GENERAL DATA PROTECTION REGULATION 

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For www.ankoornaik.com (“Our Website”)

Last updated

25th September, 2023

General Data Protection Regulation (GDPR) came into effect 25^th May 2018, creates consistent data protection rules across Europe. It applies to all companies that process personal data about individuals in the EU, regardless of where the company is geographically based. Processing refers to anything related to personal data of individuals in the EU, including but not limited to ‘how a company handles and manages data’, such as collecting, storing, using and deleting/destroying data.

Definitions:

Company / Us / We

means the sole Proprietary Concern under the brand name of “Ankoor Naik” owned by Mr. Ankoor Naik.

GDPR

means the General Data Protection Regulation.

Responsible Person

means Mr. / Ms. Ankoor Naik appointed by the Company for the purpose of ensuring GDPR relating compliances [Client to insert name of person responsible for data protection within the Company].

Register of Systems

means a register of all systems or contexts in which personal data is processed by the Company.

1. Data protection principles

We are committed to processing data in accordance with its responsibilities under the GDPR. 

Pursuant to Article 5 of the GDPR with respect to the personal data that We collect via our Website, We:

1. Process the personal data lawfully, fairly and in a transparent manner in relation to individual Users;
2. The data is collected for specified, explicit and legitimate purposes namely for receiving payments made by the Users for our Products and for marketing purpose with the prior written consent of the Users (as mentioned in our Privacy Policy) (Client to insert Privacy Policy link here) and not further processed in a manner that is incompatible with those purposes. However, with respect to Users who shall pay for our products via our payment gateway partners / service providers, such Users will be redirected to the website of such payment gateway partners / service providers and in view thereof, the transaction shall be governed by the Privacy Policy, Terms and Conditions and other website and payment related policies of such payment gateway partners / service providers. Our Website shall neither be liable nor responsible in any manner whatsoever at any time for any breach or default on the part of any payment gateway partners / service providers relating to the User and/or personal data / sensitive personal data of the User.
3. We may further process the personal data so collected solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes that is not incompatible with the initial purposes;
4. The data so collected by Us is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
5. The data collected, to the best of our knowledge and belief, is accurate and where necessary, kept up-to date; every reasonable step is taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without any undue delay;
6. The data collected is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures as required by the GDPR in order to safeguard the rights and freedoms of individuals; and
7. The data collected is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. General provisions

1. This Policy applies to all personal data collected / processed by Us that belongs to individual Users that reside in European Union. 
2. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this Policy. 
3. This Policy shall be reviewed by Us at least once, annually or as per the changes in the applicable laws for the time being in force. 

3. Lawful, fair and transparent processing 

Pursuant to Article 6 of the GDPR with respect to the personal data, We take the following measures:

1. All data collected is preceded by a prior written free consent from the individual Users with respect to processing of their personal data;
2. We ensure that processing of data is lawful, fair and transparent, 
3. We maintain a register for the same viz. Register of Systems. 
4. The Register of Systems shall be reviewed at least once, annually. 
5. Individuals (whose data is collected) shall have the right to access their personal data and any such requests made to Us shall be dealt with in a timely manner. 

4. Lawful purposes

1. All data processed by Us is carried on either one of the following lawful basis: prior written free consent of the User, contractual, legal obligation, vital interests, public task or legitimate interests.
2. We ensure to note the appropriate lawful basis in the Register of Systems.
3. When consent of a User is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. 
4. When communications are sent to individuals based on their consent, the option for the individual to revoke their consent is clearly available and accordingly systems are in place to ensure such revocation of User consent is reflected accurately in the Company’s systems.  

5. Data minimisation

1. We ensure that personal data so collected by Us is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 
2. [Client to add considerations relevant to the Company’s particular systems] 

6. Accuracy

1. We take reasonable steps to ensure personal data of Users so collected is accurate. 
2. Where necessary for the lawful basis on which data is processed, requisite steps are put in place to ensure that personal data of Users is kept up-to-date. 
3. [Client to add considerations relevant to the Company’s particular systems]

7. Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, We have put in place an archiving policy for each area in which personal data is processed and We review this process annually. 
2. The archiving policy shall consider what data should/must be retained, for how long, and why. 

8. Security

1. We ensure that personal data is stored securely using modern software that is kept-up-to-date. 
2. All Our servers where the personal data is stored in India and we do not indulge in cross-border transfer of personal data collected by us.All our servers where the personal data is stored is available worldwide and we do not indulge in cross-border transfer of personal data collected by us.
3. Access to personal data shall be limited to personnel who shall “need” access to the same and appropriate security measures are in place to avoid unauthorised sharing of information. 
4. When personal data is deleted / erased, the erasure / removal / deletion is done safely in such a manner that the data so deleted is irrecoverable. 
5. Appropriate back-up and disaster recovery solutions are in place with an aim to circumvent data breach and in the event of data breach, the breach can be effectively controlled.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, We shall promptly assess the risk with an intent to contain the breach as far as possible.

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