Protecting the individual’s privacy on the Internet is crucial to the future of an internet-based business and the move toward a true internet economy. Algonomy Software Private Limited (formerly known as Manthan Software Solutions Pvt. Ltd.) (“Algonomy”, “we”, “us” or “our”, each of which reference shall be construed to also include our affiliates, subsidiaries, group companies and permitted assigns) have formulated this statement (“Privacy Statement”) to demonstrate our firm commitment to the individual`s right to data protection and privacy. All references to “you”, “your” or “user”, as applicable, mean the person who accesses, uses and/or participates in the Website in any manner.

This Privacy Statement outlines how we handle information that we collect through https://algonomy.com/ (“Website”) that can be used, directly or indirectly, to identify an individual (“Personal Data“). This Privacy Statement also provides information regarding how you can access and update your Personal Data and make certain choices about how your Personal Data is used by us. This Privacy Statement will come into effect from 1 Feb 2021.

B. DATA SUBJECT’S RIGHTS.

1. Right to request for correction or deletion of Personal Data. You can request from Algonomy at any time information about which Personal Data Algonomy processes about you and the correction or deletion of such Personal Data. Please note, however, that Algonomy can delete your Personal Data only if there is no statutory obligation or prevailing right of Algonomy to retain it.
   Kindly note that if you request that Algonomy delete your Personal Data, you will not be able to continue to use the Website or any Algonomy service, if such usage requires Algonomy’s use of your Personal Data.
2. Right to request for a copy of the Personal Data. If Algonomy uses your Personal Data based on your consent or to perform a contract with you, you may further request from Algonomy a copy of the Personal Data that you have provided to Algonomy. You may also ask for a copy of the information setting out purposes, categories of personal data processed, recipients to whom your Personal Data is disclosed, and the period for which your Personal Data is stored. In this case, please contact us at the email address below and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the Personal Data is to be sent to you or another recipient. Algonomy will carefully consider your request and discuss with you how it can best fulfill it.
3. Right to request for Algonomy to stop processing. You can request from Algonomy that Algonomy restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data Algonomy has about you is incorrect, (but only for as long as Algonomy requires to check the accuracy of the relevant Personal Data), (ii) there is no legal basis for Algonomy processing your Personal Data and you demand that Algonomy restricts your Personal Data from further processing, (iii) Algonomy no longer requires your Personal Data but you claim that you require Algonomy to retain such Personal Data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Data by Algonomy (based on Algonomy’s legitimate interest as further set out in B. below) for as long as it is required to review as to whether Algonomy has a prevailing interest or legal obligation in processing your Personal Data.
   Please direct any such request to privacy@algonomy.com.
4. Right to lodge a complaint. If you believe that Algonomy is not processing your Personal Data in accordance with the requirements set out herein or applicable EEA and / or Indian data protection laws, you can contact our grievance officer in accordance with paragraph 3 of Section E below. Furthermore, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which Algonomy has its registered seat.
5. Right to have the Personal Data transferred If at any time you wish to have your Personal Data transferred to another data controller, you may contact us at privacy@algonomy.com to request for such transfer.
6. Use of this Website by children. This Website is not intended for anyone under the age of majority in the jurisdiction from where the Website is being accessed. You may only access or use this Website if you are 18 (eighteen) years of age or at the age of majority in the jurisdiction from where the Website is being accessed by you, whichever is higher. If at any time, Algonomy is  intimated that it has collected the data of persons below the age of majority in the jurisdiction from where the Website is being accessed years or has provided any services to such person, we will at once delete the data from our records, and stop the provision of services. If you are a parent or guardian and believe we may have collected information about a child, please contact at privacy@algonomy.com.
7. Links to other websites. This Website may contain links to foreign (meaning non-Algonomy group companies) websites. Clicking on links to third party websites may allow such third party to collect Personal Data about you. Algonomy is not responsible for the privacy practices or the content of websites outside the Algonomy group companies. Therefore, we recommend that you carefully read the privacy statements of such foreign sites before accessing the same.

C. WHERE ALGONOMY USES YOUR PERSONAL DATA BASED ON APPLICABLE LAW

In the following cases, Algonomy is permitted to process your Personal Data under the applicable data protection law.

1. Providing the requested goods or services. If you request digital content, Algonomy will use the Personal Data that you enter into the order or registration form (usually (a subset of) your name, (email) address and telephone number, company name and address, your job title and role) for providing the requested digital content, products and/or services. This may also include conversation data that you may trigger via the chat functionalities on algonomy.com (https://algonomy.com/) or other local Algonomy web presences, contact forms, emails, or telephone. In this Privacy Statement, “products and/or services” includes (access to) Algonomy’s web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.
   If you participate in tutorials or trainings provided by Algonomy, Algonomy may also track your learning progress in order to make this information available to you.
2. Usage of Personal Data. Furthermore, we communicate on a regular basis by email with users who subscribe to our services for the purposes as provided below. We may use your email address to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about Algonomy’s software and services (including marketing-related newsletters) as well as events of Algonomy and in order to display relevant content on the Website. With regard to marketing-related types of communication (i.e., emails and phone calls), Algonomy will (i) where legally required only provide you with such information after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing- related types of communication from us. You can opt out of these at any time at https://algonomy.com/contact.
3. Ensuring complaince. Algonomy and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, Algonomy is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through Algonomy’s Website or other delivery channels controlled by Algonomy. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to Algonomy’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match. Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Data or receipt of marketing materials (that is to say, depending on the country in which the relevant Algonomy group company operates, whether you have expressly consented to or opted out of receiving marketing materials) may be stored and exchanged between members of the Algonomy group as required to ensure compliance.
4. Algonomy’s legitimate interest. Each of the use cases below constitutes a legitimate interest of Algonomy to process or use your Personal Data. If you do not agree with this approach, you may object against Algonomy’s processing or use of your Personal Data as set out below.
   • Questionnaires and surveys. Algonomy may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, Algonomy may use such Personal Data to improve its products and services.
   • Creation of anonymized data sets. Algonomy may anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates’ products and services.
   • Recording of calls and chats for quality improvement purposes. In case of telephone calls or chat sessions, Algonomy may record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of Algonomy’s services.
   • In order to keep you up-to-date/request feedback. Within an existing business relationship between you and Algonomy, Algonomy may inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from Algonomy. Furthermore, where you have attended a webinar, seminar or event of Algonomy or purchased products or services from Algonomy, Algonomy may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.
   • Every computer device connected to the internet is given a domain name and a set of numbers that serve as that computer’s Internet Protocol or “IP” address. When you request a page from within the Website, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed the Website.
5. Right to object. You may object to Algonomy using Personal Data for the above purposes at any time by unsubscribing at https://algonomy.com/contact. If you do so, Algonomy will cease using your Personal Data for the above purposes (that is to say, under a legitimate interest set out above) and remove it from its systems unless Algonomy is permitted to use such Personal Data for another purpose set out in this Privacy Statement or Algonomy determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.

D. WHERE ALGONOMY USES YOUR PERSONAL DATA BASED ON YOUR CONSENT

In the following cases Algonomy will only use your Personal Data as further detailed below after you have granted your prior consent into the relevant processing operations.

1. News about Algonomy’s Products and Services. Subject to a respective provision and your consent, Algonomy may use your name, email and postal address and telephone number job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with Algonomy (prior purchases, participation in webinars, seminars, or events or the use of (web) services) in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about Algonomy’s software and services (including marketing-related newsletters) as well as events of Algonomy and in order to display relevant content on the Website. In connection with these marketing-related activities, Algonomy may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own data bases in order to display to you more relevant information.
2. Creating user profiles. Algonomy offers you the option to use its web offerings including forums, blogs, and networks (such as the Algonomy community) linked to this Website that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, and telephone number, personal interests, skills, and basic information about your company.
   These profiles may relate to a single web offering of Algonomy or, if created in the Algonomy Cloud Platform Identity Authentication Service, may also allow you to access other web offerings of Algonomy or of other entities of the Algonomy group, or both (irrespective of any consent granted under the section “Forwarding your Personal Data to other Algonomy companies.” below). It is, however, always your choice which of these additional web offerings you use and your Personal Data is only forwarded to them once you initially access them. Kindly note that without your consent for Algonomy to create such user profiles, Algonomy will not be in a position to offer such services to you where your consent is a statutory requirement that Algonomy can provide these services to you.
   Within any web offering, beyond the mere provision of access your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by Algonomy to foster the quality of communication and collaboration through such offerings and for Algonomy to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant web offering, you can use the functionality of the relevant web offering to determine which information you want to share.
3. Event profiling. If you register for an event, seminar, or webinar of Algonomy, Algonomy may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.
4. Forwarding your Personal Data to other Algonomy Algonomy may transfer your Personal Data to other entities in the Algonomy group, which may or may not be situated in a different jurisdiction. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above.
5. Forwarding your Personal Data to our marketing partners. Algonomy may, with your prior consent, share your Personal Data with our marketing partners to enable them to reach out to you for relevant marketing products and/or services that you may be interested in. For example, our marketing partners may reach out to you for programmes to improve customer satisfaction, performing market research, providing value added services, for regional support of services, or to organize Algonomy events. Algonomy will not, at any time, sell your Personal Data to any third party.
6. Forwarding your date to third-parties as a result of aquation, merger or bankruptcy. We also reserve the right to disclose and transfer your Personal Data: (i) to a subsequent owner, co-owner or operator of the Website; or (ii) in connection with a corporate merger, consolidation, bankruptcy, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change involving Algonomy. You will be notified via email and/or through a prominent notice on the Website of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data.
7. Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing at https://algonomy.com/contact. In case of withdrawal, Algonomy will not process Personal Data subject to this consent any longer unless legally required to do so. In case Algonomy is required to retain your Personal Data for legal reasons, your Personal Data will be restricted from further processing and only retained for the term required by applicable law. However, any such withdrawal has no effect on past processing of personal data by Algonomy up to the point in time of your withdrawal. Furthermore, if your use of an Algonomy offering requires your prior consent, Algonomy will not (any longer) be able to provide the relevant service (or services, if you revoke the consent for Algonomy to use your profile under the Algonomy Cloud Platform Identity Authentication Service for multiple Algonomy offerings), offer or event to you after your revocation.

E. MISCELLANEOUS

1. How does Algonomy protect your Personal Data
   Algonomy implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of your Personal Data such as (i) only providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible; (ii) using secure servers to store your information; and (iii) using Secure Sockets Layer (SSL) software or other similar encryption technologies.Our databases have a number of security measures to ensure there is no loss, misuse or illegal alteration of information collected from its users. The Personal Data we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet or wireless communication and any information you transmit to Algonomy you do at your own risk. If, despite our best efforts, an unauthorised breach of our security measures occurs, resulting in the unauthorised access, duplication, removal or alteration of any Personal Data, subject to applicable law, Algonomy, its directors, officers, employees, promoters, or affiliates will not be held responsible for any loss resulting from such unforeseen breach.

2. Changes to the Privacy Statement
   From time to time, we may update this Privacy Statement to reflect changes to our information practices, including due to any changes in Algonomy’s corporate structure or any changes in applicable law. Any changes will be effective immediately upon the posting of the revised Privacy Statement. If we make any material changes, we may notify you by email (sent to the e- mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

3. Grievance Officer
   If you have any questions or concerns about this Privacy Policy, please feel free to contact our grievance officer by writing to us at privacy@alogonomy.com or using the details provided on our ‘Contact Us’ page. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of personal information about you. Except where required by applicable law, Algonomy cannot ensure a response to questions or comments regarding topics unrelated to this Privacy Statement or Algonomy’s privacy practices.

F. GDPR SPECIFIC PROVISIONS

This Privacy Statement is in compliance with the provisions of the European Union General Data Protection Regulation (“GDPR”).

G. CCPA SPECIFIC PROVISIONS

Algonomy also complies with California Consumer Privacy Act (“CCPA”) as approved on August 14, 2020.  Algonomy believes and supports the five general rights for personal information under the CCPA, including right to know what information is being collected, the right to know if information is being sold/disclosed and to opt-out of such sale, the right to access personal information collected, the right to have such personal information collected be deleted, the right of non-discrimination for exercising their rights under the CCPA.

H. RUSSIA-SPECIFIC PROVISIONS

Algonomy also complies with California Consumer Privacy Act (“CCPA”) as approved on August 14, 2020.  Algonomy believes and supports the five general rights for personal information under the CCPA, including right to know what information is being collected, the right to know if information is being sold/disclosed and to opt-out of such sale, the right to access personal information collected, the right to have such personal information collected be deleted, the right of non-discrimination for exercising their rights under the CCPA.

YOU HAVE READ THIS PRIVACY STATEMENT AND AGREE TO ALL OF THE PROVISIONS CONTAINED ABOVE.