Poocho Research Technologies Private Limited (“Poocho,” “Company,” “we,” “our,” or “us”) is an online venue where Poocho and other companies or groups (hereinafter referred to as “Researcher”) create web application-based research projects and surveys (collectively “Studies”) that are shared by Researchers across their networks for interested individuals (collectively called “Pals”) to participate in for research purposes. The users of the Platform, to whom the Platform is provided for the purposes of using the services Researchers and or Pals as the case may be (hereinafter referred to as “Users” or “you”). 

‍LEGAL BASIS:
‍This Privacy Policy (‘‘Privacy Policy’’) is meant to help the Users understand what information we collect, why we collect it, what information we disclose and how the Users can update, manage, export, and delete their information.  It shall be read with our Terms and Conditions found in the next section and in compliance with the following: 
i. The Information Technology Act, 2000
ii. The Information Technology (Reasonable Security Practices and Procedures and Personal Information) Rules, 2011 (the “IT Rules”)
iii. The Information Technology (Intermediaries Guidelines) Rules, 2011.Any other applicable laws

Introduction.
‍This privacy policy (“Privacy Policy”) explains how we collect, use, disclose and transfer information from and about research participants (“Pals”) collected through the Poocho web application (the “App”), the Poocho website located at www.poocho.co and poochopals. com and any other website, widget, mobile application, or other services that link to this Privacy Policy (collectively, the “Platform”). Please review this Privacy Policy carefully. If you, as a Pal, do not agree with our policies and practices as outlined in this Privacy Policy, you should not use or register with the Platform.
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1. What Information Do We Hold and Collect and From What Sources Do We Collect It?

(a) Required Registration Information
‍Pals must create an account to use the Platform. An account may require the Pals to provide at least first name, last name, email, mobile phone number and date of birth (“Account Information”).
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‍(b) Pal Profile Information
‍Pals must also complete their profile in order to qualify for Studies. This profile information includes but is not limited to gender, country of residence, household information, education information, income, and employment status, and general preferences.Some of this information may be considered Sensitive Data. “Sensitive Data” means information specifying medical or health conditions, racial or ethnic groups, political opinions, religious or philosophical beliefs, trade union memberships, or information specifying the sex life of an individual.This information helps Poocho and Researchers contextualize your responses in the context of a Study. Pals may update, change, or delete this additional profile information through the App at any time.The information described in paragraph 1(b) along with the name is referred to in this Privacy Policy collectively as “Pals Profile Information.”By creating an account or posting this additional profile information, Pals understand and acknowledge that Poocho and Researchers will be able to view and use this Pal Profile Information without disclosing any personally-identifying information as outlined in this Privacy Policy.
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‍(c) Social Media Information
‍If you choose to register for the Platform via a third-party service with which you have an account like Facebook, we collect information from your third-party accounts, such as name, email address, profile picture, list of friends, people you follow, likes, work, and education history, current city or other third-party account information that your privacy settings in your third-party account permit us to access. Third-party services, such as Facebook and other social networking services, have their policies concerning the collection, use, sharing, and protection of your information. Poocho does not have any control over how any third-party services use or disclose the information they collect about you. Poocho shall not be responsible for any information disclosed by any such third-party and no claims shall further be brought against Poocho.
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‍(d) Information Provided by Pals in Response to Studies
‍Each Study in which a Pal participates requests the Pal to submit information in the form of live or recorded video interviews, phone calls, and/or multimedia responses to surveys (collectively, “Study Data”). Similarly, we sometimes send Screener Surveys (“Screeners”) to prospective Pals for potential Studies that request additional information (“Screener Data”).Participating in any Study or Screener is optional. However, any Study Data or Screener Data that is submitted to Poocho and the applicable Researcher may be used as described in this Privacy Policy, including for the Researcher’s business purposes. By submitting Study Data or Screener Data, Pals are consenting to allow Poocho and Researchers to view and use this information for varied purposes as outlined in this Privacy Policy. Unless otherwise specifically consented by you, Poocho shall keep the information anonymous as mentioned herein. We reserve the right to create and use anonymous information, information that cannot reasonably identify you, or as otherwise defined by applicable law, for any purpose and to disclose such information to third parties in our sole discretion.
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‍(e) Information We Automatically Collect as You Access and Use the Platform
‍To provide Platform, we may require certain user information and may obtain the same through User-provided data or automatic data collection. In addition to any information that you choose to submit to us, we and our third-party service providers use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Platform (“Usage Information”). This Usage Information includes the browser that you are using, the URL that referred you to the Platform, all of the areas within the Platform that you visit, and the time of day, among other information. In addition, we collect the IP address or other unique identifier (“Device Identifier”) for a user’s computer or other device used to access the Platform (a “Device”). A Device Identifier is a number that is automatically assigned to a Device used to access the Platform, and our computers identify a Device by its Device Identifier. With your permission, we and our service providers collect and use precise location data, cellphone movement sensor data, or information about the websites or apps you visit. We collect and use your Device’s operating system and version, Device type, and carrier name if you are using the App on a Mobile Device. A few of the methods that we use to collect Usage Information include, without limitation,  cookies, beacons, and embedded scripts (any subsequent technology and methods hereafter developed).
• Advertisements on Other Websites. We display advertisements for recruiting Pals on other websites and services. When you click on a Poocho advertisement on these other websites and services, we receive information about the website or service that served the advertisement, and which advertisement you clicked. If you then interact with our Platform, we may combine the information about your activity with our advertisement with the information we subsequently collect and/or you subsequently submit on our Website.
• Email Receipt. If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing studies. 

(f) Payment and Tax Information
‍If you are a Pal, we collect your Paytm or Google Pay or online banking/payment account information and such other associated information, to provide compensation for Studies; Pals who earn over certain amounts of compensation may be required to provide additional documentation to allow Poocho to send certain tax documentation.

‍2. How Do We Use the Information Collected?
‍We may use your information:
• to provide you with information or the Platform;
• to create and maintain your accounts;\
• to process transactions or payments that you have requested or agreed to receive;
• to process your registration with the Platform, including verifying your information is active and valid;
• to search for you and contact you about participating in Screeners, Studies, or active survey participation opportunities or data collection to build your Pal Profile;
• for internal record keeping and administrative purposes; and to run competitions and/or offer additional benefits to you
• to determine if you qualify for or inform you about Studies in certain locations;
• to establish and conduct Studies on behalf of Researchers or Poocho, or Studies by Researchers and, under our contract with you (the Pal Terms and Conditions), provide Researchers with Study Data, certain Pal Profile Information, and certain Screener Data for Researchers to use for their own business purposes;• if it is Study Data or Screener Data, as part of a Study in which a Pal has participated, including to analyze and synthesize research findings;
• to enhance or improve the Platform;
• to customize your experience with the Platform, or to provide you specific content that is most relevant to you;
• for research, statistical analysis, and business intelligence purposes with the help of computer science technologies including without limitation, artificial intelligence, and machine learning. Such demographics will be in an aggregated or non-personally identifiable form thereby ensuring anonymity unless specifically consented by You to use the information for the above-mentioned purposes in a non-anonymous form.  
• to contact you (such as via email) with regard to your use of the Platform and, in our discretion, changes to the Platform and/or the Platform’ policies;
• to send offers and promotional materials related to the Platform and for other Poocho marketing purposes;• for Poocho’s advertising, marketing, publicity, and promotional activities. Such demographics will be in an aggregated or non-personally identifiable form thereby ensuring anonymity unless specifically consented by You to use the information for the above-mentioned purposes in a non-anonymous form.  
• to transcribe interviews and/or videos;
• for other purposes disclosed at the time you provide your information or as otherwise outlined in this Privacy Policy;
• to comply with any procedures, laws , and regulations which apply to us, to comply with our legal obligations or, otherwise, where it is necessary for our legitimate interests or the legitimate interests of others; or to disclose your information if we believe it is necessary to share information to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or property, violations of the Platform other policies, or as otherwise required by law when responding to subpoenas, court orders and other legal processes.

‍3. How and When Do We Disclose Information to Third Parties?
(a) Sharing Pal Profile Information and Study Data with Researchers
When you apply for a Study, participate in and are subsequently compensated for Studies and for providing your Study Data, certain Screener Data, and Pal Profile Information, you agree to assign all right, title, and interest in all such data to Poocho and the applicable Researcher, and all such information belongs to Poocho and/or the relevant Researcher. If you are a Pal, you expressly consent to Poocho sharing certain Pal Profile Information, Screener Data and Study Data with a Researcher if you apply to a Study posted by that Researcher, including any Sensitive Data that is included in Pal Profile Information. As a Pal, you can withdraw or modify your consent to our future collection, sharing and processing of the Pal Profile Information at any time, by changing your account settings or your profile or by deactivating your account or by contacting Poocho on the information as provided below, subject to the restrictions described herein.

Note: The Pals may require to contact us in order to delete and/or update the data in cases of early stages of the Studies.

The security of information is important and we have implemented commercially acceptable means to protect the same. However, remember that no method of transmission over the internet, or method of electronic storage, is 100% secure, and we cannot guarantee its absolute security. We have implemented all reasonable industry practices, and security policies, rules and technical measures to protect the data including information that is under Poocho’s control from unauthorised access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the Pal’s electronic devices through which the user avails the Platform, we shall not be held liable for any loss whatsoever incurred by the Pal.

In the event, our service providers and third parties distribute information outside the scope of our agreement with such providers’ or third parties, then Poocho cannot be held liable for the confidentiality. Further, Poocho shall not be held responsible, in cases of breach of security or actions including without limitation, computer hacking, unauthorized access to computer data and storage device, computer crashes, etc. 
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‍Compliance with Data Protection Regulations
‍The information we obtain from or about you may be processed and stored in India and our other various servers located across the globe, which may provide for different data protection rules than the country in which you reside. You hereby consent to the collection, transfer, use, storage and disclosure of your information as described in this Privacy Policy, including the transfer of your information outside of your country of residence.
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If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Poocho Research Technologies Private Limited aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your information.If you wish to be informed about what information we hold about you and if you want it to be removed from our systems, please contact us on the details as given below.
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‍(b) Sharing When You Agree To Receive Information from Third Parties
‍You may be presented with an opportunity to receive information and/or marketing offers directly from third parties. If you consent to have your information shared, your information will be disclosed to such third parties and all information you disclose will be subject to the privacy policy and practices of such third parties. You should review the privacy policies and practices of such third parties. If you later decide that you no longer want to receive communication from a third party, you will need to contact that third party directly.
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‍(c) Sharing With Third Parties Providing Platform on Our Behalf
‍We may use third party vendors to perform certain services on our behalf, such as hosting the Platform, designing and/or operating the App’s features, tracking App or website analytics, collecting mobile sensor data, and enabling Poocho to send you information about participating in Studies and you consent to the disclosure of the Information to such third parties. We may provide these vendors with access to certain of your information to carry out the services they are performing for us. These third party vendors are not permitted to use your information other than for performing services for Poocho. 
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‍(d) Sharing of User Generated Content
‍The Platform may permit you to submit ideas, photographs, videos, writings, pictures, data, questions, comments, suggestions, or other feedback in a forum available to the public. This information will become publicly available. Poocho is not responsible for the use or misuse of any such content.
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‍(e) Sharing With Your ConsentWe share your information for any other purpose disclosed by us at the time you provide the information.

‍4. How Do I Access, Change, or Delete My Information, Exercise Choices, and Change Communications Preferences?

(a) Accessing, Correcting and Deleting Information
‍You are responsible for maintaining the accuracy and legality of the Account Information and Pal Profile Information you submit to us. Except as described herein, the Platform will allow you to directly review, correct, update, or remove your Account Information and Pal Profile Information at any time. For automatically- collected information, you also can exercise certain opt-out rights by following the instructions in section 1(e) above or by contacting us as outlined in “Contact Us” below.Individuals in the European Union and some other jurisdictions have certain legal rights (including, in certain cases, under the EU) to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in certain circumstances. They may also object to our uses or disclosures of personal data or exercise legal rights to withdraw consent, though such actions typically will not have a retroactive effect. Poocho will make every effort to respond to your request within the period required by applicable law, usually within 30 days. Please note that certain information may be exempt from such requests in certain circumstances, such as if we need to keep processing your information to perform our contractual obligations, including to Study Data, or for our legitimate interests.

In situations in which we process personal data on behalf of our customers, such as a Researchers, we may refer the request to the relevant customer and cooperate with their handling of the request, subject to any special contractual arrangement with that customer. In addition to the rights above, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
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‍(b) Deactivating Your Account; Retention of Your Information by Poocho
‍We keep your information as long as reasonably necessary for the purposes for which it is processed. The length of time depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.You may deactivate your account by contacting Poocho and requesting that your account be deactivated. See “Contact Us” below in this Privacy Policy. If you deactivate your account, your Account Information, and Pal Profile Information, and your payment account information (as applicable) will generally be deleted within 30 days. However, we may retain your certain information even after you have deactivated your account if retention is reasonably necessary to comply with our legal obligations, to meet regulatory requirements, to prevent fraud and abuse, or to enforce this Privacy Policy, or other legal agreements with users, Researchers or Pals, or for certain legitimate business interests. We may also retain information for a limited period, if required by law.

‍5. Information Relating to Children Under the Age of 13
‍The Platform is not intended for use by children under 13 years of age (or in the EU, children under 16 years of age). We do not knowingly process data of EU residents under the age of 16 without parental consent. If we learn that we have collected or received personal information from a child under 13 or from a child in the EU under the age of 16 without parent or guardian consent, we will take reasonable steps to delete that information. If you believe that we might have any information from or about a child under 13 or from a child in the EU under the age of 16, please contact us as provided in the “Contact Us” section below.

‍6. How Information Is Protected
‍When using our application, your Poocho account may be secured by user-created passwords and/or one-time password(s) (OTP) which may be automatically generated and sent to your registered phone number and/or email-id for one time use only, in which case reasonable precautions are taken to ensure that your Account Information or Pal Profile Information is kept private. You are responsible for keeping your passwords confidential. We ask you not to share your password and/or OTP with anyone.We implement physical, technical, and administrative measures to protect your information stored within our databases, and we restrict access to such information to those employees who need access to perform their job functions, such as our customer service personnel and technical staff.Despite these efforts, please note that we cannot 100% ensure or guarantee the security of your information. Unauthorized entry or use, hardware or software failure, and other factors could compromise the security of your information. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to the Platform and that any such transmission is at your own risk.

‍7. Changes to This Privacy Policy
‍We reserve the right to change this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will provide notice to you on the Platform or by some other means, such as e-mail. Please review the changes carefully. If you agree to the changes, simply continue to use the Platform. If you object to any of the changes and no longer wish to use the Platform, you may deactivate your account. Unless stated otherwise, our current Privacy Policy applies to all information we have about you or your account. Using the Platform after a notice of changes has been communicated to you or published on the Platform shall constitute consent to the changed terms or practices.

‍8. Contact Us
‍If you have any questions about (a) access to your information; (b) the collection, use, management, or disclosure of your information; or (c) this Privacy Policy, you should contact us by email at pals.support@poocho.co