When you create an account or register with us, we collect information that can be used to identify you ("Personal Information"). Personal Information may include your email address, name, username, address, and phone number, PAN Card number, and any other personally identifiable information that you may choose to provide us or that you choose to include in your account on the Platform. We may also collect Personal Information that you provide when you place Bids, make an offer or an Acceptance, or otherwise communicate with us or other Users on or through the Platform.
THE PLATFORM WILL NOT BE AVAILABLE TO INDIVIDUALS OR ENTITIES NOT REGISTERED WITH KTPL. IF YOU ARE NOT REGISTERED, YOU WILL NOT BE ABLE TO USE THE PLATFORM.
Your Content and Communications:
Our Services permit you to interact with us through the notification system. We collect and store all of the comments, communications, and chats you post, transmit or generate on the Platform and/or through the Services. When you ask for assistance from KTPL for customer support, the contact information you provide will be collected, as well as the information which you post while using the Platform and/or the Services, such as, your user ID number, etc., and any correspondence or information contained within.
- Cookies: KTPL
information (a) to store and access information; (b) to enable KTPL to provide you with more customized services, and (c) to collect other information about your use of our Services.
- KTPL’S USE AND DISCLOSURE OF INFORMATION
Use of information
You agree that KTPL and/or service providers on KTPL’s behalf may use the information they collect, including your Personal Information for:
You may unsubscribe from some of these messages by sending an email to us at the email address set out in Clause 11 below.
- contacting you for customer support;
- sending you updates or information about the Platform and/or Services;
- managing your account and relationship with the Platform and/or Services, and improving your experience when you use it;
- improving the Services, research, surveying, and engaging with you, for example by sending you communications for these purposes;
- marketing and promotion of the Platform and/or Services and/or other products;
- personalizing and optimizing the Platform and/or Services;
- sharing promotional content and/or advertising; and
- creating reports, analysis, or similar services for research or business intelligence.
By using the Platform and/or the Services you make certain that your Personal Information will be available to other Users. For example, when a trade is closed on the Platform, KTPL provides the contact information of the execution profile or, in case such profile is not available, the commercial profile, to other Users. When you list an auction with your details on the Platform, such listing, post, and/or activity are shared with other Users who may then share this information with others through the Platform and/or Services or outside the Platform and/or Services. You acknowledge that you have no expectation of privacy about the auctions, Bids, Offers, Acceptance, Contract Confirmation, which are posted on the Platform.
NOTWITHSTANDING THE ABOVE, LISTINGS/POSTINGS MADE ON THE PLATFORM WILL ONLY BE SHARED WITH OTHER USERS.
- Other transfers
ANY DISCLOSURE IS ALWAYS ON A CONFIDENTIAL BASIS.
- SECURITY OF YOUR PERSONAL INFORMATION
KTPL takes all reasonable and sound steps to ensure that the information is protected against misuse, loss, unauthorized access, modification, and/or disclosure. KTPL adopts and applies appropriate data collection, storage, management practices, and security procedures to protect against unauthorized access, alteration, addition, deletion, disclosure, and/or destruction of a User’s personal information, including their username, email address, password, transaction information, and any other data stored on the Platform. However, no data storage or transmission over the Internet or other network can be guaranteed to be 100% secure. Accordingly, KTPL does not guarantee that information will not be accessed, disclosed, altered, or destroyed by any breach of any of the abovementioned safeguards. To the extent applicable, KTPL complies with all applicable data protection laws, and you (the User) are duly bound to provide all reasonable assistance and information to KTPL about compliance with such laws.
- ACCESS TO PERSONAL INFORMATION
You have the right to access the Personal Information we collect and hold about you. If at any time you would like to access or change your Personal Information, or you would like more information on our approach to protecting your privacy, please contact us at the contact details set out in Clause 11 below. You can opt-out of receiving certain promotional or marketing material by selecting the unsubscribe option contained within the emails providing such material or contacting us at the contact details set out in Clause 11 below. However, you cannot opt out of receiving all e-mails from us about your use of the Platform, such as e-mails about the status of your account.
- DATA PROTECTION PRACTICES
Our data is hosted in AWS infrastructure and the data is encrypted at rest and in transit using AES-256 Encryption Standards. We utilize network firewalls built into Amazon VPC frameworks to ensure further security. We use AWS Cloudwatch and AWS GuardDuty for monitoring the systems, access logs, and activity on our infrastructure.
- ADOPTION OF STANDARD PRACTICES
We have implemented standard security best practices and have a comprehensively documented information security program in compliance with Rule 8 of the Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011. However, this is to further record and clarify, the Company is not required to comply with any specific ISO standard as per the Applicable Laws.
- DATA RETENTION POLICY
We are committed to protecting and respecting your privacy and will comply with all applicable data protection laws in all our dealings with your personal data. We review and update our data retention policies regularly to protect data securely and ensure that it is not deleted prematurely, either inadvertently or maliciously.
- User Data Retention
- Personal Data of the Users, such as but not limited to the below
- Full Name;
- Email address;
- Phone number;
- Physical Address;
- Id Photo;
- Id Proof details;
- Family Details;
- Date / Place of Birth;
- Bank Account details;
- Transaction Information;
- Geo- Location Information: Use and store information about your location- to provide features of our Service, to improve and customise our offerings;
- Usage Information is captured - Your interactions with the platform;
- Non-Identifying Information - Whenever you visit our website, we may collect non-identifying information, such as referring URL, browser, operating system, and Internet Service Provider;
- We retain residual information in our backup and/or database. Such information would be deleted subject to contractual agreements, provided that region/country’s law permits the same.
- Corporate Data Retention
- Including but not limited to, business records, files, finances, taxes, legal and vendor partners, corporate announcements, shareholding patterns, both paper or electronic records;
- Excluding Customer (User) data and Employee Data;
- Protect data from destruction for a length of time till the servers are operated by the Company;
- Obtain approval of legal department to permanently delete the data after period mentioned above is over.
- Employee Data Retention
- Including but not limited to, memoranda, contracts, emails, expense records and performance reports;
- Email, Slack, Notion, HR data to be retained for period in accordance with Applicable Laws;
- The policy to be reviewed periodically by the senior management. Accordingly suggest changes while facing practical difficulties or comply with legislations;
- Certain records to be kept for Perpetuity, unless mentioned otherwise:
- Board of Directors Records of minutes of meetings;
- Press Releases and Public Filings documents;
- Book of Accounts and Tax Records;
- Employment Records including recruitment, employment and personal information. Retained for 3 years from cessation of employment;
- Intellectual Property Records;
- Execution copies of all contracts should be retained for at least 3 years following the expiry or termination of the contracts.
KTPL may retain the information (including Personal Information) for as long as is necessary to fulfill the purposes for which it was collected or as needed to provide, even after you have discontinued or deleted any account or have ended the provision of the Services, if retention of such information is reasonably necessary to comply with KTPL’s legal obligations, regulatory requirements and for resolving disputes between Users or for preventing fraud, for backup, archival, and/or audit purposes or any other use.
- GENERAL TERMS
COMPLAINT & GRIEVANCE MECHANISM
To Address the queries/concerns of the users we have defined Complaint & Grievance Mechanism.
Level 1: Users can reach us through the “Help via Call” feature on the mobile application or can write to us at firstname.lastname@example.org.
Level 2: If the user query/concerns are not addressed to the expected levels, then they can reach the Grievance Officer- Mr. Jitender Bedwal. Email id: email@example.com ; Grievance officer acknowledges the receipt of any user query/concerns within 48 hours and redresses the complaint within 1 month from the date of receipt of the complaint.
- Level 3: In the unlikely event that your issue remains unresolved to your satisfaction despite escalating to our Grievance Officer, you can reach out to our Nodal Officer Mr. Mahesh Jakhotia – firstname.lastname@example.org . We will respond within 3 business days from the date of receipt of your email.