Protecting the individual's privacy on the Internet is crucial to the future of Internet-based business and the move toward a true Internet economy. We have created this Privacy Statement to demonstrate our firm commitment to the individual`s right to data protection and privacy.
This Privacy Statement outlines how we handle information that we collect that can be used to directly or indirectly identify an individual ("Personal Data"). This Privacy Statement also provides information regarding how you can access and update your Personal Data and make certain choices about how your Personal Data is used by us. This Privacy Statement will come into effect from May 25, 2018.
A. General Information
When does this Privacy Statement apply? This Privacy Statement applies to Personal Data that you provide to Manthan Systems Inc. and/or its affiliates or its group entities (“MANTHAN”) through manthan.com (the “Website”) or through subscription of our products and/or services, or by joining the MANTHAN community on social media websites, or which is provided to one of our marketing partners, or which is provided through other engagements with MANTHAN or which is derived from the Personal Data as outlined below.
The use of and any information that is gathered by cookies or other web tracking technologies on the Website is subject to the disclosures and options provided by the TrustArc Consent Manager which can be found on the relevant website.
Data Controller. The data controller of the “Website is Manthan Systems, Inc. 5201 Great America Parkway Suite 320, Santa Clara, CA 95054. Where a registration form is presented on this Website, the data controller may vary depending on the actual offering or the purpose of the data collection but it is in any case displayed on the individual registration form’s privacy statement. MANTHAN’s data protection officer is Atul Batra (email@example.com) and any queries that you may have regarding this Privacy Statement may be addressed to the above email address.
What Personal Data does MANTHAN collect. MANTHAN may collect the following information from you, through your use of the Website or through subscription of our products and/or services, or by joining the MANTHAN community on social media websites, or which is provided to one of our marketing partners or through engagement with MANTHAN: (i) name; (ii) title; (iii) email address; (iv) company name and (v) phone number.
Cookies. Additionally, MANTHAN may also collect cookies through your use of the Website. Cookies are text files that MANTHAN may place in your computer browser to store your preferences. Cookies are used to record various aspects of your visit and assist us in providing you with uninterrupted service. One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content. However, no personal information identifying the user is collected nor any data capture mechanisms is employed. You may change your cookie settings at any time, on your browser.
What does MANTHAN do with your Personal Data? MANTHAN will process the Personal Data provided hereunder only as set out in this Privacy Statement. Further information can be found in Sections B. and C. below. (1) Where the processing of your Personal Data is based on a statutory permission, you can find information on which Personal Data MANTHAN is processing or using for which purposes in Section B below. (2) Where consent for the processing of your Personal Data is required you can find further information in Section C. below.
Duration of processing of Personal Data. Where MANTHAN is processing and using your Personal Data as permitted by law (see B. below) or under your consent (see C. below), MANTHAN will store your Personal Data (i) only for as long as is required to fulfil the purposes for which the Personal Data was collected. If, at any time, you object to MANTHAN’s use of your Personal Data (where MANTHAN has a legitimate interest in using your Personal Data), or you withdraw your consent (as provided under Section C), Manthan will stop processing of such Personal Data. However, where MANTHAN is required by mandatory law to retain your Personal Data longer or where your Personal Data is required for MANTHAN to assert or defend against legal claims, MANTHAN will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.
Why am I required to provide Personal Data? As a general principle, your granting of any consent and your provision of any Personal Data hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide Personal Data. However, there are circumstances in which MANTHAN cannot take action without certain Personal Data, for example because this Personal Data is required to process your orders or provide you with access to a web offering or newsletter. In these cases, it will unfortunately not be possible for MANTHAN to provide you with what you request without the relevant Personal Data. [At every instance when Manthan is collecting Personal Data from you, you will be informed of the purposes for which such Personal Data will be used, and the option to opt-out of providing the information or any of the purposes for which your Personal Data might be used.
Where will your Personal Data be processed? As part of a global group of companies, MANTHAN has affiliates and third-party service providers within as well as outside of the European Economic Area (the “EEA”). As a consequence, whenever MANTHAN is using or otherwise processing your Personal Data for the purposes set out in this Privacy Statement, MANTHAN may transfer your Personal Data to countries outside of the EEA including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 87/2010/EC or any future replacement) in order to contractually provide that your Personal Data is subject to a level of data protection that applies within the EEA. You may obtain a redacted copy (from which commercial information and information that is not relevant has been removed) of such Standard Contractual Clauses by sending a request firstname.lastname@example.org.
Data subject's rights.
Right to request for correction or deletion of Personal Data. You can request from MANTHAN at any time information about which Personal Data MANTHAN processes about you and the correction or deletion of such Personal Data. Please note, however, that MANTHAN can delete your Personal Data only if there is no statutory obligation or prevailing right of MANTHAN to retain it. Kindly note that if you request that MANTHAN delete your Personal Data, you will not be able to continue to use any MANTHAN service that requires MANTHAN’s use of your Personal Data.
Right to request for a copy of the Personal Data. If MANTHAN uses your Personal Data based on your consent or to perform a contract with you, you may further request from MANTHAN a copy of the Personal Data that you have provided to MANTHAN. You may also ask for a copy of the information setting out purposes, categories of personal data processed, recipients to whom your Personal Data disclosed, and the period for which you Data is stored. In this case, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like this information, and whether the Personal Data is to be sent to you or another recipient. MANTHAN will carefully consider your request and discuss with you how it can best fulfill it.
Right to request for Manthan to stop processing. Furthermore, you can request from MANTHAN that MANTHAN restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data MANTHAN has about you is incorrect, (but only for as long as MANTHAN requires to check the accuracy of the relevant Personal Data), (ii) there is no legal basis for MANTHAN processing your Personal Data and you demand that MANTHAN restricts your Personal Data from further processing, (iii) MANTHAN no longer requires your Personal Data but you claim that you require MANTHAN to retain such data in order to claim or exercise legal rights or to defend against third party claims or (iv) in case you object to the processing of your Personal Data by MANTHAN (based on MANTHAN’s legitimate interest as further set out in B. below) for as long as it is required to review as to whether MANTHAN has a prevailing interest or legal obligation in processing your Personal Data.
Right to lodge a complaint. If you believe that MANTHAN is not processing your Personal Data in accordance with the requirements set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which MANTHAN has its registered seat.
Right to have the Personal Data transferred If at any time you wish to have your Personal Data transferred to another controller, you may contact us at [.] to request for such transfer.
Use of this website by children. This website is not intended for anyone under the age of 16 years. If you are younger than 16, you may not register with or use this website. If at any time, Manthan is intimated that it has collected the data of users below 16 years or has provided services to such person, we will at once delete the data from our records, and stop the provision of services.
Links to other websites. This website may contain links to foreign (meaning non-MANTHAN Group companies) websites. MANTHAN is not responsible for the privacy practices or the content of websites outside the MANTHAN Group of companies. Therefore, we recommend that you carefully read the privacy statements of such foreign sites.
B. Where MANTHAN uses your Personal Data based on applicable Law
In the following cases, MANTHAN is permitted to process your Personal Data under the applicable data protection law.
Providing the requested goods or services. If you request digital content, MANTHAN will use the Personal Data that you enter into the order or registration form (usually (a subset of) your name, (email) address, telephone number, company name and address, your job title and role) for providing the requested products and/or services. This may also include conversation data that you may trigger via the chat functionalities on MANTHAN.com or other local MANTHAN web presences, contact forms, emails, or telephone. In this Privacy Statement, “products and/or services” includes (access to) MANTHAN’s web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.
If you participate in tutorials or trainings provided by MANTHAN, MANTHAN may also track your learning progress in order to make this information available to you.
Usage of Personal Data. Furthermore, we communicate on a regular basis by email with users who subscribe to our services for the purposes as provided below, and we may also communicate by phone to resolve customer complaints or investigate suspicious transactions.
We may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), MANTHAN will (i) where legally required only provide you with such information after you have opted in and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us. You can opt out of these at any time at https://www.manthan.com/unsubscribe
Ensuring compliance. MANTHAN and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, MANTHAN is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through MANTHAN’s websites or other delivery channels controlled by MANTHAN. This may include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to MANTHAN’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match.
Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Data or receipt of marketing materials (that is to say, depending on the country in which the relevant MANTHAN Group company operates, whether you have expressly consented to or opted out of receiving marketing materials) may be stored and exchanged between members of the MANTHAN Group as required to ensure compliance.
MANTHAN’s legitimate interest. Each of the use cases below constitutes a legitimate interest of MANTHAN to process or use your Personal Data. If you do not agree with this approach, you may object against MANTHAN’s processing or use of your Personal Data as set out below.
Questionnaires and surveys. MANTHAN may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, MANTHAN may use such Personal Data to improve its products and services.
Creation of anonymized data sets. MANTHAN may anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates’ products and services.
Recording of calls and chats for quality improvement purposes. In case of telephone calls or chat sessions, MANTHAN may record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of MANTHAN’s services.
In order to keep you up-to-date/request feedback. Within an existing business relationship between you and MANTHAN, MANTHAN may inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from MANTHAN. Furthermore, where you have attended a webinar, seminar or event of MANTHAN or purchased products or services from MANTHAN, MANTHAN may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.
Right to object. You may object to MANTHAN using Personal Data for the above purposes at any time by unsubscribing at https://www.manthan.com/unsubscribe. If you do so, MANTHAN will cease using your Personal Data for the above purposes (that is to say, under a legitimate interest set out above) and remove it from its systems unless MANTHAN is permitted to use such Personal Data for another purpose set out in this Privacy Statement or MANTHAN determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.
C. Where MANTHAN uses your Personal Data based on your Consent
In the following cases MANTHAN will only use your Personal Data as further detailed below after you have granted your prior consent into the relevant processing operations.
News about MANTHAN’s Products and Services. Subject to a respective provision and your consent, MANTHAN may use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with MANTHAN (prior purchases, participation in webinars, seminars, or events or the use of (web) services) in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about MANTHAN’s software and services (including marketing-related newsletters) as well as events of MANTHAN and in order to display relevant content on MANTHAN’s websites. In connection with these marketing-related activities, MANTHAN may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own data bases in order to display to you more relevant information.
Creating user profiles. MANTHAN offers you the option to use its web offerings including forums, blogs, and networks (such as the MANTHAN Community) linked to this website that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.
These profiles may relate to a single web offering of MANTHAN or, if created in the MANTHAN Cloud Platform Identity Authentication Service, may also allow you to access other web offerings of MANTHAN or of other entities of the MANTHAN Group, or both (irrespective of any consent granted under the section “Forwarding your Personal Data to other MANTHAN companies.” below). It is, however, always your choice which of these additional web offerings you use and your Personal Data is only forwarded to them once you initially access them. Kindly note that without your consent for MANTHAN to create such user profiles MANTHAN will not be in a position to offer such services to you where your consent is a statutory requirement that MANTHAN can provide these services to you.
Within any web offering, beyond the mere provision of access your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by MANTHAN to foster the quality of communication and collaboration through such offerings and for MANTHAN to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant web offering, you can use the functionality of the relevant web offering to determine which information you want to share.
Event profiling. If you register for an event, seminar, or webinar of MANTHAN, MANTHAN may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.
Forwarding your Personal Data to other MANTHAN companies. MANTHAN may transfer your Personal Data to other entities in the MANTHAN Group. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above
Forwarding your Personal Data to our marketing partners. MANTHAN may, with your prior consent, share your Personal Data with our marketing partners to enable them to reach out to you for relevant marketing products and/or services that you may be interested in. For example, our marketing partners may reach out to you for programmes to improve customer satisfaction, performing market research, providing value added services, for regional support of services, or to organize MANTHAN events. MANTHAN will not, at any time, sell your Personal Data to any third party.
Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing at https://www.manthan.com/unsubscribe. In case of withdrawal, MANTHAN will not process Personal Data subject to this consent any longer unless legally required to do so. In case MANTHAN is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by MANTHAN up to the point in time of your withdrawal. Furthermore, if your use of an MANTHAN offering requires your prior consent, MANTHAN will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for MANTHAN to use your profile under the MANTHAN Cloud Platform Identity Authentication Service for multiple MANTHAN offerings), offer or event to you after your revocation.
How does Manthan protect your Personal Data
MANTHAN implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of your Personal Data such as (i) only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible; (ii) using secure servers to store your information; and (iii) using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.
Our databases have a number of security measures to ensure there is no loss, misuse or illegal alteration of information collected from its users. Personal Data we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet or wireless communication and any information you transmit to MANTHAN you do at your own risk. If, despite our best efforts, an unauthorised breach of our security measures occurs, resulting in the unauthorised access, duplication, removal or alteration of any Personal Data, subject to applicable law, MANTHAN, its directors, officers, employees, promoters, or affiliates will not be held responsible for any loss resulting from such unforeseen breach.
Changes to the Privacy Statement
From time to time, we may update this Privacy Statement to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Statement. If we make any material changes, we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
E. E.U. Specific Provisions
This Privacy Statement is in compliance with the provisions of the European Union General Data Protection Regulation.
F. U.S.-Specific Provisions
Where MANTHAN is subject to U.S. privacy requirements, the following also applies:
Do Not Track. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our sites do not honor “Do not track” requests. However, you may elect not to accept cookies by changing the designated settings on your web browser or, where available, by way of the TrustArc Consent Manager if the relevant website contains a link to it. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site. This site does not allow third parties to gather information about you over time and across sites.
Requirements to Protect Children's Privacy. We do not intend for our websites or online services to be used by anyone under the age of 13. If you are a parent or guardian and believe we may have collected information about a child, please contact at email@example.com.
G. Russia-Specific Provisions
The following applies to users who are resident in the Russian Federation:
The services hereunder are not intended for use by citizens of the Russian Federation who are resident in Russia. If you are a Russian citizen residing in Russia, you are hereby notified that any Personal Data that you input into the services will be solely at your own risk and responsibility, that you expressly agree that MANTHAN may gather your Personal Data and will process this data in the United States and in other countries, and that you will not hold MANTHAN accountable for any potential non-observance of legislation of the Russian Federation.