PRIVACY POLICY

Last updated as on October 16, 2022

This Privacy Statement describes and governs how Urbanic Step Marketing Private Limited and includes its employees, agents, partners, associates, affiliates and representatives (collectively, “Justdun,” “we,” and “us”) collect, access, use, disclose, transfer, store, retain or otherwise process your information when you as user or vendor (collectively, “User”), sign up or sign in for an account and uses a feature of Justdun’s website or mobile application (collectively, “Platform”). Please read this page carefully. Your continual interaction and use our platform directly or indirectly, infers your implied consent to the practices, guidelines and supplementary policies described on this page (collectively, “Privacy Policy”, “Privacy Statement”).

Information You Provide

We use the information you input onto Justdun’s platform when you create, register or use a Justdun account or feature. This information includes data in relation to or arising on account of your identifications, transactions, communications, and any other means of interactions.

We collect information you provide for the purposes of:

• Signing up or signing in to Justdun’s personal or business account

• Browsing, scraping, crawling, accessing or availing any feature, product or services on the platform

• Identification, authentication, communication or verification process, or other interactions Specifically, we deal with the following categories of information:

• Financial and Transactional information: Information which relates to parties, bank account, descriptions, billing, shipping, and payment methods.

• Voluntary and Supplementary information: Information which that you willingly and additionally provide during your responses and interactions with us which includes reviews, ratings, survey responses, contests, promotions, referrals, suggestions, improvements, or any other actions you perform

• Activity information: Information about how you use and interact with our platform, including your access time, “log-in” and “log-out” information, browser type and language, the domain name of your internet service provider, other attributes about your browser, any specific page you visit on our platform, content you view, features you use, the date and time of your use of the Platform, your search terms, and the website you visited before you visited or used the Platform;

• Online identifiers?(e.g., information you use to log in to your account), Internet Protocol (“IP”) address, and unique personal identifiers (including device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; user number; unique alias, and other identifiers);

• Professional or employment-related information, such as information you provide about your business (e.g., appointments, staffing availability, and contact data) and your employees (e.g., job titles, payroll information, and hours worked and other timecard data);

• Inferences?drawn from any of the information above to create a profile about you that may reflect, for example, your preferences, characteristics, and behaviour, including for account security purposes or to enhance our Platform to you.

• Identification Information, such as:

• Name, email address, postal address, signature, and phone number;

• Driver’s license number, Social Security number, Taxpayer Identification number, or other government-issued identification number;

Information We Collect

We use your information to develop and insure Justdun ’s products and services work better for you and for others. This describes what data we collect about you (which can vary depending on jurisdiction). We also obtain information about your users on your behalf when they transact with you. We call this information?Your Users’ Data. We collect Your Users’ Data when they transact with you through your use of Justdun ’s products, for instance when they make a payment at your establishment, or schedule an appointment, or receive an invoice from you. The Customer Data we collect will vary depending on how you use our products and services and which products and services you use. Your Users’ Data may include:

• Device Information. Information about Your Customer’s device, including hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Platform.

• Financial Information. Bank account and payment card numbers.

• Identification Information. Your users’ name; email address; mailing address; phone number; government-issued identification; or other historical, contact, and demographic information, and signature.

• Location Information. The location of Your Customer’s device depending on how they pay.

• Transaction Information. When Your Users use Justdun to make or record payments to you, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions which may include item-level data, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.

• Use Information. Information about how Your Users transact with you using our Platform, including access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, IP address, the domain name of Your Customer’s Internet service provider, other attributes about Your Customer’s browser, mobile device and operating system, features Your Customer uses, and the date and time of use of the Platform.

• Other Information You or Your Users Provide. Information that Your Users voluntarily provide you, or that you input into Justdun ’s systems about your Users. For example, survey responses; participation in contests, promotions, or other prospective seller marketing forms or devices; suggestions for improvements; notes you take about your users, or any other actions performed when they transact with you using Justdun.

Sources of Information

We collect (and/or have collected during at least the 12-month period preceding the effective date of this Privacy Notice) information about you from the following list and categories of sources:

• You directly, when you submit information to us or allow us to access information about you;

• Your devices and applications when you interact with our website or use our Platform;

• Our group companies and affiliates;

• Other sources, including:

• Social media networks;

• Online advertising companies;

• Service providers who help us with third-party identity verification, credit confirmation and fraud detection;

• Credit bureaus and financial institutions;

• Mailing list providers; and

• Publicly available sources (such as public records of criminal convictions and arrest records).

Use of your information

We use your data to do things like make sure the product offerings work, help you log in to your account, verify who you are, secure your data, fight fraud, follow the law, enforce our agreements, figure out what new products we can develop, and market products to you that we think could make it easier for you to run your business. We may collect, use and share (or have collected, used or shared during at least the 12-month period preceding the effective date of this Privacy Notice), information about you for the following reasons: Performing, improving and developing our services

• Delivering the information and support you request, including technical notices, security alerts, and support and administrative messages such as to resolve disputes, collect fees, and provide assistance for problems with our Platform or your Justdun/d account;

• Determining what or whether the Platform are available in your country;

• Developing new products and services;

• Displaying your historical transaction or appointment information;

• Improving, personalizing, and facilitating your use of our Platform;

• Processing or recording payment transactions or money transfers;

• Providing, maintaining and improving our Platform, including our website; and

• Otherwise providing you with the Justdun’s products and features you choose to use.

Communicating with you about our services

• Sending you surveys and getting your feedback about our Platform;

• Providing information about and promoting our Platform and third-party services to you; and

• Sending you information we think you may find useful or which you have requested from us about our products and services.

Protecting our services and maintaining a trusted environment

• Conducting investigations, complying with and enforcing applicable laws, regulations, legal requirements and industry standards, and responding to lawful requests for information from the government or to valid legal process;

• Contacting you to resolve disputes, collect fees, and help you with our Platform;

• Debugging to identify and fix errors that impair how our Platform function;

• Making sure you follow our user participation agreement or applicable agreements or policies;

• Investigating, detecting, preventing, recovering from or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities, or to otherwise help protect your account;

• Protecting your, our, our users’, or your users’ rights or property, or the security or integrity of our Platform;

• Verifying or maintaining the quality and safety of our Platform; and

• Verifying your identity

Advertising and marketing

• Marketing our Platform to you; and

• Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners.

• If we send you marketing emails, each email will have instructions on how you can “opt out” of getting future marketing from us.

Sharing of your information

We may share the personal information described “Information we collect about you” section with the following categories of service providers and third parties:

With other users of our services with whom you interact

• With other users of our Platform with whom you interact through your own use of our Platform. For example, we may share information with your users when you make or accept a payment, appointment, or money transfer using our Platform.

With our affiliates and group companies

• With our group companies and corporate affiliates, for the reasons outlined above. For example, we may share your information internally to understand how you engage with Justdun company products to help make our Platform better for you and for everyone, and to help us build Platform tailored to your preferences.

With our service providers

• With service providers who help us provide, maintain, and improve our Platform (e.g., vendors who help us with fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, credit bureaus, partners and other entities that help us provide the Platform;

• With service providers that help us run our advertising campaigns, contests, special offers, or other events or activities.

With your consent

• With your consent. For example:

• At your direction or as described at the time you agree to share; or

• When you authorize a third-party application or website to access your information.

Aggregated and anonymized information

• We also may share (within our group of companies or affiliates, or with service providers or other third parties) aggregated and anonymized information that does not specifically identify you or any individual user of our Platform.

Cookies and other similar technologies

Digital cookies and similar technologies help us make our services better to use by doing things like recognizing when you’ve signed in, analysing how you use our services so we can make them more useful to you, giving you a more personalized experience, and making our ads to you work better. We use these automated technologies to collect your device information, internet activity information, and inferences as described above. These technologies help us to:

• Remember your information so you do not have to re-enter it;

• Track and understand how you use and interact with our online services and emails;

• Tailor our online services to your preferences;

• Measure how useful and effective our services and communications are to you; and

• Otherwise manage and enhance our products and services.

Third-Party advertisement and analytics

We use other companies as service providers to help us analyse our site, track metrics, and advertise to you. These service providers generally promised us under contract to keep data private but have their own policies that you should be aware of: We may use third-party analytics service providers to help us with our online services, such as but not limited to Google Analytics or Facebook. The analytics providers that administer these services use technologies such as cookies, web beacons, and web server logs to help us analyse how you use our online services.

Period of information Retention

We keep your information as long as you keep using our products and services. After that, we keep it for as long as we need it to ensure business necessities and continue without interruption. We generally keep your information as long as reasonably necessary to provide you the Platform or to comply with applicable law. However, even after you deactivate your account, we can retain copies of information about you and any transactions or Platform in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with various stakeholders.

In some circumstances, we may aggregate your information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. You agree and acknowledge that your information will continue to be stored and retained by us for as long as necessary to fulfil our stated purpose(s)and for a reasonable period after the termination of your account on the Platform or access to the Services to comply with our legal rights and obligations.

Location Access

In order to provide certain Platform, we may request access to your location that includes information, including precise geolocation information collected from your device. If you do not consent to the collection of this information, certain Platform will not function properly, and you will not be able to use those Platform. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications will no longer function. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove all Justdun’s mobile applications from your device.

Promotional Communication

You can opt out of receiving promotional email messages from Justdun by either following the opt-out instructions included in those messages or by logging into your Justdun’s account and changing your email notification settings. You may only?opt out of promotional text messages from Justdun by replying STOP. Opting out of receiving communications may impact your use of the Platform. If you decide to opt out, we may still send you non-promotional (transactional) communications, such as digital receipts and messages about your account or our ongoing business relations.

User Rights

Right to a Copy/Access or Portability:

You may have the right to request, free of charge, a copy of the specific pieces of Personal Information that we have collected about you in a readily useable format that allows you to transmit this information to another entity without hindrance.

Right to Know:

You may have the right to request, free of charge, that we provide certain information about how we have handled your Personal Information, including the categories of Personal Information collected; categories of sources of Personal Information; business and/or commercial purposes for collecting your Personal Information; categories of third parties/with whom we have shared your Personal Information; and whether we sell any categories of Personal Information to third parties (however, we do not sell your Personal Information).

Right to Deletion:

You may have the right to request deletion of your Personal Information that we have collected, subject to certain exemptions. Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). We may also retain residual information, such as records to document that your request has been fulfilled.

Right to Non-Discrimination:

You may have the right not to receive discriminatory treatment on the basis of exercising your privacy rights under applicable law.

Right to Correct/Rectify:

You may have the right to rectify any incorrect Personal Information we may hold about you.

Right to Object/Restrict:

You may have the right to object to a specific use of your Personal Information as it is laid out in this Privacy Policy subject to our legitimate business interests.

Security

We take security of your data seriously and use best practices to keep your data safe. No business can ever guarantee hackers won’t be able to break into our site(s) however security and protection of your data is given the highest priority. We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers. Where you have chosen a password that enables you to access certain parts of the platform, you are responsible for keeping this password secret and confidential. We will not be responsible for any unauthorised use of your information, or for any lost, stolen, or compromised passwords, or for any activity on your user account due to such unauthorised disclosure of your password. In the event your password has been compromised in any manner whatsoever, you should promptly notify us to enable us to initiate a change of password.
We implement appropriate security measures and privacy-protective features on our Platform including encryption, password protection, call masking and physical security measures to protect your information from unauthorised access and disclosure, and follow standards prescribed by applicable law.

Processing and Storage

We operate in several countries and we (or our service providers) may move your data and process it various geographical locations. We may, and we may use third-party service providers to, process and store your information in the United States, Canada, the European Union, and other countries.

Transfer of your Information

(a) We comply with applicable laws in respect of storage and transfers of personal data. As a part of your use of the Platform, the information and personal data you provide to us may be transferred to and stored in countries other than the country you are based in. This may happen if any of our servers are from time to time located in a country other than the one you are based, or one of our vendors, partners, or service providers is located in a country other than one you are based in.
(b) By submitting your information and personal data to us, you agree to the transfer, storage, and processing of such information and personal data in the manner described above.

Business transitions

You are aware that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, your personal data might be among the assets transferred.

Children

If you are under 13, please don’t use our platform or any of its facilities or features. If we collect your information and later learn you are under 13, we will delete it at our sole discretion.
If you are between the age of 13 to 18 years of age and a user of the Justdun Platform under a verifiable Justdun account or can otherwise be identified, you may also be entitled to request us to remove content or information that has been collected by us. We have the sole discretion on our part to facilitate such requests.

Modifications

We may amend this Privacy Notice from time to time by posting a revised version and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed. We will provide you with reasonable prior notice of material changes in how we use your information, including by email if you have provided one. If you disagree with these changes, you may cancel your account at any time. If you keep using our Platform, you consent to any amendment of this Privacy Notice.

Contact

You can contact our team for any questions or concerns about how we process or handle your information or otherwise you may reach out to us, with your queries, grievances, feedback, and comments at our official address or submit a message or request through the Justdun Platform themselves via call, message, email or help centre.
Where applicable law allows for such a right to request to access, correct, object to the use, restrict or delete information that you have previously provided to us, or if you would like to request to receive an electronic copy of your information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may submit a message or request.