Introduction
O(1) India Private Limited, a company registered under the Companies Act, 2013 having its registered office at Office no. 401, 4th floor, Prudential building, Central Avenue, Powai, Mumbai, MH (400076) operates this platform with brand name Roposo Clout (hereinafter referred as “Roposo Clout”, “We”, “Us” or “Our”).
We respect Your privacy while you access ‘Roposo Clout’ (“Application”)/ app.roposoclout.com (“Website”) and other associated applications, devices, products, online marketplace and services managed by Roposo Clout that reference to this Privacy Policy (collectively referred to as the “Platform”). For the purposes of this privacy policy the term “User(s)” and wherever the context so requires “You”, “Your”, “Yourself” shall mean any natural or legal person who accesses or uses the Platform and in the event that a natural person is representing a business entity, reference to such terms shall include a reference to such business entity as well.
We, at Roposo Clout, aim to adhere to the ethical standards pertaining to collection, usage and safeguarding of the information provided by you during the use of the Application and/or the Website.
Roposo Clout has adopted this privacy policy (“Privacy Policy”) to inform You of: the information We collect from You through the Platform; the manner of collection and processing of such information; use of such information; and the steps We take to protect it. Capitalized terms not defined herein shall have the meaning ascribed to them in the Merchants’ Agreement and the Buyers’ Agreement. By using the Platform, You unconditionally agree to the terms and conditions of this Privacy Policy and consent to collecting, usage, storage, processing, handling, transferring and sharing of the information submitted by You in accordance with the terms contained hereunder. Please read the Privacy Policy before using the Platform and if You do not agree with the terms and conditions of this Privacy Policy, please do not proceed further to use this Platform.
“Group” as used in this policy, means, with respect to Roposo Clout, its affiliates and group entities listed here.
USER INFORMATION
The Platform collects certain information and data when you register via the Application or the Website. There are two types of information being collected: (A) User Provided Information; (B) Automatically Collected Information during the usage of the Service.
User Provided Information and Access
Whenever you install, download, access, use the features and/or interact with the content of Roposo Clout, we may collect personal information as stated below.
Roposo Clout collects your Information when you successfully submit information while installing the application and/or creating your account and/or while confirming your order on the Platform. While doing so, we may collect data that can be used to uniquely identify or contact a person and/or the business entity that a person represents and shall include, but not be limited to, information regarding Your name, Phone number, Email address, name of the business entity that You represent, Address of the business entity, Your and/or Your customer’s address and telephone number, Your and/or Your customer’s e-mail address and such other information for the purposes of identification and verification. We may also ask you to share the OTP sent via SMS or a password or to verify a link sent on your e-mail address. While you are using our Platform, we record your responses and activity data, including but not limited to, textual and voice responses and session details. We do not directly process any payments and do not store your debit/credit card information. Secured socket layer technology is used for processing payment transactions with third party service provider partners. When You submit User Information on the Platform including any information of Your customers, it shall be deemed that You have granted Us the right to collect, store, process, handle and use such User Information, in accordance with this Privacy Policy (as amended from time to time) and You confirm you have adequate and legally appropriate consents from Your customers to share the same . To facilitate refunds in case of returns, you may also be asked to provide bank account information.
We may ask for permission to access your data storage. However, the data storage access shall be limited to the access to store the data downloaded or saved during the usage of the Platform or the products directly in the User’s device for ensuring easy storage and access to the User. We shall not utilize this permission to access to any other data on the User’s device, except as expressly mentioned in this Privacy Policy.
We use a third party payment platform and payment aggregator services to bill you for products and services. We may use and share the User Information with reliable and reputed third-party payment gateway to whom we are associated in order to ensure swift and comfortable payment mechanism for the User. The third party service providers shall provide Us the phone number of the User utilized while completing the payment transaction.
After the User is directed to the payment mechanism and the payment gateway, We are not liable for any data stored, used or accessed by such a third party service provider and the User Information is no longer governed by this Policy or our Website's Terms of Service. The same shall be subject to the terms and conditions and privacy policy of the third party service provider. For these third party service providers, we recommend that you read their privacy policies in order to understand the manner in which your personal information and your credit/debit card details will be handled by these providers.
The said information collected from the Users could be categorized as “Personal Information”, “Sensitive Personal Information” or other information. The Personal Information, Sensitive Personal Information or other information shall collectively be referred to as “User Information” in this Policy.
We may use the User Information to contact you or your customer from time to time, to provide the services we offer through the Platform, important information and circulate marketing and promotional material in relation thereto through SMS, calls, and email. By using this Platform, you are also opting-in to receive such information and promotional content via WhatsApp. In case, you do not wish to receive any communications via WhatsApp, please reply ‘STOP’ to opt-out of this facility. We may ask you for more information for identification purposes, if required (personal information). The User shall be permitted to access the Website or Application via any device provided that the log in/access credentials match with the User credentials. In the event the User uses a new device to access or log-in to the Website or Application, the User shall be required to grant access for the new device, as may be required.
By using this Platform, You consent to the collection, storage, use and transfer of the User Information (including personal information and sensitive personal data, including my payment details) that you provide in connection with any of the services that We offer through our Platform in accordance with this Policy and You consent to the collection of any changes or updates that you may provide to the User Information.
Roposo Clout collects only such User Information that Roposo Clout believes to be relevant for the purpose of identification and verification and is required to understand You or Your interests. It is clarified that We shall not be liable, for any reason whatsoever, for the authenticity of any User Information provided by You to Us. You hereby confirm that the User Information provided by You is and shall continue to be valid, true and accurate to the best of Your knowledge.
Any portion of the Information containing personal data relating to minors or a person of unsound mind provided by you shall be deemed to be given with the consent of the legal guardian. Such consent is deemed to be provided by your registration with us.
Automatically Collected Information
When you visit the Platform, we may collect certain information about or on your device such as your internet protocol address, operating system, browser type, and internet service provider. This type of information does not identify you personally during Your visit to the Platform. We can identify You only after You submit User Information at the time of registering Yourself with the Platform.
COLLECTION OF INFORMATION
The User Information collected by Us will be deleted as per the Data Retention Guideline identified below. We may, at its option, not provide any services for which the User Information was sought and the User shall not claim deficiency of services on the basis of such non provision of goods and services.
To enhance Your use of the Platform, certain information may be collected each time You visit the Platform which are saved in server logs. It is clarified that these statistics help Us in improving the efficiency of the Platform by giving Us information relating to Your use of the Platform. Such information may include details of the server from where the Platform is being accessed, the browser and operating system used to browse the Platform, details of Your last visit to the Platform, including time, date and the duration of Your session on the Platform. This information is used by Roposo Clout to understand the number of users visiting the Platform and gather broad demographic information for aggregate use of the Platform. While collecting such information, Your anonymity shall be maintained at all times and at no time can We identify You personally, unless You submit the Information on the Platform or through the e-mail feature. Roposo Clout reserves the right to share such general information to any person on its discretion.
You acknowledge that apart from Your User Information, if You upload or exchange any data, content, information, pictorial representations and/or images including post any comments on the Platform (collectively referred to as the “Content”), such Content may contain information including User Information and the same may be available to the other Users of the Platform. Roposo Clout will not be liable for the disclosure and dissemination of such User Information on the Platform.
We may also receive information from third-party partners. The information provided in these cases follow the respective privacy policies of such third parties. In the context of advertising displayed on our Platform, Group (in their capacity as advertising partners), ad networks, advertisers or such other third-party demand partners (collectively “Ad Partners”) may also disclose to us certain personal or non-personal information they have separately collected about You so that we can effectively provide our services. They do this in accordance with their own specific privacy policies and subject to their own applicable legal requirements and, we will treat such information in accordance with the privacy policies of such Ad Partners in addition to this Policy, subject to the terms of the former. We do not use the information they provide to us for any purpose other than for providing or improving our services.
COOKIES
Like most other Platforms, We use data collection devices known as cookies to collect and store information of Users visiting the Platform. A cookie is a small amount of data that is sent to a User's browser from a web server/mobile application and is eventually stored on a User's computer hard drive/mobile device. Cookies are a reliable mechanism for Platforms to remember the activities of the User on the Platform and helps in improving Your experience on the Platform. This anonymous information is maintained distinctly and is not linked to the User Information You submit to Roposo Clout. The option of accepting cookies is up to You, however certain features of the Platform including Content and the forms may not be accessible without accepting cookies.
To browse anonymously, You may set your browser to disable cookies or delete cookies. Most cookies are session cookies that are automatically deleted from Your hard drive when You close the browser. Additionally, You may encounter cookies or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties and shall not be liable for any reason whatsoever for these third party cookies.
USE OF THE USER INFORMATION
We collect the User Information provided by You for the reasons including but not limited to the following:
verifying Your identity;
facilitating Your use of the Platform;
facilitating successful purchase of Products from the Platform;
responding to Your queries or complaints or to fulfil Your requests for information about the services and solutions that We offer and the process relating to the same;
providing You with information about Roposo Clout and to send You information, materials, and offers from Roposo Clout;
sending You important information regarding the Platform;
personalizing Your experience on the Platform by presenting offers tailored to You;
helping You address trouble- shooting problems;
providing You with related customer service;
conducting internal reviews and data analysis for the Platform (e.g., to determine the number of visitors to specific pages within the Platform);
improving the Content on the Platform and to improve our features and provide seamless service;
protecting the integrity of the Platform; and
To protect against imminent harm to the rights, property or safety of the Platform, the Company, its Users or the public as required or as may be permissible under the applicable law and/or to comply with applicable laws
Provide information, materials, advertisements, promotions and/or offerings that may be of interest to You or to run survey campaigns by itself, Ad Partners or the Group including targeted advertisements and monetization activities through Roposo Clout Platform and/or advertising channels of its Ad Partners or the Group or media partners.
Enrich, build custom audience segments or merged data sets (using the data referred herein and/or third party or the Group provided data sets) to enable our Platform, Ad Partners or the Group to better target advertisements and offer their services.
To outreach prospective dropshippers.
DISCLOSURE OF USER INFORMATION
We may disclose Your information to the third parties for a variety of business purposes, as described below, in accordance with applicable privacy laws and regulatory requirements:
(a) provide You with the services on the Platform, and may be subject to the practices of such third parties;
(b) facilitate the purchase and delivery of the Products on the Platform by You;
(c) grow Our business which may include any event of corporate sale, merger, reorganization, sale of assets whereby share such User Information with the Group, strategic partners, investors, suppliers, and service providers as the case maybe or;
(d) The User Information may be disclosed to Key shareholders, board, investors (debt or equity), legal or financial advisors. The User Information may be disclosed to the employees,contractors, vendors, partners or the Group organizations on a need-to-know basis in order to undertake process on the behalf of the Company and/or to facilitate smooth functioning of our services, such as providing payment function, supply chain, network services, IT support, customer service etc.;
(e) We may share Your data with our Ad Partners, vendors, customers, data partners, measurement companies, influencer marketing agencies and/or brand partners for influencer marketing, and other third parties we partner with for providing our products and services including for facilitating and fulfilling Your purchase of products from the Platform. If an advertisement or monetization transactions are made available to You through advertising channels of Roposo Clout Platform and/or its Group, Platform may share Your data obtained by Platform with the Group for such advertising purposes.
(f) Any legal, governmental, or regulatory authority if it is required to comply with any legal order or process, issued or commenced, in accordance with the applicable laws.
(g) We may share your data with third parties to facilitate the live chat feature on the Roposo Clout platform to address your concerns.
We will share Your User information with third parties only in the ways that are described in this Policy. We may use the individual data and behaviour patterns combined with personal Information to provide You with personalized content, and better Your learning objectives. We may provide and utilise the User Information and data collected to certain third parties for undertaking data analysis via third party analytical tools. The third-party analytical tools are utilised in order to analyse the data and information to personalize, drive insights and thereby provide a better performance, improve the quality of features and provide seamless services to the User.
You acknowledge that some of the recipients of Your information may be located outside Your country of residence. Where we transfer Your information to such third parties, we will endeavour to ensure that Your information remains secure from unauthorized disclosure or theft. To the extent required under data privacy laws of the applicable jurisdiction, we may transfer such information pursuant to consent or through applicable data protection agreements or other mechanisms permitted under such laws.
YOUR DATA PROTECTION OBLIGATION
You represent and warrant that You will comply with all applicable laws, rules, regulations, legal directives and guidelines regarding the collection, use and disclosure of personal data collected from or about your customers which apply to the services utilized or transactions contemplated hereunder including, to the extent required by applicable privacy laws, obtaining consent from your customers, providing for appropriate and legally adequate privacy policy/notice (stating the concerned data sets processed, its purposes, opt out, data subject/consumer rights or data transfer mechanisms, as required), maintaining of measures to honour data subject or consumer rights, if applicable (collectively, the “Rules”). The term “Rules” shall include, without limitation, (a) all United States Federal Trade Commission rules and guidelines regarding the collection, use and disclosure of data from or about end users and/or specific devices; (b) all United States federal and state laws regarding data collection and data privacy; (c) the Self-Regulatory Principles and guidance of the Interactive Advertising Bureau (“IAB”), as each set of principles and guidance may be amended or supplemented, or as replaced or superseded, from time to time by the IAB, or their respective successor entity.
DATA SUBJECT RIGHTS
We are committed to upholding the applicable Data Subject Rights (DSRs) and ensuring the privacy and protection of User Information. This includes, but not limited to, the right to access, modify, or delete personal data, opt out of selling or sharing or personal information, or opt out of using or disclosing of sensitive personal information, as applicable under the relevant regulations.
You can raise these requests to us directly by contacting us as set forth below.
Additionally, You are required to adhere to and ensure compliance with applicable privacy laws concerning Data Subject Rights (DSRs) of your customers. You must promptly address and execute any DSR requests from your customers in accordance with relevant regulations. If there are any DSR requests or inquiries pertaining to data managed or processed by our platform, You can escalate and raise these requests to us directly by clicking here or contacting us as set forth below.
SECURITY PRECAUTIONS
To prevent any form of unlawful interception or misuse of User Information, We use reasonable physical, electronic, and managerial procedures to safeguard and secure the User Information collected. We use reasonably secure and technologically appropriate measures, in compliance with the Information Technology Act, 2000 and the rules related thereto to protect You against loss or misuse of Your applicable User Information including internal reviews of data collection, storage and processing practices and other reasonable security measures which are equivalent to security measures that Roposo Clout uses to protect its own confidential information. We have in place a secure server for all Your transactions on the Platform, which, if required to be accessed, are accessible only by the authorized personnel of Roposo Clout. However as You are aware, no internet site/mobile based application is completely free of security risks and We do not make any representation in respect of the same.
We do not warrant that Our Platform or any electronic communication made by Us is free from virus or other harmful effects. In the event of any errors in transmission or in the event of Our Platform being inaccessible due to an act of any third party or due to any outage, or any technical or technological failure, or similar reasons beyond our control, We shall not be held liable or responsible for any losses/ damages incurred by you, and you agree that you will not have any claims against us regarding the same. You explicitly agree that Your use of the Platform and/or services is at Your own individual risk. You agree and confirm that Your User Information may be collected, used, transferred, processed and stored in the manner stipulated in this Privacy Policy. You hereby confirm that You have been made aware of the security measures undertaken by Us and You expressly consent to Us collecting, storing, handling, processing and using Your User Information.
Links to other third party sites
The Platform may provide third party information and links to other platforms that are not part of the Group including but not limited to payment gateways or social networking platforms. Roposo Clout is not responsible for any form of transmission, whatsoever, received by You from any third party platform and accordingly does not make any representations concerning the privacy practices or other policies of such third party Platforms. Under no circumstances shall Roposo Clout be deemed to control or guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, cookies, messages or other materials available on such platforms. Any User Information provided by You to such third party Platforms shall be governed in accordance with the privacy policies of such platforms and it is recommended that You review the privacy policy of such platforms prior to using such platforms.
Data Retention Guideline
We may retain device information for a period of up to 36 months, unless otherwise required by law or applicable contract.
With respect to the account information, registration data and/or addresses provided for facilitating purchase of products, the same will be retained until your specific instructions to delete such data. You can place this request to delete your data by writing to us at privacy@roposoclout.com. We may retain transaction data and certain account information of Yours as may be required to comply with its legal obligations, resolve disputes (including billing) and enforce agreements.
We may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our legal, compliance and contractual obligations.
After the applicable retention period, We may retain and use such data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes (including billing) and enforce agreements.
INTERNATIONAL DATA TRANSFERS
All personal information processed by us, Advertising Partners, the Group or our Service Providers, may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
For more information about the safeguards, we use for international transfers of your personal information, please contact us as set forth below.
CHILDREN'S INFORMATION
Our Platform is not directed to children, and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, please contact us as set forth below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child's account.
Change in Privacy Policy
We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Platform after the new Privacy Policy takes effect.
Intellectual Property rights
Our Platform and all Content on Our Platform, including graphics, text, icons, interfaces, audio clips, logos, images, reviews, comments and software is the property of Roposo Clout and/or its Content suppliers and is protected by Indian and international copyright laws. Any use, including the reproduction, modification, distribution, transmission, republication, display or performance, of the Content on this Platform can only be made with the express permission of Roposo Clout. All other trademarks, brands and copyrights other than those belonging to Roposo Clout, belong to their respective owners and are their property.
Force Majeure
Notwithstanding anything contained in this Privacy Policy or elsewhere, Roposo Clout shall not be held responsible for any loss, damage or misuse of Your User Information, if such loss, damage or misuse is attributable to a Force Majeure Event. A "Force Majeure Event" shall mean any event that is beyond the reasonable control of Roposo Clout and shall include, without limitation, sabotage, fire, flood, explosion, pandemic, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, technical snags, outage, unauthorized access to computer data and storage device, technical snags and breach of security and encryption.
Disclosures Required By Law
Roposo Clout reserves the right to disclose User Information when required by law. We will disclose such User Information wherein We have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, or other legal process served on Us or to exercise Our legal rights or defend against legal claims.
Contacting the Platform
If You have any questions, or grievances regarding (i) this Privacy Policy; (ii) practices of this Platform, or (iii) Your dealings with this Platform or believe that We have not adhered to it or (iv) wish to unsubscribe from receiving communications via SMS, calls and email or (v) wish to exercise your rights, as granted under the applicable privacy laws, You can contact us at privacy@roposoclout.com and/or the Grievance Officer at grievance@glance.com.
Alternatively, you can chat with us on the help desk chat option available in the Application.
The Grievance Officer is identified above pursuant to the provisions of applicable laws including but not limited to the Information Technology Act, 2000 and the Consumer Protection Act, 2019, and the Rules enacted under those laws.
This Privacy Policy shall be read in conjunction with the Platform’s Terms of Service and all the relevant provisions of the Platform’s Terms of Service (including but not limited to indemnification, limitation of liability, governing law and dispute resolution) shall mutatis mutandis apply to this Privacy Policy and be deemed to be incorporated herein by reference.