Privacy Policy

Last updated on: 11th Nov, 2022

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We value your trust. In order to honor that trust, 5olve Dot Pvt Ltd (which shall also include a reference to our affiliates, sister concerns etc.) has outlined below its privacy policy to fulfil its obligations under the applicable privacy laws.

Throughout this document, the terms “we”, “us”, “our”, “ours” and “Brent” refer to 5olve Dot Pvt Ltd and the terms “you”, “your”, and “yours” refer to You (as the User of the Platform).

This Privacy Policy details how we collect, store and/or use information or data provided by you while accessing and/or using our Platform and any service offered on or through Brent and our related websites, services, applications and products (hereinafter referred to as “Services”). We'll only ever collect, use and share your information in ways that are described in this policy.

Along with our Terms of Service, this policy explains how we collect and handle your information across all of our websites, mobile apps and other services. We'll review this policy from time to time to make sure it's up-to-date. If we make changes, we'll post the latest version here. We process any personal information we collect from you in accordance with the applicable laws and regulations.This Privacy Policy is required to be read in conjunction with the Terms & Conditions. Your access to and use of our Platform and the Services is conditional upon your acceptance of this Privacy Policy and the Terms & Conditions. By accessing and/or using our Platform and/or the Services, you represent that you have read, understood and are bound by the Terms & Conditions and this Privacy Policy, and that you consent to your information and data including personal information being collected, stored and used in the manner laid out in this Privacy Policy. If you do not agree to the Privacy Policy, promptly exit the page and stop accessing our Platform and/or our Services.

1. Collection of Information

‘Personal Information’ or ‘PI’ means any information that identifies (whether directly or indirectly) to a particular individual or natural person, such as the individual’s name, postal address, email address, and mobile number indicating to that particular person or such person is identifiable.

When you apply for the Services of Brent, we require the following information from you (hereinafter referred to as “Your Information”):

●  Name

●  Age

●  Address

●  Email id

●  Phone number

●  We may utilize “cookies” and other tracking technologies. A “cookie” is a small text file that
may be used, for example, to collect information about activity on the website. Some cookies and other technologies may serve to recall information previously indicated or submitted by a user. Most browsers/mobile settings allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers/mobile applications to notify you if you receive a cookie, or you may choose to block cookies with your browser/ mobile applications. Cookies enable us to personalize your viewing experience. When you revisit our website, we can recognise you by the cookie and customize your experience at this website accordingly. For example, we use cookies to recognise your access privileges to this website, track website usage and traffic patterns, identify you and keep track of your preferences, prevent fraudulent activity or improve website security, assess the performance of the website, add advertisements for goods or services of interest, and estimate the website’s audience size. You can find out more about the cookies we may use from each of the categories below:

▪  Strictly necessary: These are used for the purpose of security and help us detect, prevent, and mitigate malicious and fraudulent activities on our Services. Security cookies also support and enable other security features.

▪  Functional: These are used for the purpose of

▪  Analytics and Research - We use some cookies to collect information

about how people are using our Services. For example, these cookies allow us to know which pages are visited the most often, our site’s page load times and page response times. Overall, these cookies provide us with analytical information about how our Services are performing and how we can improve them.

Tracking technologies may record information such as internet domain and host names, internet protocol (IP) addresses, details of the device you used to access our website, browser, software and operating system types, stream patterns, and dates and times that our website is accessed. Our use of cookies and other tracking technologies allows us to improve our website and your experience.

We may automatically collect the following types of information as you use our services.

• Usage Information: which pages on our website you access, the frequency of access, what you click on while on our website and when you accessed our website. 

• Location Information: Information about your location, which may be determined through your IP address, GPS and other sensors that may reveal information on nearby devices, Wi-Fi access points and cell towers. 

• Device Information: Information about the device you are using, such as hardware model, operating system, application version number, browser, and IP addresses. 

• Mobile Device Information: This includes mobile network information, such as the unique device identifier assigned to that device, mobile carrier, operating system, telephone number and other device attributes. 

We may also collect some other information and documents including but not limited to:

• Transactional history (other than banking details) about your e-commerce activities, buying behavior.

• Your usernames, passwords, email addresses and other security-related information used by you in relation to our Services.

• Data either created by you or by a third party and which you wish to store on our servers such as image files, documents etc.

• Data available in public domain or received from any third party including social media channels, including but not limited to personal or non-personal information from your linked social media channels (like name, email address, friend list, profile pictures or any other information that is permitted to be received as per your account settings) as a part of your account information.
   

Information provided through feedback, surveys, suggestions, etc., without the parts that identify you is considered non-confidential and non-proprietary. We may use and share such information on an anonymous and aggregated basis with third parties.

At all times, you may refuse all cookies on your browser. However, by doing so, you may not be able to use certain features on the website.

Usage Information: which pages on our website you access, the frequency of access, what you click on while on our website and when you accessed our website.

Location Information: Information about your location, which may be determined through your IP address, GPS and other sensors that may reveal information on nearby devices, Wi-Fi access points and cell towers.

Device Information: Information about the device you are using, such as hardware model, operating system, application version number, browser, and IP addresses.

Mobile Device Information: This includes mobile network information, such as the unique device identifier assigned to that device, mobile carrier, operating system, telephone number and other device attributes.

Transactional history (other than banking details) about your e-commerce activities, buying behavior.

Your usernames, passwords, email addresses and other security-related information used by you in relation to our Services.

Data either created by you or by a third party and which you wish to store on our servers such as image files, documents etc.

Data available in public domain or received from any third party including social media channels, including but not limited to personal or non-personal information from your linked social media channels (like name, email address, friend list, profile pictures or any other information that is permitted to be received as per your account settings) as a part of your account information.

It is clarified that as per the Terms & Conditions, the above information is intended to be provided only by those who are legally competent, as per applicable laws, to enter into a contract and give consent for their personal information to be collected.
 

2. Use of Information

Brent shall use Your Information collected in accordance with Clause 1 of the Privacy Policy for the following purposes:

      a)  To provide our products and Services to you and all acts incidental to the same

      b)  Operating and/or improving our Platform and our products and Services and all acts incidental to the same

      c)  To communicate with you regarding existing product and Services availed by you including notifications, alerts,

           updates or surveys

      d)  To send you information about other product and Services which may be of interest to you (you may always opt out
           of such communication by informing us in writing that you are not interested in receiving such communications)
      e)  To handle enquiries and complaints

      f)  To comply with legal and regulatory requirements and to protect our legal rights

      g)  To investigate, prevent, or take action regarding unlawful activities, suspected fraud and
           situations involving potential threats to the safety of any person

       h)  To debug errors in our Platform and/or Services

       i)  To aggregate your information in order to gain insight into our Services. These aggregated databases of anonymised data allows us to generate helpful insights into patterns or trends with the rental industry. This information is also useful for book sellers as it enables them to identify new books or categories that are in demand and ensure they are selling them at competitive rates. For example, we can use search data to monitor demand for books and make sure that the fares that our users surface are legitimate.

Such information shall be strictly used for the aforesaid specified & lawful purpose only. We will always redact all/any sensitive & confidential information submitted for the purpose of availing a service, promotional offer or booking a product on the Website/App. In case you do not wish to provide this information or opt for deletion of the information already provided, we may not be able to process the desired request. We will never share any of the above information collected without their prior consent unless otherwise such action is required by any law enforcement authority for investigation, by court order or in reference to any legal process.

In our processing of your information, we also share your personal information to defend our rights and the rights of others, to efficiently maintain our business, and to comply with the law.
 

3. Storage of Information

Brent shall store Your Information collected in accordance with Clause 1 of the Privacy Policy for the duration necessary to fulfil the purposes described in Clause 2.

The collecting agency in respect of Your Information is AWS.
 

4. Consent

By accessing and/or using our Platform and/or the Services, you represent that you have read, understood and are bound by the Terms & Conditions and this Privacy Policy, and that you consent to Your information and data being collected, stored and used in the manner laid out in this Privacy Policy. We will request your permission to use or share your personal information for a specific purpose that is not compatible with the purposes listed in Clause 5. We will notify you and request for consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. With you consent, we may also share your quotes and

reviews for promotional purposes. If we rely on your consent to use or share your information, your consent may be revoked at any time by contacting us at brentcollaborator@brent.com.
 

5. How We Share Information

We share your information with our service providers, among our entities, in connection with a corporate restructuring, to prevent harm, to comply with the law, for marketing and advertisement purposes, and to protect our legal rights. The legal basis for this is our legitimate interest in providing our Services, complying with the law, and protecting our rights and those of others. We apply appropriate safeguards for this sharing of your information as described below and in Clause 6, 7, 8, 9 and 10.

We share information

• With service providers that help us perform application functions and process your transactions. 

• If we are involved or intend to be involved in a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or in connection with bankruptcy or liquidation proceedings. 

• If we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud or situations involving potential threats to the rights, property, or personal safety of any person. 

• where we are legally required to do so, such as in response to court orders or legal process, to exercise our legal rights, to defend against legal claims or demands, or to comply with the requirements of any mandatory applicable law. 

• to enforce the terms of this Notice, the Services Terms of Use and any other terms that you have agreed to, including to protect the rights, property or safety of Brent, its users, or any other person, or the copyright-protected content of the Services. 

• With our data processors who provide storage and other related services to you on our behalf such as cloud service providers, payment gateways, customer service providers, survey distributors or any other third-party for the purposes of prevention, detection mitigation, and investigation of fraudulent or illegal activities related to our Services or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security, compliance with our legal obligations, enforcement of our user agreement, facilitate our marketing and advertising activities. 

• With outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality. 

• with our group companies or affiliates who need to know or have access to such information in relation to provisioning of Services.

We adhere to appropriate security measures to protect your personal information while we share with them for processing. Further, wherever applicable, we bind these third parties with appropriate agreements and require them to process your personal information only for specific purposes along with confidentiality and with appropriate security measures. When you use a co-branded service (a service operated with a partner of Brent), or register or otherwise provide information on a co-branded site, you grant us permission to pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services. We may share your information with our partners such as your name, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine user information about you received from Brent with information about you from other sites or services; and (iii) place or recognise a unique cookie on your browser.
 

6. Your rights

You have the following rights with respect to Your Information as collected by us:

With service providers that help us perform application functions and process your transactions.

If we are involved or intend to be involved in a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or in connection with bankruptcy or liquidation proceedings.

If we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud or situations involving potential threats to the rights, property, or personal safety of any person.

where we are legally required to do so, such as in response to court orders or legal process, to exercise our legal rights, to defend against legal claims or demands, or to comply with the requirements of any mandatory applicable law.

to enforce the terms of this Notice, the Services Terms of Use and any other terms that you have agreed to, including to protect the rights, property or safety of Brent, its users, or any other person, or the copyright-protected content of the Services.

With our data processors who provide storage and other related services to you on our behalf such as cloud service providers, payment gateways, customer service providers, survey distributors or any other third-party for the purposes of prevention, detection mitigation, and investigation of fraudulent or illegal activities related to our Services or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security, compliance with our legal obligations, enforcement of our user agreement, facilitate our marketing and advertising activities.

With outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality.

with our group companies or affiliates who need to know or have access to such information in relation to provisioning of Services.

• Right to obtain confirmation on the processing of Your Information, request access to or review of your Personal Information, as well as the correction, completion, revision and erasure of Your Information. Even if you terminate your account, keep in mind that deletion of your personal information by our third-party providers may not be immediate and that deleted personal information may persist in backup copies for a reasonable period of time and as required by applicable laws and regulations;

• Right to withdraw consent for the subsequent processing or use of your Personal Information; and

• Right to receive Your Information in a structured, commonly used and machine-readable format, as well as the right to transmit such information to another entity, if we have collected such information with your consent and processed it by automated means.

• You may choose to withdraw your consent for the subsequent use of your Personal Information, by contacting us via email at brentcollaborator@brent.com. We will provide you with further assistance in this regard and guide you through the process. We reserve the right to seek further details from you in order to ascertain the exact nature of the withdrawal of consent. Withdrawal of consent shall not be treated as effective unless the communication is made to the email id given above. Once you choose to withdraw consent for subsequent use of your personal data by Brent, you will not be able to avail our products and Services or retrieve any of the content you have may have shared with us.

If you contact us for any of the aforesaid reasons, we may keep a record of that correspondence for our internal reference and archival purposes. We will not retain a record of that correspondence for longer than is reasonably necessary.
 

7. How Long We Keep Your Information

We retain personal information until the later of (i) the information is no longer necessary to accomplish the purpose for which it was provided, (ii) there is no ongoing business reason to keep the information, or (iii) until you request that your account be deleted.

We retain your information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. More specifically we would retain some data for longer periods of time for the following reasons:

• Security, fraud and abuse prevention – to protect you, other people, and us from fraud, abuse and unauthorised access. 

• Financial record-keeping – when you make a payment to us, we are often required to retain this information for long periods of time for the purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations

• Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process or enforceable governmental request as required to enforce our terms of service, including investigation of potential violations. 

• Direct communications with us – if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications. 
   

8. Disclosure and Transfer of Information

Security, fraud and abuse prevention – to protect you, other people, and us from fraud, abuse and unauthorized access.

Financial record-keeping – when you make a payment to us, we are often required to retain this information for long periods of time for the purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations

Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process or enforceable governmental request as required to enforce our terms of service, including investigation of potential violations.

Direct communications with us – if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.

The disclosure and/or transfer of Your Information is limited for the purposes as described in Clause 2. You consent to us sharing your information with third-parties and our partners for the limited purpose as identified in Clause 2. The third-parties and our partners are not permitted to do anything with Your Information which is outside the scope of Brent Services. However, Brent will not be responsible for any misuse of Your Information by such third-parties and partners. Brent does not sell or rent Your Information to any third party. Brent also does not disclose or transfer Your Information to any other third parties without your consent, unless such disclosure or transfer is:

1. Required in order to comply with any applicable law or court order or direction; or

2. Requested by any appropriate Governmental agency or authority as per applicable law for the purpose of, inter alia, verification of identity, prevention, detection, investigation,
   prosecution or punishment of any offenses or incidents.

3. Required to enforce or protect our rights or properties or any or all of our affiliates,
   associates, employees, directors or officers or when we have reason to believe that disclosing your Personal Information is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

Sometimes the countries that your data is transferred to, or stored in, may have different, or less stringent, data protection and security standards than your own. However, subject to the local laws in these countries, we'll provide the safeguards needed to protect your data regardless of location. We do this through a combination of appropriate technical, organizational and administrative security measures, and by putting in place the necessary legal contracts to back up these requirements.
 

9. Security

Brent complies with reasonable security practices and procedures as required by the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. However, since complete security cannot be ensured by any entity, please note that Brent does not guarantee the security of Your Information. In the event that Brent becomes aware of any breach of security such that it affects Your Information, Brent shall notify you using commercially reasonable efforts. However, as detailed in Clause 10 of this Privacy Policy, you should look at this Privacy Policy regularly to check for such changes.

Brent claims no responsibility for the security of any third-party links, websites or resources that you may access through or in connection with our Platform and/or the Services.
 

10. Third Party Websites and Applications

Our Services may include and link to features and services (such as social applications like Google, Facebook, YouTube, WhatsApp, Instagram, Twitter and payment gateways) that are provided by a third party. If you use these features and services, please understand that the third parties that operate them may collect information from you which will be used in accordance with their own privacy policy and terms of use, which may differ from ours.

We share information relating to our users with selected third parties who provide us with a variety of different services that support the delivery of our services. These third party processors range from providers of technical infrastructure to customer service and authentication tools. We require any third party processor which handles information on our behalf to do so pursuant to contractual terms which require that the information is kept secure, is processed in accordance with applicable data protection laws, and used only as we have instructed and not for the third party processor’s own purposes (unless you have explicitly consented to them doing so).

The types of third party processors we may share elements of your personal data with include:

• Payment processors engaged by us to securely store or handle payments information, such as credit or debit card details, required for facilitating booking with travel suppliers - for example, when you provide us with your credit or debit card details, we store these in a PCI-compliant data vault provided by an industry-leading third party payment processor;

• Providers of security and fraud prevention services – for example, we use these providers to identify automated software agents that might disrupt our services or to prevent misuse of our APIs;

• Providers of data aggregation and analytics software services that enable us to effectively monitor and optimize the delivery of our services;

• Providers of software platforms that assist us in communicating or providing customer support services to you – for example, we manage and respond to any messages you send us via our help center using a third party communications management tool;

• Providers of online cloud storage services and other essential IT support services. 

Payment processors engaged by us to securely store or handle payments information, such as credit or debit card details, required for facilitating booking with travel suppliers - for

example, when you provide us with your credit or debit card details, we store these in a PCI- compliant data vault provided by an industry-leading third party payment processor; Providers of security and fraud prevention services – for example, we use these providers to identify automated software agents that might disrupt our services or to prevent misuse of our APIs;

Providers of data aggregation and analytics software services that enable us to effectively monitor and optimize the delivery of our services;

Providers of software platforms that assist us in communicating or providing customer support services to you – for example, we manage and respond to any messages you send us via our help center using a third party communications management tool;

Providers of online cloud storage services and other essential IT support services.

In order to prevent and detect fraud, we may share information about you with the fraud prevention services providers we cooperate with ("Fraud Prevention Providers").

We will share personal data with third parties where you expressly authorise us to, such as where we run a promotion in conjunction with a partner and you instruct us to share your email address with that third party for the purpose of receiving promotional emails.

We may share and/or make available your publicly accessible personal data such as your name, profile picture, reviews, book photos to carefully selected third parties with whom we have a contractual relationship

We do not accept any responsibility or liability for or endorse these third party policies or for any personal data that may be collected by or through these websites or services. You should always read the privacy policy of any feature or service you access carefully in order to understand the specific privacy and information usage practices.
 

11. Changes to the Privacy Policy

We retain the right to amend this Privacy Policy from time to time, for instance when we update the functionality of our Services or when there are regulatory changes. We will use commercially reasonable efforts to generally notify all users of any material changes to this Privacy Policy, such as through a notice on our website/application. However, as a user of our Platform and/or the Services, you should look at this Privacy Policy regularly to check for such changes. We will also update the “Last Updated” date at the top of this Privacy Policy, which reflects the effective date of this Privacy Policy. Your continued access or use of our Platform and/or the Services after the date of the new Privacy Policy constitutes your acceptance of the new Privacy Policy. If you do not agree to the new Privacy Policy, you must stop accessing and/or using our Platform and/or the Services. You hereby acknowledge that any collection, storage, processing, sharing or other use of Your Information shall be governed by the Privacy Policy as applicable at the time of such collection, storage, processing or other use.
 

12. Use of Child Information

Our platform is only available to persons who can form a legally binding contract under the Indian Contract Act, 1872. We do not knowingly solicit or collect personal information from children under the age of 18 years. If you have shared any personal information of children under the age of 18 years, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. Any action or activity undertaken by children below the age of 18 years on our Platform and/or while using our Services shall be deemed to have been taken with the consent and authorisation of their parent and/or legal guardian and the parent and/or legal guardian shall be fully responsible for the same. If you are a parent or legal guardian agreeing to the Terms & Conditions & Privacy Policy for the benefit of your child who is below 18 years of age, be advised that you are fully responsible for his/her use of our Platform and/or use of our Services, including all financial charges and legal liability that he/she may incur.