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Privacy Policy

Last Updated: July 05, 2024

Welcome to Proximity! We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Notice including all schedules outlines how we collect, use, disclose, and safeguard your data when you visit our website or use our services. By using our services, you agree to the terms of this policy.

This is a contract between PROXIMITY LABS PRIVATE LIMITED having its registered office at HD-496, WeWork Enam Sambhav, C - 20, G Block Rd, G Block BKC, Bandra Kurla Complex, Bandra(East), Mumbai, Mumbai, Maharashtra, India, 400051 (“Proximity” or “We”, “we” or “Us”, “us” or “Our”, “our”) and you (“You”, “you” or “Your”, “your”), a User. "User/ “Users" shall mean any individual who visits, accesses, and registers on the Website or avails of our services on the Website. This describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you visit our website or engage in any other way.

And by Proximity Works Inc, a Delaware corporation having its registered office at 355, Bryant Street, Unit 403, San Francisco, CA 94107.

BY ACCESSING, USING, INSTALLING, OR DOWNLOADING THE WEBSITE, YOU ARE AGREEING TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AND TERMS OF USE OF THE WEBSITE THEN DO NOT USE THE WEBSITE.

Proximity is the owner and operator of the website https://proximity.studio/ (“Website”) whose purpose is to Improve education in India and bring in soft skill enhancement.

While we are covering the laws wherein, we operate hereinafter referred to as “Applicable Laws”, a specific Privacy Notice for CCPA/CPRA is attached as Schedule A to deal with the consumers in California.

COLLECTION OF INFORMATION

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us. Some of the categories of such data are as follows:

  • Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

  • Sensitive Information. We do not process sensitive information.

  • Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by the vendor. You may follow their privacy policies on their site.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Information collected from other sources

We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

To enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, email addresses, phone numbers, intent data (or user behavior data), and Internet Protocol (IP) addresses, for purposes of targeted advertising and event promotion. All such information is collected based on various legal bases as per the contracts or consents these platforms have with you and where we are provided with such legal basis.

A list of such Personal data elements is as below with their purposes:

We have collected the following personal data elements:

List of PD collected with Purpose

Sl. No.

Personal Data Element

Mandatory

Purpose

 

Contact Information

Y/N

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.

  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

  • For Employment purposes: We may process your data as you apply to us

  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is following your marketing preferences. You can opt out of our marketing emails at any time. This is detailed in the “INDIVIDUAL RIGHTS” section below.

  • To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

1

first and last name

Y/N

2

Salutation

Y/N

3

Address

Y/N

4

telephone number(s)

Y/N

5

email address

Y/N

6

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

 

7

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

 

LEGAL BASIS

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under Applicable Laws, like with your consent, to comply with Applicable Laws, to provide you with services to enter or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. Specific country provisions of some key principles and Legal Bases used are mentioned in Schedule B below.

Specific country provisions are mentioned in Schedule B below.

CONSENT WITHDRAWAL

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the “CONTACT US” section or by updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

OPT-OUT

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the CONTACT US section below. You will then be removed from the marketing lists — however, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out here. We have categorized our cookies into two

  • Essential Cookies – are those without which are necessary for the natural functioning of the site and without which the site will not move.

  • Non-Essential Cookies which are basically cookies that our third-party partners like Google Analytics collects for doing marketing and Analytics

You have a choice to select the cookies you seek to allow or disallow.

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at support@proximity.studio

DISCLOSURE OF PERSONAL INFORMATION

We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protecting the data they hold on to our behalf and to retain it for the period we instruct. We may share personal information with Government Entities. We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt-out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

THIRD-PARTY WEBSITES

We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services but are not affiliated with our Services. Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us, and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused using such third-party websites, services, or applications. The inclusion of a link to a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

STORAGE & CROSS BORDER TRANSFER

We may transfer, store, and process your information in countries other than your own following the mandates of the Applicable Laws. Our servers are located in multiple countries. Please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information as mentioned in the section above in our Servers. We will however keep to the principles of Applicable Laws as defined in the specific country provisions articulated in Schedule B.

If you are a resident in countries that may not necessarily have data protection laws or other similar laws as comprehensive as those in your country, however, we will take all necessary measures to protect your personal information through this privacy notice and Applicable Laws.

RETENTION PERIOD

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than what is required as per Applicable Laws.

When we have no ongoing legitimate business/interest/use/purpose need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

SECURITY

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Protecting your data is a top priority for us. We implement rigorous measures in line with applicable DPDPA, PDA, CCPA, PDPA, DIFC, DOPPA, and International Standards (iso, NIST, etc.), Internet laws, etc. to ensure the confidentiality and security of your information. Here’s how we safeguard your data:

  • Compliance and Standards: We adhere to all relevant data protection and security laws and regulations. This includes implementing measures that meet or exceed industry standards to protect your personal information.

  • Service Provider Obligations: We require our service providers to implement appropriate security measures to safeguard the confidentiality and security of your data when they handle it on our behalf.

  • Technical Measures: Depending on the sensitivity of the data and technological advancements, we deploy technical safeguards. These measures may include encryption, secure transmission methods, firewalls, and access controls to prevent unauthorized access, alteration, or disclosure of your data.

  • Organizational Measures: We have organizational controls in place, such as policies, procedures, and training programs, to ensure that our employees and partners understand their responsibilities in protecting your data.

  • Risk Prevention: We assess risks related to data processing activities and implement measures to mitigate these risks. This includes measures to prevent data loss, destruction, unauthorized access, or alteration.

  • Continuous Improvement: We regularly review and update our security measures to adapt to new security threats and technological advancements. This ensures that your data remains protected against evolving risks.

  • Cost Considerations: We balance the costs of implementing security measures with the importance of protecting your data. Our goal is to maintain a high level of security without compromising efficiency or accessibility.

  • Transparency and Communication: We are transparent about our data security practices and communicate any significant updates or breaches promptly, as required by law and following our commitment to your privacy.

MINORS DATA

We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at support@proximity.studio

INDIVIDUAL RIGHTS

In some regions, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. In some regions, you have certain rights under Applicable Laws. These may include the following rights:

  • to request access and obtain a copy of your personal information,

  • to request rectification or erasure.

  • to restrict the processing of your personal information.

  • if applicable, to data portability; and

  • not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information.

Based on the Applicable Laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, Please Contact our DPO by following the information given below in the “CONTACT US” section.

Specific country provisions are articulated in Schedule B.

NOTIFICATION OF BREACH

We are committed to promptly notifying you in the event of a data breach that may compromise your personal information. Here's how we handle such situations:

  • Notification Procedure: If we detect a breach of your personal data that poses a risk to your rights and freedoms, we will notify you without undue delay. This notification will include details of the nature of the breach, the categories of data affected, and our proposed actions to mitigate the breach.

  • Communication Channels: We will notify you using the most appropriate communication method available based on the information we have on file for you. This may include email, in-app notifications, or other means of contact.

  • Steps You Can Take: In the event of a data breach, we recommend that you take precautionary measures such as changing your password and reviewing your account for any suspicious activity.

  • Further Information: For more details on how we handle data breaches or to report any concerns, please refer to the "Contact Us" section of this policy.

We prioritize the security of your personal information and are committed to maintaining transparency and accountability in our data protection practices.

Specific country provisions are mentioned in Schedule B below as well as the Authorities whom to Notify for each country as applicable.

UPDATES TO NOTICE

We will update this notice as necessary to stay compliant with relevant Applicable Laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

CONTACT US

If you have questions or comments about this notice, you may contact our Data Protection Officer
Email: support@proximity.studio

GRIEVANCE REDRESSAL

We have a Grievance Redressal process. In case of any grievances, you can reach out to our Grievance Redressal Officer at support@proximity.studio

GOVERNING LAW AND JURISDICTION

This Privacy Policy is governed by the laws of India.  Any claim related to any dispute arising as a result of the Website or under this Privacy Policy will be made before a court of competent jurisdiction located in Bangalore.

ENTIRE AGREEMENT

This Privacy Policy and the Terms of Use of the Website constitute the entire agreement between You and Proximity and govern your use of the Website, superseding any prior agreements between You and Proximity.

IF YOU DO NOT AGREE WITH THE TERMS OF THE PRIVACY POLICY AND TERMS OF USE, PLEASE DO NOT ACCESS OR USE THE WEBSITE

SCHEDULE A

CPRA/CCPA Privacy Notice

This notice concerns the consumer data privacy regulations under the California Privacy Rights Acts(“CPRA”) and the California Consumer Privacy Act (“CCPA”). Some of the sections in the main Privacy Policy and Cookies policy would read into this Notice.

This notice applies only to California residents. Under the California Consumer Privacy Act (CCPA), the objective of this Notice is intended to provide all users of Proximity Tech who are California residents with the following notice concerning our use of your personal data and your rights listed below:

General Requirements

The basic requirements of maintaining personal data through its life cycle i.e. collection, processing, storing, transferring, and disposal are based on the explicit purposes mentioned in the Privacy policy and are specifically compatible with the purpose.

The California Code of Regulations defines a "resident" as:

  • every individual who is in the State of California for other than a temporary or transitory purpose and

  • every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

This privacy notice section for California residents supplements the information contained in this Notice and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information that need to be articulated if collected from California residents within the last twelve (12) months.

We have collected the following categories of personal information in the past twelve (12) months:

Category
Examples

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

B. Personal information as defined in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

I. Professional or employment-related information

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

J. Education information

Student records and directory information

We will use and retain the collected personal information as needed to provide the Services as prescribed in the applicable laws.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels.

  • Facilitation in the delivery of our Services and to respond to your inquiries.

Proximity Tech collects only the personal data that has been mentioned in the general Privacy Policy.

Sources

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from the forms you complete on our Service, preferences you express or provide through our Service, or from your purchases on our Service.

  • Automatically from you. For example, through cookies and usage data, we set on your device as you navigate through our Service.

  • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that we use to provide the service to you.

We use the personal data collected for the specified purpose only. We also retain only until there is a reasonable assumption that such retention no longer serves the express and limited purposes for which your personal data was collected, upon which the information will be securely deleted.

Under CCPA/CPRA, personal information does not include:

  • Publicly available information from government records

  • Deidentified or aggregated consumer information

  • Information excluded from the CPRA's scope, such as:

    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Your Rights under the CPRA/CCPA

The Act provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

The right to notice. You have the right to be notified about the following aspects of your personal data:

  • Categories Collected: You have the right to know which categories of personal data we collect about you. This could include information like contact details, purchase history, browsing activity, or any other data point falling under a specific category.

  • Purposes of Use: You have the right to understand the reasons why we collect and use your personal data. This could involve providing services, fulfilling transactions, personalizing your experience, or any other purpose outlined in our privacy policy.

The right to request. You have the right to request information about how we handle your personal data. Upon receiving and verifying your request, we will disclose the following details:

  • Categories of Personal Data Collected: We will disclose the types of personal data we collect about you. This could include information like name, address, email, purchase history, browsing activity, or any other data categorized according to applicable regulations.

  • Sources of Personal Data: We will identify the sources from which we obtain your personal data. This could be directly from you, through third-party providers, or from publicly available sources.

  • Purpose of Collection and Use: We will explain the business or commercial reasons for collecting and using your personal data. This could involve providing services, fulfilling transactions, personalizing your experience, or any other purpose outlined in our privacy policy.

  • Data Sharing:

    • Categories of Third-Party Recipients: We will identify the categories of third parties with whom we share your personal data.

    • Specific Data Disclosed: If requested, we can disclose the specific pieces of personal data we have collected about you.

  • Data Sales (if applicable):

    • Categories of Personal Information Sold: If we sell your personal data, we will disclose the categories of information involved.

    • Categories of Personal Information Disclosed: If we disclose your personal data for a business purpose, we will disclose the categories of information involved.

Proximity Tech must provide such disclosures to you in writing, by postal or electronic mail at your option, in a readily useable format that allows you to transmit the information from one entity to another without hindrance. Proximity tech may, at its discretion, require you to authenticate your identity and request before acting upon any request for disclosure.

California law (Shine the Light Law) gives you the right to request information about what personal information we might have shared with other companies for marketing purposes in the past year. You can also get a list of the companies we shared it with. This is free, and you can only request it once a year.

If you live in California and want to do this, contact us using the information below.

Right to Correct

You have the right to request that Proximity Tech rectify any inaccuracies in your personal data that we hold. Upon receiving and verifying your request, Proximity Tech will make commercially reasonable efforts to correct the identified inaccuracies following your instructions.

Please keep in mind that:

  • You have the right to request correction of your data.

  • We will verify your identity before processing your request.

  • We will make commercially reasonable efforts to correct the inaccuracies you identify.

  • The corrections will be made based on your instructions.

Sale of Personal Information

We clarify that our practices do not constitute a "sale of personal information" as defined by the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). This means we do not exchange your personal information for monetary or other valuable consideration. Additionally, we do not share your personal information for any commercial purposes.

Right to Opt-Out of Sharing (CCPA/CPRA)

Even if a future interpretation of CCPA/CPRA deems a specific process to be a "sale," you retain the right to instruct us to not share your personal information with third parties.

Right to Deletion of Personal Data

You have the right to request the deletion of your personal information, but certain legal and operational exceptions may apply. Upon receiving and verifying your request, we will erase your personal information from our systems and instruct our service providers to do the same, unless one or more of the following exceptions apply:

  • Contractual Necessity: We may retain your information to fulfil the terms of a transaction you initiated, provide a service you requested, or complete actions anticipated within the scope of our ongoing business relationship.

  • Security Purposes: We may retain your information for security reasons, such as detecting and preventing fraudulent activity.

  • Functionality Maintenance: We may retain your information to troubleshoot and fix problems that may be hindering the intended functionality of our services.

  • Legal Rights and Public Interest: We may retain your information to comply with legal obligations, exercise our right to free speech, or facilitate the free speech rights of others. This exception may also apply in limited cases of public interest research, but only with your prior informed consent and when deletion would significantly impede the research goals.

  • Internal Uses: We may retain your information for internal purposes that are compatible with the context in which you provided it and are aligned with reasonable consumer expectations based on our relationship.

  • Legal Compliance: We may retain your information to comply with mandatory legal requirements. Complying with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Other Lawful Uses: We may retain your information for other internal and lawful uses that are consistent with the way you provided it.

If any of these exceptions apply, we will provide a clear explanation for why we cannot fulfill your deletion request.

Right to Limit Use and Disclosure of Sensitive Personal Information.

We take your privacy seriously and avoid collecting or processing sensitive personal information whenever possible. This includes:

  • Social Security numbers

  • Driver's licenses and state IDs

  • Passport numbers

  • Login credentials for any account

  • Credit card numbers and financial information

  • Real-time location data

  • Information about your race, ethnicity, religion, union membership, or sexual orientation

  • The contents of your emails and texts (unless we're the intended recipient)

  • Genetic data, biometric data, and health data

If a business does collect any of this sensitive information, you have the right to limit their use of it. You can tell them to only use it for the specific reason they need it to provide their services. Once you tell them this, they cannot use or share your sensitive information for any other purpose unless you give them explicit permission.

Important Exceptions:

There are a few exceptions to this right:

  • If the information is used in a way that doesn't reveal anything personal about you (like anonymized data).

  • If the information is already publicly available.

Right to Access Information about Automated Decision-Making and Right to Opt-Out of Automated Decision-Making Technology

Under the CCPA/CPRA, We provide our consumers the right to understand how automated decision-making processes use their personal data. This includes:

  • Information on the existence of such technologies.

  • An explanation of the logic involved.

  • The potential impacts on their privacy and personal freedoms.

Right to Opt-Out of Automated Decision-Making Technology

Consumers also have the right to opt out of automated decision-making technologies that affect them. We:

  • Stop using such technologies for consumers who opt out.

  • Ensure future decisions involve human intervention.

You have the right to opt out of us selling or sharing your personal information with other businesses in the future. If you submit a request to opt out, we'll process it as soon as possible, but definitely within 15 days of receiving it.

Right of No Retaliation

The law prohibits us from discriminating against you for exercising any of your rights as a consumer under this policy. This includes, but is not limited to, the following actions:

  • Denial of Service or Goods: We cannot refuse to provide you with goods or services because you exercised your rights under this policy.

  • Price or Rate Discrimination: We cannot charge you a different price or rate for goods or services, nor can we deny you discounts or other benefits, or impose penalties, solely because you exercised your rights under this policy.

  • Quality of Service: We cannot provide you with a different level or quality of goods or services based on your exercise of rights under this policy.

  • Threats of Different Treatment: We cannot suggest that you will receive a different price, rate, or level of service based on your exercise of rights under this policy.

Use of Personal Information for Business Purposes

Using Your Information for Our Business

We might use your personal information for our own internal purposes, like developing and testing new technologies. This doesn't count as "selling" your information.

Sharing Your Information with Others

In the 12 months, we have shared certain categories of your personal information with other businesses for business-related reasons. We have detailed these categories of information:

  • Category A. Identifiers

  • Category B. Personal information, as defined in the California Customer Records law

  • Category C. Characteristics of protected classifications under state or federal law

  • Category D. Commercial information

  • Category E. Biometric information

  • Category F. Internet or other electronic network activity information

  • Category G. Geolocation data

  • Category H. Audio, electronic, visual, and similar information

  • Category I. Professional or employment-related information

  • Category J. Education information

  • Category K. Inferences drawn from collected personal information

  • Category L. Sensitive personal information

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

Right to request deletion of the data — Request to delete

You have the right to ask us to remove your personal information. We'll do our best to honor your request and you may contact us (refer to section “Contact us”) to exercise the rights stated above, but there might be some situations where we can't by law. For example, if someone else's right to free speech is involved, or if we're legally required to keep your information.

We're not required to give out or erase information that's been made anonymous (doesn't identify you).

Verification process

To make sure we're giving you the information you request about your data or any other right you practice (given above), we need to verify your identity. This helps us ensure we're only providing information about you, and not someone else.

Here's how we might verify your identity:

  • We might ask you to provide some information that matches what you've already given us.

  • We might contact you through a phone number or email address you've provided before.

  • We might use other methods depending on the situation.

The information you give us for verification will only be used to confirm it's you. We'll try our best not to ask for extra information, but if we can't verify you with what we already have, we might need some additional details. This extra information will only be used for verification and security purposes, and we'll delete it once we're done.

Other privacy rights

  • You may object to the processing of your personal information.

  • You can designate an authorized agent to request the CCPA on your behalf. We may deny a request from an authorized agent who does not submit proof that they have been validly authorized to act on your behalf by the CCPA.

Disclosure of Personal Information for Business Purposes

This section explains the types of personal information we might use or share with other businesses. It's based on a California law (CPRA) that defines these categories.

Important Note:

  • This list describes the categories of information, not every single piece of information within those categories:

    • Category A. Identifiers

    • Category B. Personal information, as defined in the California Customer Records law

    • Category C. Characteristics of protected classifications under state or federal law

    • Category D. Commercial information

    • Category E. Biometric information

    • Category F. Internet or other electronic network activity information

    • Category G. Geolocation data

    • Category H. Audio, electronic, visual, and similar information

    • Category I. Professional or employment-related information

    • Category J. Education information

    • Category K. Inferences drawn from collected personal information

    • Category L. Sensitive personal information

  • We believe, to the best of our knowledge, that we might have shared some information from these categories in the past year.

Keeping Your Information Safe:

Whenever we share your information with another business, we make sure they sign a contract. This contract requires them to:

  • Keep your information confidential.

  • Only use your information for the specific purpose outlined in the contract.

Sharing of Personal Information

We may share your personal information identified in the above categories with Government agencies or to fulfil legal obligations as and when required by applicable laws.

Financial Incentives

Financial Incentives and Your Data

The law allows us to offer financial incentives, price differences, or other benefits in exchange for your personal information. These incentives must be "reasonably related" to the value of your data.

What We Can Offer:

We may offer you financial incentives, such as price discounts or service upgrades, in exchange for you allowing us to retain, sell, or share your personal information.

Transparency Regarding Incentives:

If we offer a financial incentive, we will clearly explain:

  • The specific price difference or benefit you'll receive.

  • The key terms of the incentive program, including how long it lasts and what data is involved.

  • A good-faith estimate of the value we place on your data that justifies the incentive.

  • The method we used to calculate that value.

Your Choice and Opt-out:

You have the right to choose whether to participate in any financial incentive program we offer. You can opt-out at any time by contacting us through the following methods:

  • Email: support@proximity.studio

  • Phone: +919035144703

  • Contact details at the bottom of this document

Sale of Personal Information of Minors Under 16 Years of Age

Protecting Children's Privacy

We don't knowingly collect information from users under 16 on our website. However, some websites we link to might collect information from minors. It's important for parents and guardians to:

  • Monitor their children's internet use.

  • Teach their children not to share information on other websites without permission.

Selling Personal Information (California Residents Only)

We don't sell the personal information of anyone we know to be under 16. There might be exceptions in California if:

  • A teen (13-16 years old) gives us explicit permission.

  • A parent or guardian gives permission for a child under 13.

Even if you allow us to sell your information, you can change your mind later and opt out. Just contact us to request this.

Removing a Child's Information

If you believe a child under 13 (or 16 depending on your location) has given us information, please contact us with details so we can delete it.

Transferring Your Information (California Residents Only)

If you request to download your personal information (data portability), we'll provide it in a format that's easy to use and transfer to another service.

Notification of Breach

At Proximity Tech, the security of your personal information is of utmost importance to us. In the unfortunate event of a data breach involving your personal information, we have established procedures to ensure you are promptly informed and provided with the necessary steps to protect yourself.

What Constitutes a Data Breach

A data breach occurs when there is unauthorized access to or disclosure of personal information that compromises the security, confidentiality, or integrity of that information. This can include incidents such as hacking, unauthorized access by insiders, loss or theft of data storage devices, and accidental sharing of personal information.

Notification Process

In the event of a data breach, Proximity Tech will take the following steps to notify affected individuals:

  • Assessment and Containment:

    • We will promptly assess the scope and impact of the breach.

    • Measures will be taken to contain the breach and prevent further unauthorized access.

  • Investigation:

    • A thorough investigation will be conducted to determine the cause of the breach and the extent of the compromised data.

  • Notification to Affected consumers:

    • Timing: Notification will be made as soon as reasonably practicable, considering the need to verify the breach and restore data integrity.

    • Method: Notifications may be made via email, postal mail, telephone, or other direct communication channels.

    • Content: The notification will include:

      • A description of the incident and the type of information involved.

      • The steps we have taken to address the breach.

      • Recommendations for individuals to protect themselves, such as monitoring their accounts and changing passwords.

      • Contact information for our support team to assist with any questions or concerns.

  • Notification to Authorities:

    • We will notify relevant regulatory authorities as required by law, including the California Attorney General’s Office if the breach affects a significant number of California residents.

Contact Us

Thank you for visiting Proximity Tech. We value your feedback and are here to assist you with any inquiries, concerns, or issues regarding our services and products. To exercise any rights stated above you contact us.

How to Contact Us

You can reach us through the following channels:

  • Email: support@proximity.studio

  • Phone: +919035144703

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