Exeter Premedia Private Limited (hereinafter “Exeter”/ “We”/ “Us”/ “Our”) is engaged in the business of providing editorial and digital publishing services including project management, artwork, design and data services.

This privacy policy (“Privacy Policy”) explains how we collect, use, share, disclose and protect the personal information about the users and visitors of, disclose and protect the personal information about the users and visitors (jointly and severally referred to as “You” or “User” in this Privacy Policy) of our website www.exeterpremedia.com (referred to as the “Website”).

BY USING THIS WEBSITE OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THIS PRIVACY POLICY.

IN THE EVENT YOU ARE LOCATED IN THE EUROPEAN UNION (“EU”) OR EUROPEAN ECONOMIC AREA (“EEA”), YOU WILL BE ASKED TO PROVIDE CLEAR AND AFFIRMATIVE CONSENT TO THE COLLECTION, PROCESSING, AND SHARING OF YOUR PERSONAL INFORMATION, SUBJECT TO WITHDRAWAL OF YOUR CONSENT AT ANY TIME ON REQUEST. EXETER WILL NOT SHARE ANY PERSONAL INFORMATION WITH ANY THIRD PARTY EXCEPT AS OUTLINED IN THIS PRIVACY POLICY OR AS PERMITTED BY LAW. THIS PRIVACY POLICY IS IN COMPLIANCE WITH THE INFORMATION TECHNOLOGY ACT 2000, THE INFORMATION TECHNOLOGY (REASONABLE SECURITY PRACTICES AND PROCEDURES AND SENSITIVE PERSONAL DATA OR INFORMATION) RULES 2011, REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 27 APRIL 2016 ON THE PROTECTION OF NATURAL PERSONS WITH REGARD TO THE PROCESSING OF PERSONAL DATA AND ON THE FREE MOVEMENT OF SUCH DATA (HEREINAFTER REFERRED TO AS THE “GENERAL DATA PROTECTION REGULATION” OR “GDPR”) AS AND WHERE APPLICABLE AND ANY OTHER APPLICABLE LAWS WITH RESPECT TO WEBSITE IN COLLECTION AND/OR PROCESSING OF PERSONAL INFORMATION (AS DEFINED HEREINAFTER) OF USERS, AND TO PROVIDE APPROPRIATE PROTECTION AND CARE WITH RESPECT TO THE TREATMENT OF SUCH INFORMATION IN ACCORDANCE WITH APPLICABLE LAWS.

YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT ACCESS OUR WEBSITE. IF YOU VISIT THE WEBSITE ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

A) When you access our Website, You may provide us with Your Personal Information, including when you register an account with us or sign up to receive announcements or other information from Us. Such information may be inclusive of but not limited to:

1. Your personal details such as Name, Date of Birth/Age and Gender,
2. Contact Details such as Residential Address, contact number, email address,
3. Login ID and password,
   
4. Your usage details such as time, frequency, duration and pattern of use, features used and any other information that is willingly shared by You.
5. Financial and payment information when you make purchases (where relevant).
6. Any other information specifically collected by us in connection with services we may offer to you under a separate agreement.

B) In addition to the above, the following information is defined as “Personal Information” is defined under Information Technology (Reasonable Security Practices & Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”) to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

The SPDI Rules further define “sensitive personal data or information” of a person to mean personal information about that person relating to the following: (i) passwords; (ii) financial information such as bank accounts, credit and debit card details or other payment instrument details; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information; (vii) information received by body corporate under lawful contract or otherwise; (viii) visitor details as provided at the time of registration or thereafter; and (ix) call data records.
(Points (A) and (B) shall collectively referred to as “Personal Information“).

C) We may also obtain information about you from other sources and we may add and maintain such information along with the information about you obtained through the Website.

D) To improve the responsiveness of the Website, as you navigate through the website, we collect your computer operating system type, browser type, browser language, the websites you visited previously, pages you viewed, time spent on each page, access times and information about your use and actions on our site. Certain other information is also passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as internet protocol addresses, cookies, internet tags, and navigational data collection. Navigational data is used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors. Cookies are small data files stored on your hard drive by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience when using the Website. This type of information is collected to make the Website more useful to you and to tailor the experience with us to meet your interests and needs.

E) You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or if Exeter has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Exeter shall disregard and delete such at its sole discretion, and may bar/restrict you from using or accessing its Website in the future. Exeter shall retain the right not to correct, delete or update your Personal Information, including (a) where the Personal Information is opinion data that is kept solely for evaluative purpose; and (b) the Personal Information is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

By providing your Personal Information and / or accessing the site, you are consenting to the collection, storage, use and disclosure of your Personal Information by Exeter to operate, maintain, and improve the Website and the services offered by it, to process and deliver contest entries and rewards, to respond to comments and questions and to provide customer service, to send information including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages, to communicate about promotions, upcoming events and other news about products and services offered by us and our selected partners, to link or combine user information with other personal information, to protect, investigate and deter against fraudulent, unauthorized, or illegal activity, or to provide the products or services that you request.

Collection of information which has been designated as ‘sensitive personal data or information’ under the SPDI Rules requires your express consent and by affirming your assent to this Privacy Policy, you provide your consent to such collection as required under applicable law. As outlined in this Privacy Policy, we will not process your Personal Information without a lawful basis to do so. In general, We may process your Personal Information on the legal basis of: (i) consent (ii) contract (if you have either availed services and/or entered into an agreement with Exeter and such processing is a necessary part thereof); (iii) compliance with Applicable Laws (as set forth below); (iv) to protect the vital interests of any individual. 

If You are a User from EU or EEA, then You will be asked to provide clear and affirmative consent to the collection, processing, and sharing of your Personal Information by/with Exeter, subject to withdrawal of your consent at any time on request. Under GDPR, EU/EEA residents have the following rights: 1. To know the purpose to process the Personal Information; 2. To know the status of Personal Information processed; 3. Access the Personal Information that is processed; 4. To erase or rectify the Personal Information; 5. Restrict the processing of the Personal Information; 6. Data portability of the Personal Information provided by you. This allows the User to download all Personal Information that has been shared with Exeter in a readable format for your own purposes; and 7. Opt-out option from processing the Personal Information (unless Exeter has otherwise compelling legitimate grounds) The abovementioned rights can be exercised by EU/EEA residents by contacting Exeter at privacyinquiries@exeterpremedia.com.

• Exeter will take reasonable steps to accurately record the Personal Information that you provide to Exeter and any subsequent updates. As a User, you have the right to access and correct your Personal Information that Exeter holds. 
• You can follow the “unsubscribe” instructions in commercial email messages. If required by you, Exeter will delete the Personal Information provided by you, but Exeter may retain information about you for the purposes authorized under this Privacy Policy and for the duration as mentioned in this Privacy Policy, unless prohibited by law. Thereafter, Exeter will either delete your Personal Information or de-identify it so that it is anonymous and not attributed to your identity. Upon deletion of your Personal Information, copies of your Personal Information may remain viewable in cached and archived pages.
  
• We shall retain your Personal Information for a duration of 1 (one) year unless otherwise agreed to under an agreement between You and Exeter or if we require the Personal Information for a longer duration in order to provide services to You, under a separate agreement.
• The data protection rights available to you include: the right to access, right to rectification, right to erasure, right to restrict processing, right to object to processing, right to data portability.

We shall not disclose your Personal Information to third parties except as mentioned herein:

• At your direction to disclose such information;
• We may share or disclose your non-private, aggregated or otherwise non-personal information with third parties in compliance with the terms of this Privacy Policy and the applicable laws.
• Information that we collect from our Users, including Personal Information, is considered to be a business asset. As a result, if we are acquired as a result of a transaction such as a merger, acquisition or asset sale or if we go out of business or enter bankruptcy, your Personal Information may be disclosed or transferred to the third-party acquirer in connection with the transaction.
• We may share or disclose your Personal Information for legal, protection and safety purposes, including to comply with laws, to respond to lawful requests and legal processes, and to protect the rights and property of our company, agents, customers and others, which includes enforcing our agreements, policies, and terms of service. We may share information in an emergency, which includes protecting the safety of our employees, our customers, or any other person, however in compliance with applicable laws.

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you. You may send requests about your Personal Information to our contact information below. You can request to change contact choices, opt-out of certain information sharing with others, and update your Personal Information. You can typically remove and reject cookies from our site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our site works for you. You may at any time also intimate to us that you wish to have your data erased from our servers/records. We will in such circumstance comply and within reasonable timeframes have such data removed from our servers.

• Exeter takes all necessary precautions to protect your Personal Information both online and off-line, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures in order to prevent unauthorized access, disclosure or use of your Personal Information.
• Please be aware, however, that these security measures do not guarantee that your information will not be accessed, compromised, corrupted, disclosed or destroyed. Accordingly, we cannot guarantee the absolute security of any information.
• By using the Website, you acknowledge that you understand and agree to assume these risks. Your Personal Information may be stored on the servers provided to us by third parties (based on separate agreements containing security related clauses in accordance with applicable laws)
• Exeter makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations. Exeter shall not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Exeter discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Exeter believes in good faith that disclosure is reasonably necessary to protect the property or rights of Exeter, third parties or the public at large.
• Exeter is not responsible for the confidentiality, security or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, Exeter shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Exeter including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.

We do not knowingly collect Personal Information from children under 18. If you become aware that your child has provided us with Personal Information without your consent, please contact us at privacyinquiries@exeterpremedia.com. If we learn that we have collected Personal Information of a child under 18, we will take steps to delete such information from our records and terminate the child’s account as soon as possible.

If Exeter, or substantially all of its assets, were acquired, or in the unlikely event that Exeter goes out of business or enters bankruptcy, the acquired Personal Information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Exeter may continue to use your personal information as set forth in this policy.

In case of any questions, queries, feedback, comments, or concerns about any of the terms of this Privacy Policy, you are requested to contact us through e-mail at privacyinquiries@exeterpremedia.com.