PRIVACY@TAGMANGO

WHAT THIS PRIVACY POLICY COVERS

Our mission is to enable all our Creators to create and host their online digital business to reach and manage their end users, customers, and subscribers. In order to accomplish our mission and objectives, we are required to collect, store and process personal data of the Users.

Our commitment is not only to provide our Services, but also to secure your personal data in full compliance with the applicable laws, including the (Indian) Information Technology Act, 2000 and the rules, regulations, guidelines and clarifications framed there under, including the (Indian) Information Technology (Intermediaries Guidelines and Digital Media Ethics Code) Rules, 2021 and the (Indian)Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 and the (Indian) Digital Personal Data Protection Act, 2023 (collectively “Data Protection Laws”).

This Privacy Policy describes the privacy and security practices that TagMango employs when collecting, using and handling (processing) personal data and information about you in connection with our Services. It also explains the choices you have in relation to these processing activities.

Personal data or information means any data about an individual who is identifiable by or in relation to such data i.e. all information that relates to an identified individual or to an identifiable individual. For example, your name, address, email address, educational and employment background, professional and job qualifications.

It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

For the purpose of the Data Protection Laws, the company responsible for your personal data in India is TagMango Private Limited.

This Privacy Policy applies in relevant countries where we do business, although different countries may approach data privacy in slightly different ways and so we also have country specific parts to this Privacy Policy.

WHY TAGMANGO COLLECTS PERSONAL DATA

We have explained below the reasons why TagMango needs to collect your personal data and this forms our legal basis for processing your personal data and information.

Your Consent

Your use of the Platform and the Services and the processing of information about you for the purposes providing our Services are based on your consent. Any processing of your personal data in connection with your use of the Services is based on your explicit consent. Please note that you can always close your account and withdraw your consent, although this may affect our ability to provide you, our Services.

In certain circumstances, we are required to obtain your consent to process your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent. The Data Protection Laws require that consent should be freely given, should be specific and unconditional and be based on informed and unambiguous indication of the individual’s wish by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. In plain language, this means that: (i) you have to give us your consent freely, without us putting you under any type of pressure; (ii) you have to know what you are consenting to – so we'll make sure we give you enough information; (iii) you should have control over which processing activities you consent to and which you don’t; and (iv) you need to take positive and affirmative action in giving us your consent. We will provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion. We may also provide for such other methods by which the above requirement can be met. As we have mentioned, you have the right to withdraw your consent to these activities.

Performance of Contract

TagMango offers an online platform that allows a Creator to create and host his online digital business to reach and manage his end users, customers, and subscribers and its contractual obligation towards its Users is based upon terms and conditions published on the Platform from time to time. These terms and conditions set out the essential provisions that govern: (i) its relationship with the Users and clearly define and document our rights, responsibilities and obligations; (ii) a User’s access to and use of the Platform and the Services; and (iii) the transactions and activities undertaken by a User pursuant to the Services. We may have to process your information to perform our contractual obligations towards you. For example, where you have purchased a subscription from us and we need to use your contact details and payment information in order to process your order and deliver your subscription.

Legitimate Interests

The Platform is an online platform that allows a Creator to create and host his online digital business to reach and manage his end users, customers, and subscribers. TagMango merely makes the Platform and the Services available to enable a Creator to connect with his customers and transact directly with each other and vice versa

If you are a Creator and have subscribed to our Services, we feel it’s reasonable to expect that you are happy for us to collect and use personal data about you to help you provide our Services. We need to do these things so that we can function as a business, and to help you and your subscriber.

The processing of information about you as part of our Services is based on our legitimate interest to enable you to grow your business and connect with your customers.

Simply put, our processing of information about you for business operations purposes is based on our legitimate interest in operating our business in an efficient and appropriate manner. We have to make sure our business runs smoothly, so that we can carry on providing Services to our Users.

Establishing, Exercising or Defending Legal Claims

Sometimes it may be necessary for us to process personal data in connection with exercising or defending legal claims. The Data Protection Laws allows this where the processing "is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity". This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

Communications

In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing your information.

WHEN AND WHAT KIND OF PERSONAL INFORMATION DOES TAGMANGOCOLLECT AND PROCESS

Here's a more detailed look at the information we may collect and process. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity, Contact & Professional Data

When you register with us (or create an Account on the Platform and use the Services), we collect information that you provide voluntarily during your registration or creation and use of your Account. This includes information such as:

• full name (first name, maiden name, last name);
• profile name;
• username;
• gender;
• date of birth;
• address;
• contact number;
• email;
• profile picture;
• nationality;
• qualifications;
• education details;
• employment history;
• job-related skills;
• work history;
• language skills;
• preferred languages;
• interests;
• industry certifications;
• endorsements;
• achievements;
• desired compensation and rate of pay;
• other job-related data; and
• self-description.

Please note that you do not have to provide additional information to build your profile and it is solely at your choice to do so, including whether or not to include any personal information. We collect information that only you choose to give us. We strongly recommend you not to post or add personal data to your profile that you would not want to be publicly available or visible to others.

Transaction Data

This includes details about payments to and from you and other details of Services you have purchased from us.

Communications

If you contact us for customer support or otherwise communicate with us, we collect the content of these communications.

Location Information

When we provide our Services, we may ask you for, access, or track geo-location-based information from your device while using our Platform or downloading or using our applications or other functionality. If you choose to engage with these Services, we will receive certain information about your location, which may include country, state, city, or more specific location information, in order to provide you with the requested Services including geographically relevant features, offers, applications, and application recommendations.

Technical & Usage Data

When you access the Platform and/or use the Services, certain information is stored in our servers automatically. The information captured automatically includes the following:

• your login information;
• data about the pages you access within the Platform;
• your choices and behaviour;
• browser type and version;
• time zone setting;
• browser plug-in types and versions;
• your internet protocol (“IP”) address;
• device identity or unique identifier;
• device type;
• geo-location information (subject to your consent);
• device and connection information;
• operating system;
• technology on the devices you use to access the Platform;
• mobile network information;
• history of your visit, statistics on page views; and
• traffic to and from the sites, referral URL, ad data, and standard web log data and other information.

As you interact with our Platform, we may automatically collect technical data about your equipment, browsing actions and patterns. We may also collect information about your visit including the pages you visited, frequency of your visits, what you searched for, length of visits and methods used to browse away from the page. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

We also collect anonymous information through our use of cookies and web beacons.

The Platform uses persistent and session cookies and other similar technologies to offer you a personalized experience and to remember your browsing preferences, including your log in details and choice of language. Cookies are stored primarily to ensure that in the event you return to the Platform, it shall personalize your browsing, including, enabling you to be logged on the Platform automatically. This information may, where permitted by Applicable Law, also be combined with other information we hold about you. The cookies are uniquely assigned to you and can only be accessed by your web page server in our domain. You can disable our cookies or all cookies through your browser settings. Upon the beginning of each of your visits to the Platform, the Platform also provides the choice to turn off all cookies which are not strictly necessary for the provision of Services. Please be advised that disabling cookies through either method may impact many of the Platform’s features. In addition to cookies, we and/or our third-party advertising partners may use technologies that help us better manage and analyze content.

Third party platforms

If you register for or log into the Platform or Service using a third party platform (like Facebook or Google), they will furnish certain information to us to facilitate your account creation or log-in with us

Technical service partners

We sometimes receive information about you from technical service partners.

HOW TAGMANGO USES YOUR PERSONAL DATA

When we ask you to supply us with personal data, we will make it clear whether the personal data we are asking for must be supplied so that we can provide the Services to you, or whether the supply of any personal data we ask for is optional.

We generally use your information for the purposes described below:

Providing Services

We may use your personal data to fulfil a contract or take steps linked to a contract and to provide our Services to you. We may use your personal data to: (i) administer the Platform; (ii) improve your browsing experience by personalizing the Platform; (iii) enable your use of the Services available on the Platform; (iv) supply to you the Services purchased via the Platform; (v) send statements and invoices to you, and collect payments from you; and (vi) send you email notifications which you have specifically requested.

We may also use your personal data to: (i) review your activity on our Services to detect spam or activity that poses a risk to our community or the public; (ii) analyze your log data and device information to identify and investigate suspicious behaviour or violations of our policies or Terms;(iii) conduct age verification, as appropriate; (iv) conduct analytics and research on who is using our Services and what they are doing; (v) improve our products and services and those of our group companies and offer new features; (vi) create aggregated or de-identified information that cannot reasonably be used to identify you (we process, maintain, and use this information only in a de-identified fashion for the purposes of this Privacy Policy and will not attempt to re-identify such information).

Communications & Administrative Support

We may use your personal data to:

• to communicate with you in relation to the provision of the contracted Services;
• to provide you with administrative support such as account creation, security and responding to issues;
• to provide an improved user experience;
• to provide you with surveys, information about our offers and promotions, related to our Services; and
• deal with enquiries and complaints made by or about you relating to the Platform.

Please note that you do not have to provide additional information to build your profile and it is solely at your choice to do so, including whether or not to include any personal information. We collect information that only you choose to give us. We strongly recommend you not to post or add personal data to your profile that you would not want to be publicly available or visible to others.

Consent

Where you have given your express permission to receive marketing communications, we may use your personal data to send you newsletters, surveys, information about our awards and events, examinations, offers and promotions, related to our services which may be of interest to you.

Where required by law

We may also process your personal data if required by law or to comply with applicable laws and regulations, including responding to requests by government or law enforcement agencies or for the prevention of crime or fraud.

Marketing

We may use personal data to send direct marketing communications about our products and services that we feel you will be interested in. This may be in the form of email, or by SMS or any other electronic message. We may also send to you our newsletter and other marketing 6 communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, where you have specifically agreed to this. You can always choose to opt out of receiving direct marketing as all our marketing communications include unsubscribe links, alternatively, you can contact us to stop further communications. We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do this.

Statistical Purposes

We may use personal data for statistical purposes such as analyzing the performance of our sites and apps and to understand how visitors use them. We may look at what you have viewed on our sites and apps and what services you have bought to better understand what your interests and preferences are.

Security of the Platform

We also collect anonymous information through our use of cookies and web beacons.

We may use personal data to maintain the security of the Platform and our systems and networks. For example, we may process information about you when investigating suspicious activity on our sites, systems and networks.

WITH WHOM DOES TAGMANGO SHARE YOUR PERSONAL DATA WITH

Where appropriate and in accordance with laws and requirements, we may share your personal data, in various ways and for various reasons, with the following categories of people. Any organization which accesses your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and comply with all data privacy laws that apply. We will ensure there is a contract in place with the categories of recipients listed below which include obligations in relation to the confidentiality, security and lawful processing of any personal data shared with them. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We may also independently audit these service providers to make sure that they meet our standards.

Employees of TagMango

We may share your personal data with the employees, personnel and members of staff within TagMango when you provide TagMango with your information. We take all reasonable steps to ensure that our employees, personnel and staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a business need to know it.

Third Parties

We may also share your personal data with trusted third parties including:

• Contractors, service providers, vendors and suppliers contracted to us in connection with the provision of our products and services; and
• External and internal lawyers and/or specialist advisors and consultants.

Law Enforcement Agencies & Prevention of Unlawful Acts

We may disclose your personal data:

• to the extent that we are required to do so by law;
• to a court or governmental authority based on an order or direction from such authority;
  
• with the police or other law enforcement agencies in the event of a crime or offence or prevention of or detection or investigation of a crime or offence or cyber incidents;
  
• in connection with any legal proceedings or prospective legal proceedings for prosecution or punishment of offences;
  
• in order to establish, exercise or defend our legal rights (including providing information toothers for the purposes of fraud prevention and reducing credit risk);
  
• to prevent bodily harm to any person;
  
• to protect the safety, rights, or property of any person or the public;
  
• to protect the rights of anyone else; and/or
  
• to combat societal harms.
  

Successors

We may reveal your personal data to any other organization that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organization we transfer your personal data to uses it in line with our privacy policy. If we were to engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Privacy Policy, we would share your information with a party involved in such a process (for example, a potential purchaser).

INTERNATIONAL DATA TRANSFERS

TagMango is a worldwide service. By using our products or services, you authorize us to transfer and store your information outside your home country for the purposes described in this policy.

Data we collect may be transferred to, stored and processed in any country or territory where one or more of our group companies or service providers are based or have facilities. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal data that we transfer in line with this Privacy Policy.

Whenever we transfer your personal data out of India, we ensure similar protection and put in place atleast one of these safeguards:

• We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data; and
  
• We may also use specific approved contracts with our service providers who are based in countries outside India. These contracts give your personal data the same protection it has in India.
  

FOR HOW LONG DO WE RETAIN PERSONAL INFORMATION

The term for which we shall be retaining your personal information depends solely on the nature of the information. The storage periods are determined on a case-by-case basis. We keep account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or depersonalize it so that we cannot use it to identify you.

We may, however, retain your personal information for: (i) accounting purposes for such time period as is prescribed under Applicable Law; and (ii) for legal purposes till the completion of statutory limitation for bringing any suit, if any. We will also retain your information for the purposes and for such time periods as may be prescribed under Applicable Laws.

Under certain circumstances, we alter the personal information collected from Users to render it anonymous so that it could no longer be personally identifiable. In the event of such anonymization of data, we shall have the right to retain such data for as long as we require and use such data without intimating you of such use and for any lawful purposes of whatsoever nature, whether mentioned in this Privacy Policy or not.

If you have created an account on Platform, your account information will be retained for as long as you maintain an active account. Your account will be deemed inactive, and your account information will be deleted after 3 (three) years of inactivity or such other period as we may determine. We will delete your personal data from our systems if we have not had any meaningful contact with you. We may preserve your data for such a longer period as we believe in good faith that the law or relevant regulators require us to preserve your data.

To the extent permitted or required by law, TagMango may delete your personal data at any time. As a result, you should retain your own copy of any information you submit to us.

Retention of your personal and sensitive data by a third party shall be governed by their privacy policies and TagMango is neither responsible nor could be held liable for any breach or non-compliance from such party’s part.

HOW IS YOUR PERSONAL INFORMATION SECURED

WHAT ARE YOUR RESPONSIBILITIES

You are responsible for the personal data that you provide or make available to TagMango, and you must ensure it is relevant, truthful, accurate and not misleading in any way. Please ensure that you do not suppress any material information while providing your personal data. You shall not impersonate another person while providing your personal data. Further, if you provide any personal data concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for TagMango to collect and use that information as described in this Privacy Policy. While we are taking all possible measures to secure your personal data in full compliance with the applicable laws, we too expect you to not register false or frivolous grievances or complaints against us.

WHAT ARE YOUR RIGHTS AND CHOICES

You have legal rights under the Data Protection Laws in relation to your personal data. For information about you collected by us or as otherwise required by law, you may request to exercise some or all of the following rights and choices regarding how we process your personal data.

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or take any action when we know we are dealing with the right person.

We will not charge you for any of these requests unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before we proceed with your request

We aim to respond to all valid requests within 30 (thirty) days. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than 30 (thirty) days. To speed up our response, we may ask you to provide more details about what you want to receive or are concerned about.

We may not always be able to do what you have asked, for example, if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

• Withdraw consent - You may request to withdraw the consent you have previously provided for theprocessing of your personal data by contacting us at privacy@tagmango.com.
• Erase/Delete personal data -You have the right to ask for your personal data to be deleted or erased. For example, you can exercise this right if you think that we no longer need your personal data for the purposes listed in this Privacy Policy. You can erase or delete all or some of your personal data on the Platform. If you have any questions about this process, you may contact us at privacy@tagmango.com. Please however note that we may have to retain certain personal data for complying with any applicable laws.
• Change or correct personal data - We strive to keep personal data about you correct, complete and up-to-date but if you notice that we are processing outdated or otherwise incorrect data about you, you always have the right to ask us to correct or update it. You can also edit your personal data on the Platform to keep them correct, complete and up-to-date. If you have any questions about this process, you may contact us at privacy@tagmango.com.
• Object to use of personal data - You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interests in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information. You can ask us to stop using all or some of your personal data by contacting us at privacy@tagmango.com.
• Restrict use of personal data - You have the right to ask us to restrict processing your personal data. This means that we will not do anything else with your personal data but continue storing it in our systems. You can ask us to stop using all or some of your personal data by contacting us at privacy@tagmango.com.
• Right to access and/or take your data - You have the right to know what personal data we process about you, to receive information about how we process it and to receive a copy or summary of this data. You can also obtain a copy of some of your personal data in machine readable form on the Platform. To request access to all of your personal data covered under this Privacy Policy, please contact privacy@tagmango.com. You also have a right to know with whom we have shared your personal data along with a description of the personal data so shared.
• Right to data portability- You have the right to ask us to send you – or someone else – a copy of the data you have provided to us in a commonly used machine-readable format. This right only applies to the personal data that you have provided to us when we have collected data based on your consent or on a contract that we have with you. This right does not apply to any personal data which we hold or process based on our legitimate interest or which is not held in digital form. Once we have validated your request, we will transfer your data to your designated destination.
• Right to nominate: You have a right to nominate any other individual of your choice, who, in the unfortunate event of your death or your inability to exercise your rights under this policy due to certain incapacity, will exercise your rights under this Privacy Policy.
• Right of grievance redressal & to lodge complaint - We hope that you would always contact us if you have any concern or questions about how we process personal data or your rights with respect to your personal data. However, if you think that we do not comply with the Data Protection Law when processing your personal data, you have the right to lodge a complaint with the concerned data protection authority.

CHILDREN'S AND MINOR'S PRIVACY

Certain portions of the Platform are accessible by young adults who are legally minors and may not be able to provide valid consent to our collection, use, disclosure, storage, or other handling of their personal information. Parents and guardians of children/minors are personally responsible for monitoring their child's/minor's access to, and use of, our Platform and the Services and for providing valid approvals for their child's/minor's access to the Platform and subscription to the Services provided by us. If you are under the age of 18 (eighteen) years, it is mandatory that your parent or guardian has read and accepted this Privacy Policy on your behalf, and it is assumed that you have ensured that the use of the Platform and the Services by you is under the guidance and control of your parents or guardian. If you are a child or young adult under the age of 18 (eighteen) years, you must ask your parent or legal guardian to approve your provision of personal information before you submit your personal details to us. If your parent or guardian has not read and agreed to this Privacy Policy, you will not have permission to use the Platform and the Services. We have the right to contact the parents ofany User as and when required in connection with the Services.

THIRD PARTY LINKS

The Platform includes buttons, tools, or content that link to other companies’ services, such as Facebook, X, Instagram, and LinkedIn. We may collect information about your use of these features. In addition, when you see or interact with these buttons, tools, or content, or view a web page on the Platform, some information from your browser may automatically be sent to the other company, in accordance with the terms and conditions of such other company.

UPDATES TO THE POLICY

This Privacy Policy on management and confidentiality of personal data may be periodically updated to reflect changes in our personal data confidentiality practices. In case of substantial changes, we will notify you with a clearly visible message on our Platform, indicating the date of the last update in the beginning of the Privacy Policy.

We ensure compliance with Applicable Laws by periodically updating this Privacy Policy. Hence, you are strongly advised to read this Privacy Policy carefully from time to time.

GRIEVANCE / DATA PROTECTION OFFICER—YOUR QUESTIONS ANDCOMMENTS

TagMango has appointed a Grievance/Data Protection Officer, as identified below. If you believe TagMango has used information about you in a way that is not consistent with this Privacy Policy or if you have questions or comments related to our privacy practices or other grievances, please contact the Grievance/Data Protection Officer.