Privacy Policy

Pooja Jhunjhunwala & Associates (PJA) is the author and publisher of the internet resource www.poojajassociates.com (“Website”) on the World Wide Web.

This policy ("Privacy Policy") explains how we collect, use, disclose and protect Personal information about the Users of the Services. We have created this Privacy Policy to demonstrate our commitment to the protection of your privacy and your personal information. This privacy policy applies to anyone who interacts with us in relation to our services via any channel (e.g. website, email, phone, messages, etc.). Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use.

BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IN CASE YOU DO NOT AGREE TO OUR POLICY, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION AND IMMEDIATELY CEASE USING OUR WEBSITE.

In this Privacy Policy, the below terms, words and expressions shall have the following meanings:

"We", "Us", "Our" shall mean "Pooja Jhunjhunwala & Associates (PJA)"

"You", "Your" or "User" means any natural or legal person who uses the Website for availing services offered by the Website ("Services").

"Services" means any services offered by PJA.

"Policy" refers to this Privacy Policy".

"Website" refers to this webpage (www.poojajassociates.com) or any other digital medium and other offline sources.

This Privacy Policy is published in compliance with, inter alia:

• Section 43A of the Information Technology Act, 2000;
• Regulation 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (the “SPI Rules”);
• Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.

This Privacy Policy covers: (i) the type of information collected from the users through the Website including sensitive personal data or information; (ii) the purpose, means and modes of usage of such information; and (iii) How and to whom PJA will disclose such information

Generally some of the Services require us to know who you are so that we can best meet your needs. When you access the Services or through any interaction with us via registration, emails, telephone calls or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. You hereby consent to the collection of such information by PJA. Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:

• contact data (such as your email address and phone number etc);
• demographic data (such as your gender, your date of birth and your pin code etc);
• data regarding your usage of the services and history of the appointments made by or with you through the use of Services;
• other information that you voluntarily choose to provide to us (such as information shared by you with us through emails or letters).

The information collected from you by PJA may constitute 'personal information' under the SPI Rules.

For the purpose of this Privacy Policy, “Personal Information” as defined under Section 2(i) of the SPI Rules means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person.

We may also collect personal information from third parties such as regulatory authorities, your employer, other organizations you are associated with, government agencies, credit reporting agencies, information or service providers and social media platforms. Any unsolicited information shall be treated as stipulated by law, including destroying or de-identifying such information as the law prescribes.

3.1 Our primary goal in collecting your information is to provide you with an enhanced experience when using the Services.

3.2 We may use the information obtained from you to prevent, discover and investigate violations of this Privacy Policy or any applicable terms of service.

3.3 In addition, we may use your Protected Information or Usage Information for the following purposes, including but not limited to:

• Personal identification and authentication purposes;
• To provide apt responses to your enquiries and requests;
• Providing our service to you and upgrading the same based on your needs;
• Maintaining and updating your records;
• For research, planning, service development, security or risk management;
• Ensure compliance with the regulatory framework;
• Improve our service delivery;
• To perform administrative and maintenance functions related to our services; and
• Sending you reminders, notices, updates, support and administrative messages, service bulletins, updates about our firm, and any other requested information.

4.1 The security of your information is our priority. We take all necessary precautions to protect your personal information and have adopted reasonable security practices and measures to ensure that the information we collect is secure.

4.2 Your Personal Information is maintained by PJA in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time, if required.

4.3 We may provide links to websites for the convenience and information of users. These websites may not be owned, controlled, or operated by us. In those cases, we cannot control how information collected by those websites will be used, shared, or secured. If the user visits linked sites, we strongly recommend that the user reviews the privacy notices or policies posted at those sites. We are not responsible for the content of linked sites, the user's use of them, or the information practices of their operators.

4.4 PJA makes all User information accessible to its employees, agents or partners only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.

4.5 Notwithstanding the above, PJA is not responsible for the confidentiality, security or distribution of your Personal Information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, PJA shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of PJA including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.

4.6 Although we will endeavour to safeguard the confidentiality of your information, transmissions made by means of the Internet cannot be made absolutely secure. No such measures are competent enough to prevent all potential security breaches. We in no way are to be held responsible for the unauthorized use of your information. By using our services, you agree that we will have no liability for disclosure of your information due to errors in transmission or unauthorized acts of third parties.

5.1 We may disclose your information to the following third parties :

• Our agents, service providers, and advisors;
• Our partners;
• Other users of our services; and
• Regulatory bodies, government agencies, law enforcement bodies and courts etc;

5.2 We reserve the right to access, monitor, use or disclose any personal information or communications as required by law and when we believe, at our sole discretion that disclosure is necessary to protect our or others' rights, comply with the law, enforce our policies, or respond to lawful requests, protect someone from injury and/or to comply with a judicial proceeding, court order, or legal process.

5.3 We do not Anonymise and share personal information for commercial purposes such as identification of latest data trends and advertising.

6.1 The Website uses temporary cookies, which are files that your web browser puts on your system when you visit a website, to store certain information that is not sensitive personal data or information. The information collected through these cookies is used by us for the technical administration of the Website and to improve the quality of our services. We may also use trusted third-party services that track this information on our behalf.

6.2 By using our site or allowing your browser to “accept cookies”, you consent to use of cookies with respect to your device. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Platform.

6.3 We may use third party cookies to track visitor behaviour and to improve the quality of our services. However, such cookies will not store any kind of personal information, nor will such information be disclosed to any third party.

6.4 These cookies are intended to be automatically cleared or deleted when the User quits the browser application. You are encouraged to use the “clear cookies” functionality of your browser to ensure such clearing / deletion, since it is impossible for us to guarantee, predict or provide for the behaviour of your system.

6.5 Please note that third parties' affiliates may also use cookies, over which we have no control.

6.6 The information we collect with cookies is not sold, rented, or shared with any third parties.

6.7 Due to the communications standards on the Internet, when a User or the End-User or anyone who visits the Website, PJA automatically receives the URL of the site from which anyone visits. PJA also receives the Internet Protocol (IP) address of each User's computer (or the proxy server a User used to access the World Wide Web), User's computer operating system and type of web browser the User is using, email patterns, phone numbers as well as the name of User's ISP. This information is used to analyze overall trends to help PJA improve its Service. The linkage between User's IP address and User's personally identifiable information is not shared with or disclosed to third parties.

You unconditionally agree that becoming a User of the Website and its Services signifies your

• assent to this Privacy Policy, and
• consent to PJA using, collecting, processing and/or disclosing your Personal Information in the manner and for the purposes set out in this Privacy Policy. Your visit to the Website and use of the Services is subject to this Privacy Policy and the Terms and Conditions.

If You Use the Services On Behalf Of Someone Else or an Entity (Such As Your Employer), You Represent That You Are Authorised By Such Individual Or Entity To (I) Accept This Privacy Policy On Such Individual's Or Entity's Behalf, And (Ii) Consent On Behalf Of Such Individual Or Entity To Our Collection, Use And Disclosure Of Such Individual's Or Entity's Information As Described In This Privacy Policy.

8.1 PJA has the sole discretion to change, modify, add or delete portions of the terms of this privacy policy at any time, with or without prior Notice. We will post the new privacy policy on the website and update the "Last updated" date at the top of this page. We will display a notice on the Website, or notify the Users through an email, in case of any change/update, so that you may review the changed terms prior to continuing to use the Services.

8.2 If a User uses the Services or accesses the Website after a notice of changes has been sent to such User or published on the Website, such User hereby provides his/her/its consent to the changed terms.

9.1 We will retain your personal information/data for as long as it is necessary for the purposes for which we collect or process them, unless otherwise required for the purposes of fulfilling any legal obligation.

9.2 You may request us to update, amend, correct, complete or delete your Personal information retained by us through email.

9.3 We may also retain your Personal Data where necessary for compliance with a legal obligation applicable to Pooja Jhunjhunwala & Associates, or in order to protect your interests.

The Privacy Policy shall be governed by and constructed in accordance with the applicable laws of India without reference to conflict of laws principles. Courts in Hyderabad, Telangana shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, this Privacy Policy.