we may receive from other sources includes details of the Mandate Information available to us, customer support or enrolment information, page view, search term and search result information, and credit or identity information which we may use to detect fraud.


Please note that we use google analytics and similar kind of tools for the purpose of analytics and measurement of the Services. For example, we may use the data gathered from your usage of the Services by facebook, twitter etc. to design new products or services, or to make our existing offerings under the Services more user friendly.


2.3    Apart from the information listed above and the Mandate Information made available to us while providing our Services, we do not collect any other sensitive information such as financial data, political views of any individuals, health-related information or sexual orientation of any individuals, information related to race, caste or language (Collectively, “Sensitive Personal Information”), unless required by the provisions of any applicable law.


3.        Use of Information


We use your PII and other information collected from you for the following purposes:


(i)  To provide you with a customised and optimised experience with our Services;


(ii)                 To provide you with the functionalities of the Website, App and Services in a proper manner;


(iii)               To track your usage of our Services and customise the Services to best suit your requirements;


(iv)                To send you communications, as per your notification settings, on any updates or developments pertaining to the Services or your use of the Services;


(v)                  To improve the security of the Services;


(vi)                To protect our rights and property and the rights and property of our other users;


(vii)             To provide you with information about new products or services launched by us or our partners;


(viii)           To back up our systems to ensure preparedness for disaster recovery;


(ix)                To provide you with customer support services, whether through email, phone, push notifications or messages within the Services;


(x)                  To provide you with technical service and support, including updates;


(xi)                To combine your PII or other information with information obtained from other users on the Platform, and publish summaries of aggregate data online or offline;


(xii)              To provide information to third-parties performing services in support of our delivery of the Services to you;


(xiii)           To communicate promotions and other offers, and for the purposes of advertisements;


(xiv)            To improve the quality, features and functionality of the Services, including measurement of service usage and efficiency of algorithms;


(xv)              For the purposes of auditing, research and analysis to ensure the technical stability of the Platform;


(xvi)            To prevent and detect any fraud or other illegal activity on the Platform, and to prevent violations of our Terms of Use;


(xvii)         To respond to legal requirements, exercise our legal rights and defend against any legal claims, to protect our interests or those of any third parties;


(xviii)       To facilitate payment processes and verify payment information;


(xix)            As may be necessary to enforce the terms of this Privacy policy and our Terms of Service.


4.        Storage of information


4.1    All data storage of your PII or other information collected from you may be stored and processed on computers located at the cloud servers provided by the Amazon Web Service. Through your use of the Services, you unequivocally consent to the processing and storage of your information.


4.2    We store some of your information on your device for subsequent retrieval and utilisation. We take commercially reasonable care to encrypt this information on your device with passwords or other secrets supplied by you. Such information stored on your personal device is subject to the security offered by your device, browser and other components. You understand and agree that we cannot be held responsible for any compromise of access to your personal device, for loss of information, theft or for any exploits or logic attacks on your device through malware or other software or hardware that is outside the control of our Services.


4.3    Although the security of your PII and other information is important to us, do remember that no method of electronic storage, or method of transmission over the internet is 100% secure. While we strive to use commercially acceptable and standard means to protect your information, including internal reviews of our data collection, storage and processing practices and security measures, we cannot guarantee absolute security in this regard. You provide your information and PII to us at your own risk.


5.        disclosure and sharing of information


5.1    We may employ third parties to facilitate the Services, to provide the Services on our behalf, to help us analyse how the Services are used, or to perform Service-related services. We may share your information with third-parties in the following circumstances:


(i)  We have obtained your consent, including when you choose to register a user account, use the Services, and otherwise share your information with us, other users on the Platform and/or other third-parties;


(ii)        If sharing or disclosure of your PII or other information is necessary to provide you with the Services;


(iii)      If we have been purchased by a third-party;


(iv)       If sharing or disclosure of your PII or other information with our associate entities, including any related companies, successors, assigns, licensees, affiliates or business partners becomes necessary. We require that these entities process your PII or other information solely as per our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures;


(v)         If your PII or other information is demanded by a court order or by governmental authorities;


(vi)       If sharing or disclosure of your PII or other information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty;


(vii)    If sharing or disclosure of your PII or other information is needed to protect our employees, independent contractors, officers, members or other users; and


(viii)  If otherwise permitted to do so by this Privacy Policy or by provisions of applicable law.


5.2    The following categories of recipients will most likely receive your information to enable us to provide the Services to you:


(i)  Third Party Data Center Services such as Amazon Web Service;


(ii)        Third Party SMTP Services such as ;


(iii)      Facebook, Instagram, for direct marketing;


(iv)       Third party Service Providers such as Paytm, Razorpay etc.


5.3    All financial information collected on the Platform is used solely to enable payments as consideration for the Services. No financial information collected on the Platform is used for marketing or promotional purposes. Remember that if you provide any PII directly to a third party, such as through a link on the Website or the App, the processing is typically based on their standards (which may not be the same as ours);


5.4    When any PII or other information pertaining to the users is shared with third-parties, such as advertisers, licensees and content distributors, we shall ensure that such information shall be non-private, aggregated or anonymised so that it will not identify you personally. You understand that we may further distribute your information to a wider audience through third-party sites and services, as long such distribution is consistent with this clause and other provisions contained in this Privacy Policy.


5.5    We may use external advertising companies to serve advertisements when you have visited our website. These companies may use anonymised information about your visits to this and other websites in order to provide advertisements about goods and services that may be of interest to you.


5.6    We may share PII with our parents, subsidiaries, divisions, and affiliates or as part of any sale, merger or acquisition;


5.7    We will never sell your PII to unaffiliated third-parties without your approval at the time of collection. You agree to inform us of any changes to your PII, and to protect the security of your username, password and PII.


6.        Legal basis for processing information under GDPR for users in the European Union (“EU”)


6.1         We process information of users in the EU in accordance with European laws and regulations such as the General Data Protection Regulation (“GDPR”). The GDPR governs how we process your information and the rights that EU users have in relation to your information. This entails that we will collect and use your information only where:


(i)  We need such information to provide you the Services and fulfil our obligations to you under our Terms of Use. This includes the functionalities of the Website and/or App;


(ii)        The collection and use of your information is justified because of a legitimate interest such as for research and development or marketing the Services (but only where our legitimate interest isn’t overridden by your interest in protecting your information);


(iii)      We have obtained your consent for using your information in a manner compliant with this Privacy Policy;


(iv)       The collection and use of your information is necessary for compliance with our legal obligations.


6.2    You may withdraw your consent for using your information at any time by writing to info@India  Where we are using your information because of a legitimate interest to do so, you have the right to object to that use. However, if you do so, you may not be able to continue using the functionalities of the Website, and/or the App.


6.3    Please note that the provisions in this Clause 6 of this Privacy Policy are applicable only if you are a user situated in the EU and a data subject under provisions of the EU GDPR.



7.        Rights with resepct to your information


7.1    The laws of some countries grant particular rights in respect of your personal information. If you are a user situated in the European Union, you may have the right to:


(i)  Request a copy of your information and data portability: This right entitles you to know whether we hold any PII about you and, if we do, to obtain a copy of such PII in a structured, commonly used and machine-readable format;


(ii)        Request that your information is deleted: This right entitles you to request the deletion of PII, including in situations where such PII would no longer be necessary to achieve the purposes;


(iii)      Request that we correct inaccuracies relating to your information: This right entitles you to have PII to be corrected if it is inaccurate or incomplete;


(iv)       Object to our use of your information: This right entitles you to request that we no longer process your PII;


(v)         Request that restrictions be placed on processing of PII: This right entitles you to request that we only process PII in certain circumstances, including with consent.


7.2    If you wish to make a request in respect of your personal information, please contact us at info@India


7.3    If, at any time, you prefer not to receive communications from us, simply follow the unsubscribe options at the bottom of each such communication or contact us directly at info@India We will make commercially reasonable efforts to implement your opt-out requests promptly, but you may still receive our emails for up to 7 (seven) working days as we process your request.


7.4    In some circumstances, we may not be able to comply with a request that you make in respect of your personal information. For example, we may not be able to provide a copy of your information where it infringes on the rights of another user. We may also be required to retain certain information that you ask us to delete for various reasons, such as where there is a legal requirement to do so.


7.5    If we are unable to resolve your request, or if you are concerned about a potential violation, you may be entitled to report the issue or make a complaint to the data protection authority in your jurisdiction.


8.        Information Retention 


8.1    Upon receiving a deactivation request, we will deactivate your account and all PII and Sensitive Personal Information collected by us will be destroyed. We retain non-personally identifiable information indefinitely for the purposes of analytics, subject to such information being kept separate from other information that may constitute PII or that may, in combination with such non-personally identifiable information, render the information personally identifiable.


8.2    We collect and retain certain information that is required for our detection, investigation and prevention of fraud, cheating and other violations of our Terms of Use and applicable laws ("Breach(es)"). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on such Breaches and stored only for the minimum amount of time needed for the purpose of dealing with such Breaches. If the data indicates that such a Breach has occurred, we will further store the data for the establishment, exercise or defence of legal claims, until a legal case related to it has been resolved, or such legal claim no longer exists due to the expiry of relevant limitation periods. Please note that the specific data stored for dealing with Breaches may not be disclosed to you if such disclosure will compromise our legal rights as well as the mechanism through which we detect, investigate and prevent such Breaches.


9.        Changes to this Privacy Policy


We may update our Privacy Policy from time to time. You agree to periodically review the current version of the Privacy Policy, as posted on the Website or App. We will notify you of material changes in advance by email or by notice on this page when you log on to the Website or the App. Changes to this Privacy Policy are effective when they are posted on this page. If you do not agree to the change, you may discontinue the use of Services.


10.    Contact us


If you have any questions about this Privacy Policy, please contact us at info@India