| 1 | 1 | ## PRIVACY POLICY |
| 2 | 2 | |
| 3 | | The Malayala Manorama Co. (P) Ltd. ("Malayala Manorama" or "we") operates manoramaonline.com, fasttrackworld.com, gulfmanorama.com, manoramanews.com the Malayala Manorama iPhone application, the Malayala Manorama iPad application , the Malayala Manorama Android application, the Malayala Manorama Java/Symbian application, Malayala Manorama Windows application and any other Malayala Manorama owned and controlled URL, Mobile site and mobile application (collectively, the "Site"), Malayala Manorama messaging services, video services, RSS feeds, podcasting services, mobile services, and any other feature, content, or applications offered from time to time by Malayala Manorama in connection with Malayala Manorama' business (collectively, the "Malayala Manorama Services"). |
| 3 | Welcome to Manoramaonline. **This website/application is exclusively owned, operated and managed by The Malayala Manorama Co Private Limted.** By accessing or purchasing from this site, you agree to the terms below. |
| 4 | 4 | |
| 5 | | As set forth in our Terms of Use, Malayala Manorama is a general audience site, is not targeted to children, and does not knowingly collect personal information from children under 16 years of age. We encourage minors to seek the consent from their parents before providing any information about themselves. |
| 5 | 1. ## Definitions |
| 6 | 6 | |
| 7 | | This Privacy Policy describes Malayala Manorama's collection and use of users' personal information (e.g., information that identifies a specific person, such as full name or email address). It also describes generally Malayala Manorama's practices for handling non-personally identifiable information (e.g., user interests, demographics and site usage) to the extent such information is associated with a particular user or user account. This Privacy Policy applies to all "users," including both visitors (users who use some of the Malayala Manorama Services without being registered) and "Members" (users who have registered with Malayala Manorama). |
| 7 | a) Controller means the natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data |
| 8 | 8 | |
| 9 | | ## SUBMISSION AND COLLECTION OF INFORMATION ON Malayala Manorama SERVICES |
| 9 | b) "International Organization" means an organization and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries. |
| 10 | 10 | |
| 11 | | **User Submitted Information** |
| 11 | c) "Personal Data" means any information relating to an identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes Sensitive Personal Data. |
| 12 | 12 | |
| 13 | | Registration Information is the information that Members must provide to use at registration in order to create a profile (also called an "account"), and includes display name, email address, year of birth, zip code, and country. |
| 13 | d) "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. |
| 14 | 14 | |
| 15 | | ## Malayala Manorama Collected Information |
| 15 | e) "Sensitive Personal Data" means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, your criminal record, genetic and biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning your sex life or sexual orientation. |
| 16 | 16 | |
| 17 | | Malayala Manorama Services Activity Information. When users access the Malayala Manorama Services, we may collect certain non-personally identifiable information about those visits. For example, in order to permit your connection to the Malayala Manorama Services, our servers receive and record information about your computer and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Malayala Manorama Services from a mobile or other device, we may collect a unique device identifier assigned to that device or other transactional information for that device in order to serve content to it. We also may use cookies and other tracking technologies (including browser cookies, pixels, beacons, and Adobe Flash technology including cookies), which are comprised of small bits of data that often include an anonymous unique identifier. Web sites send this data to your browser when you first request a web page and then store the data on your computer so the web site can access information when you make subsequent requests for pages from that site. We may use these technologies to anonymously collect and store information about your usage of the Malayala Manorama Services, such as pages you have visited, search queries you have run, and advertisements you have seen. We use cookies to store data such as password, name, address, preferred font size, page layout to remember your settings for personalizing the way content is viewed by you so that you don’t have to make changes every time you visit our site. We also use third party cookies and tracking cookies for serving advertisements based on your search history. If you use our site you are consenting to the use of cookies as explained here. |
| 17 | f) "Website" means the website located at www.ManoramaOnline.com which is owned and operated by The Malayala Manorama Company Ltd. |
| 18 | 18 | |
| 19 | | Third parties that support the Malayala Manorama Services by serving advertisements or providing services, such as allowing users to share content or tracking aggregate site usage statistics, may also use these technologies to collect similar information. Malayala Manorama does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. |
| 19 | g) "Unregistered User" means any person who accesses and/or uses the Website without registering on the Website as a Registered User. |
| 20 | 20 | |
| 21 | | Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies). Users can manage the use of Flash technologies, including cookies, with the Flash management tools available at Adobe's web site, see http://www.adobe.com/products/flashplayer/security/privacy\_policy/. Please note that by blocking any or all cookies you may not have access to certain features or personalization available through the Malayala Manorama Services. |
| 21 | h) "Registered User" means any person who accesses or uses the Website after opening a registered user account with the Website. |
| 22 | 22 | |
| 23 | | Public Information and Posts consist of comments or content that you post to the Site and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public information and posts are always public, which means they are available to everyone and may be displayed in search results on external search engines. |
| 23 | i) "Registered User Account" means the account opened by a person with the Website after taking the required steps and providing the required details for the purposes of availing of the services provided by the Website. |
| 24 | 24 | |
| 25 | | Third Parties. To improve the quality of the Malayala Manorama Services, we may supplement the information we collect with information from third parties. If you access the Malayala Manorama Services through a third-party connection, log-in, website, app or service, we may also collect your public user ID associated with that third-party service, and any information or content you have permitted that third party service to share with us, such as your profile picture, email address, and any information you have made public in connection with that service and which the third party shares with partner services. When you access the Malayala Manorama Services through a third party service, or when you connect the Malayala Manorama Services to a third party service, you are authorizing us to collect, store and use any and all information or content you have made public in connection with that service in accordance with this Privacy Policy. |
| 25 | j) "You", "Your" means users of the Website, whether Registered Users or Unregistered Users |
| 26 | 26 | |
| 27 | | Location of Data. The Malayala Manorama Services are hosted by multiple cloud service providers across the globe. If you are a user located inside or outside India, you understand and consent to having any personal information you provide transferred to and processed where our servers are hosted. Indian data protection and other relevant laws may not be the same as those in your jurisdiction. |
| 27 | k) "We" "Our" means The Malayala Manorama Company Ltd. |
| 28 | 28 | |
| 29 | | ## How We Use Information |
| 29 | 2. The various services provided in or through this Website are hereinafter collectively referred to as the \`Services'. The Services provided by the Website also include certain services that are available via the User's mobile phone, including (i) the ability to upload content to the Website via the User's mobile phone (Mobile Uploads), (ii) the ability to browse the Website from the User's mobile phone (Mobile Web), and (iii) the ability to access certain features of the Website through a mobile application the User can download and install on the User's mobile phone (Mobile Client) (referred to collectively as "Mobile Services"). The Site Owner does not charge the User for these Mobile Services, However, the User's carrier's normal messaging, data transfer and other rates and fees will still apply. The User should check with the User's carrier to find out what plans are available and how much they cost. In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by the User's carrier or mobile device vendor, and not all Mobile Services may work with all carriers or devices. Therefore, the User should check with the User's carrier or mobile device vendor to find out if the Mobile Services are available on the User's mobile devices, and whether restrictions, if any, apply to the User's use of such Mobile Services. By using the Mobile Services, the User agrees to allow the Site Owner to communicate with User regarding the Website and other entities by SMS, MMS, text message or other electronic means (sent to the User's mobile device). the User further acknowledges that certain information about the User's usage of the Mobile Services may be communicated to the Site Owner. The Mobile Services provided by the Website have been tested by the Site Owner in a laboratory on certain mobile devices and it has been found that they work normally in conjunction with other normal applications or services available on the mobile devices, However, use of the Website's mobile services on the User's mobile device is at the User's own risk and the Site Owner will not be responsible for any malfunction on the User's mobile device or loss of data on account of the use by the User of the Website's mobile services. |
| 30 | 30 | |
| 31 | | **To Provide and Manage the Services You Request**. This includes, for example, processing your subscription, sending you electronic newsletters, or enabling you to participate in the features provided by the Services. It also includes providing personalized content and recommendations to you, including by email. Through such features, we are able to bring you information and content tailored to your individual interests and needs. |
| 31 | 3. The Malayala Manorama Company Ltd., is the Controller with respect to information you provide through the Services. |
| 32 | 32 | |
| 33 | | **To Contact You**. We may periodically contact you with offers and information about the Services and our affiliates, including in connection with your accounts, online surveys, legal notices, news stories, new features that you are entitled to access, and other important information. You may opt out of receiving commercial email messages from us by following the instructions contained in those email messages. |
| 33 | 4. The manner in which we collect and handle the personal data of customers is detailed in this Privacy Policy. |
| 34 | 34 | |
| 35 | | **To Deliver Targeted Advertising and Email promotions**. We may use your information to facilitate the delivery of targeted ads, promotions, and offers to you, on behalf of ourselves and advertisers, on and off the Services. |
| 35 | 5. When you use our Services, the advertisements displayed may be personalized and tailored to your interests and preferences based on your personal data collected through our Services. For more information on advertising and your rights and choices, see "Third Party Websites, Social Media, and Advertisers" below. |
| 36 | 36 | |
| 37 | | **To Better Understand Our Readers and Users**. The Services conduct research on our users' demographics, interests and behavior based on the information we collect. We do this to better understand and serve our users, and to improve our products and services. |
| 37 | 6. By accessing and using the Website you are consenting to the collection and use of your data in accordance with this Privacy Policy. By registering an account or logging on as a member on the Website, you are consenting to the collection and use of your Personal Data and Sensitive Personal Data. |
| 38 | 38 | |
| 39 | | ## DATA DELETION |
| 39 | 7. For any requests relating to our use of your Personal Data or Personal Sensitive Data, you may send an email to our Data Protection Officer, Mr. Renjit Paul at customersupport@mm.co.in and your requests will be taken up and acted upon. |
| 40 | 40 | |
| 41 | | If you wish Manorama Online to delete your user account/personally identifiable data, you are requested to send an email to customersupport@mm.co.in - by expressly stating that your account/ the data provided by you be deleted. Please note that we may retain backup information related to your account in our archives for some time after deletion for fraud detection or to comply with applicable law. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. Your request will be processed within two working days of the receipt of your request. |
| 41 | 8. If you are a Registered User, you may at any time choose to suspend your profile from the website by changing your profile status from Active to Hidden in the My Account section of the Website. In order to delete your account with us you may do so on your own by pressing the button for Deleting availing in the Edit profile section of your account on the website. Further you may withdraw your consent to our collection and use of your Personal Data and Sensitive Personal Data by sending an email with your instructions to our Data Protection Officer. However, this may affect or limit your ability to use the Website and its services |
| 42 | 42 | |
| 43 | | ## NOTICE & CHOICE |
| 43 | 9. Please note that in order to erase any Personal Data that we have already collected from you, a request must be made by you sending an email to our Data Protection Officer with specific directions to either erase all your Personal Data or clearly identifying any specific Personal Data which you wish erased. |
| 44 | 44 | |
| 45 | | Means of Notice and Choice. This Privacy Policy is the primary means by which Malayala Manorama provides you with notice about its collection and use of your personal information. Malayala Manorama will not use your personal information in a manner different from what is described in this Privacy Policy without your permission. |
| 45 | 10. In order to provide you with the best matches with other persons who have registered on the Website, it is necessary for you to provide your personal details accurately. When you register for our services you are required to identify yourself and use truthful and accurate information. |
| 46 | 46 | |
| 47 | | We may change this Privacy Policy at any time by posting the revised Privacy Policy in the "Privacy Policy" section of the Website. The revised Privacy Policy is effective immediately when posted on the Website. It is the responsibility of each User to review the Website and the Privacy Policy periodically to learn of any revisions to this Privacy Policy. Your continued use of the Website after the effectiveness of such revisions will constitute your acknowledgment and acceptance of the terms of the revised Privacy Policy. |
| 47 | 11. Whenever you (including non-member users) visit our Website, our servers automatically record information for statistical purposes about your usage of the Website such as: (i) the type of browser used;(ii) the referring URL;(iii) the IP address;(iv) the number and type of pages viewed;(v) the date and time of visits; and(vi) the exit URL. This information we collect about you is not Personal Data and, in any event, remains anonymous. We do not link the anonymous information to any other Personal Data unless you have either registered as a member or logged on as a member at the time of use. Accordingly, if you have not identified yourself on the Website, such as by registering as a member or logging on as a member, we will not link a record of your usage of our Website to you personally. |
| 48 | 48 | |
| 49 | | Location of Data. The Malayala Manorama Services are hosted in the United States. If you are a user located inside or outside India, you understand and consent to having any personal information you provide transferred to and processed in the United States. Indian data protection and other relevant laws may not be the same as those in your jurisdiction. As a result, please read this Privacy Policy with care. |
| 49 | 12. Upon your registration as a member we collect information about you in order to provide you the benefit of the Registered User however the additional benefits of website can be availed on upon becoming membership. We collect non-identifying information as well as Personal Data from you directly when you first register, and also from time to time. Thereafter if you provide us with additional information Personal Data which may be collected by the Website, which information may include: (i) your full name;(ii) your email address;(iii) your residential address;(iv) your phone number;(v) a photograph of you;(vi) your age;(vii) your occupation;(viii) a description of your appearance;(ix) your credit card and billing information (if provided by you). |
| 50 | 50 | |
| 51 | | Linked Websites. The Malayala Manorama Services may also be linked to sites operated by Malayala Manorama affiliates (i.e., that are part of the "Affiliated Companies") or third parties, and may carry advertisements or offer games or applications developed and maintained by third parties. Malayala Manorama is not responsible for the privacy practices of any such third parties, and once you leave the Malayala Manorama Services via a link, enable a third-party service, or click an advertisement, you should check the applicable privacy policy of the third-party site. Additionally, although all Affiliated Companies adhere to the Malayala Manorama corporate Privacy Principles, users who visit an Affiliated Company site should still refer to its separate privacy policy, which may differ in some respects from this Privacy Policy. |
| 51 | 13. To properly enable you to utilize our services, we may also collect certain Sensitive Personal Data including: (i) your racial or ethnic origin; (ii) your religious beliefs or affiliations; (iii) your health; and (iv) your sexual preferences, practices or orientation. |
| 52 | 52 | |
| 53 | | ## USE AND DISCLOSURE |
| 53 | 14. To improve your experience on our Website, we may use cookies and other tracking technologies, such as pixel tags, web beacons, device IDs, or advertising IDs. |
| 54 | 54 | |
| 55 | | We use the information we collect from and about users for the following purposes: |
| 55 | 15. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this, you may not be able to use the full functionality of our Website. |
| 56 | 56 | |
| 57 | | To provide and manage the Malayala Manorama Services. We use the information we collect from and about users to provide the Malayala Manorama Services and features to you including to measure and improve those services and features, to personalize your experience by delivering relevant content, advertising and marketing messages, to provide you with customer support, and to respond to inquiries. We may use aggregated, anonymous data about use of and activity on the Malayala Manorama Services to assist us in this regard and such data is not subject to this Privacy Policy. |
| 57 | 16. Website may use third party services like Google Analytics, Google Firebase, Admob, Facebook and Comscore or inhouse products like Lens in order to collecting certain data for analytics purposes. These data are basically the traffic sessions, navigation details, user browser, IP address etc and not the subscriber profile details from our database. In order to understand the traffic of the site, we avail the service of Google Analytics. For user attribution of marketing campaigns, we use Facebook Audience Measurement. To aid in publishing reports on a monthly basis from various sites we deploy Comscore (https://www.comscore.com/About/Privacy/Security) |
| 58 | 58 | |
| 59 | | To allow third-party service providers to assist us in providing and managing the Malayala Manorama Services. Malayala Manorama may make your non-public personal information available to certain third-party service providers, such as contractors, agents or sponsors, who help us manage or provide the Malayala Manorama Services. These outside service providers are required to protect non-public personal information entrusted to them and not use it for any other purpose than the specific service they are providing to Site. |
| 59 | 17. Our Website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and web page usage. |
| 60 | 60 | |
| 61 | | We may use the information you provide to us, and information we collect about your use of the Malayala Manorama Services through cookies and other technologies, to assist us in delivering you relevant ads when you visit the Malayala Manorama Services. We may work with third-party advertising networks and advertisers who help deliver these ads to you. We do not share your non-public personal information with these third parties, but we may share anonymized or aggregated information with them to improve the relevancy of the ads you see on the Malayala Manorama Services. As noted above, these third-party advertising networks and advertisers may also use cookies and similar technologies to collect and track non-personally identifiable information such as demographic information, aggregated information, and Internet activity to assist them in delivering advertising that is more relevant to your interests. |
| 61 | 18. You can customize or opt out of Google Analytics for Display Advertising using the Ads Settings of your Google account. |
| 62 | 62 | |
| 63 | | To contact you. Malayala Manorama may periodically send promotional materials (e.g., newsletters) or notifications related to the Malayala Manorama Services to the email address you provided to us at registration or to your account. If you want to stop receiving promotional materials from Malayala Manorama, you can follow the unsubscribe instructions at the bottom of each email. There are certain service notification emails that you may not opt-out of as long as you are a member, such as notifications of changes to the Malayala Manorama Services or policies. |
| 63 | 19. Our Website uses cookies and other tracking technologies to support Google Analytics for: (i) Google Marketing Platform integrations; (ii) Demographic and Interest Reporting; (iii) Display Advertising including Remarketing and Google Display Network Impression Reporting to advertise our services online; (iv) Optimizing and personalizing ad services based on your past visits to our Website; and (v) Reporting the use of ad services and interactions with ad impressions and how they are related to visits to our site. Cookies and other tracking technologies may also be used to support analytics by other third parties. |
| 64 | 64 | |
| 65 | | To protect the rights of Malayala Manorama and our users. There may be instances when Malayala Manorama may disclose user information without providing notice or choice, including situations where Malayala Manorama has a good faith belief that such disclosure is necessary in order to: (i) protect or defend the legal rights or property of Malayala Manorama, our Affiliated Companies or their employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of users of the Malayala Manorama Services or members of the public; (iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process. |
| 65 | 20. We may allow third parties, including authorized service providers, advertising companies, data management platforms, and ad networks to serve advertisements on our Website. These companies may use tracking technologies (such as cookies, pixel tags, web beacons, device IDs, or advertising IDs) to collect information about users who view or interact with their advertisements. Any information that these third parties collect via cookies is completely anonymous and is non-identifiable. |
| 66 | 66 | |
| 67 | | To complete a merger or sale of assets. If Malayala Manorama sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Malayala Manorama may transfer your information to the party or parties involved in the transaction as part of that transaction. |
| 67 | 21. ManoramaOnline may also hire software consultants/developers to add/modify features on the ManoramaOnline website who are bound by strict confidentiality clauses regarding the safety and security of the data. |
| 68 | 68 | |
| 69 | | ## SECURITY |
| 69 | 22. You may refuse the use of third party data collection by selecting the appropriate settings on your browser, deleting your account or by switching off your profile. |
| 70 | 70 | |
| 71 | | Malayala Manorama uses commercially reasonable administrative, technical, personnel and physical measures to safeguard user information in its possession against loss, theft and unauthorized use, disclosure or modification. |
| 71 | 23. There are also a number of places on our Website where you may access third party websites that do not operate under this Privacy Policy and that we do not control. Such third party websites may collect your Personal Data. We recommend that you consult the privacy policy of all third party websites that you visit. |
| 72 | 72 | |
| 73 | | ## ACCESS, REMEDIES AND COMPLIANCE |
| 73 | 24. Our Website interfaces with social media sites such as Facebook, Instagram, Linkedin and others. If you choose to "like" or "share" information from our Website through these services, you should review the privacy policy of the relevant service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to our Website with other Personal Data. |
| 74 | 74 | |
| 75 | | To cancel your account, email customersupport@mm.co.in, subject, "Delete My Account" and include the email address that you registered your account with (if different from the email address you're sending the email from). Remember that even after you cancel your account, copies of some information from your account may remain viewable in some circumstances - where, for example, you have shared information with a third-party application or web site. We may also retain backup information related to your account on our servers for some time after cancelation for fraud detection or to comply with applicable law or our internal security policies. Because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines. |
| 75 | 25. In order to promote our products and services to you, we may also provide a hash of your email address to third parties, such as Facebook, in order to better target our advertising to you, by using products. A comparison of your hashed email address will only be for the purpose of promoting our goods and services to you and will not be used by that third party for any other purpose. The comparison of the hash of your email address will not be used to identify you or your email address, and no further information about you will be provided by us to that third party. |
| 76 | 76 | |
| 77 | | ## CONTACT US |
| 77 | 26. Website may use third party services like Evolok support in audience segmentation based on user data captured / machine learned for targeting ads, content & implementing subscription protocols. The scope of captured data (metrics) may include collection of geographic, demographic, social, behavioral & ; transaction data of users. |
| 78 | 78 | |
| 79 | | If you have questions about this Privacy Policy, please contact Malayala Manorama at: |
| 79 | 27. Third party service providers like Google may use their own audience identification signals for re-targeting ads to specific set of audience. Website may pass first party user data to ad servers using custom parameters. |
| 80 | 80 | |
| 81 | | Email: [customersupport@mm.co.in](mailto:customersupport@mm.co.in) |
| 81 | 28. Electronic forms & activity trackers may be used to collect user data. |
| 82 | 82 | |
| 83 | | Address: |
| 83 | 29. Purposes of collecting, holding, using and disclosing Personal Data (a) Collect from you Where it is reasonable or practical to do so we will only collect Personal Data about you from you directly through electronic forms, activity tracking and via email solicitation. In the event of any data collected through an intermediary, the primary contact detail, email or the phone number is validated before the profile is made active. (b) Purposes of collecting Personal Data We will only collect Personal Data that is reasonably necessary for: (i) enabling us to process your application for membership and enabling us to provide services to you (including creating your publicly viewable profile, allowing members to search for suitable matches and providing mechanisms for communication between members); (ii) our internal research and statistical purposes (including market segmentation and customer value analysis); (iii) enabling us to forward to you other information or material which we believe may be of interest to you; (iv) enabling a payment processor to process payments that you make to us. We use payment gateways namely Razorpay and Techprocess/ Ingenico for processing payments; and (v) any other purpose specified in our Website Terms of Use available on our Website. The above five purposes are hereinafter collectively referred to as the "Primary Purpose". (c) Use and disclosure of Personal Data Use of Personal Data for the Primary Purpose will include the use of Personal Data in automated decision-making processes. We will use or disclose Personal Data about you only, where:(i) you would reasonably expect us to use or disclose the Personal Data for such activity; or (ii) you have consented to the use or disclosure for the activity; or (iii) the use or disclosure of the Personal Data is required or authorized under law, regulation or court order. (d) Holding of Personal Data We will use best practice processes and take all reasonable steps to protect Personal Data that we hold from: (i) misuse, interference, and loss; and(ii) unauthorized access, modification, or disclosure. (e) International transfers:- (i) Any profile information that you have provided to us will be publicly viewable on your profile, irrespective of the location of the viewer. By creating a profile you acknowledge that overseas recipients will be able to view your profile. (ii)In order to provide customer support, perform back office functions, perform fraud prevention tasks, or provide services to you, we may need to allow our staff or suppliers (who may be located or whose resources may be located other than your country of residence) to access your profile information, billing information or other Personal Data that you have supplied. (iii) We have implemented security measures to protect the security of your Personal Data. However, as with any transfer of data, there are still risks of data breaches. There may be instances where your Personal Data is transferred to third party countries and international organizations. Such transfers are necessary in order for us to perform our obligations set out in our Website Terms of Use and for us to deliver our services to you. (iv) By providing your Personal Data and Sensitive Personal Data you are explicitly consenting to the international transfer and processing of such data in accordance with this Privacy Policy, in full and informed knowledge of the risks associated with such transfers and processing. (v)You may withdraw your consent at any time by sending an email with your instructions to our Data Protection Officer. However, this may affect or limit your ability to use the Website and its services. (f) Unsolicited information: If we collect Personal Data which we have not sought or requested about you, and if we determine we are legally permitted to collect that information, we will deal with that information in accordance with the terms of this Privacy Policy. In all other circumstances, we will destroy or de-identify the relevant Personal Data as soon as practicable, where it is lawful and reasonable to do so. (g) Information not confidential: Any material or information provided by you for inclusion in any member profile will be treated as non-confidential and non-proprietary. We may use such material or information without restriction. Specifically, we will use such material or information (including any profile information, photographs, video or audio recordings) that you have provided to us in order to copy your profile into any other relevant website owned and operated by us. Any such material or information provided by you will be made available for other members or users of the Website to read. (h) Communication: We reserve the right to send SMS/Whatapp/electronic mail to you regarding recommended profile matches, notification alerts of activity such as interest alerts or message alerts, promotions or offers, changes or additions to our services, or any products and services of our affiliated businesses. For sending transactional or communication SMS's, we have availed the services of SMS Country for the purpose of updating our users/subscribers about the transactions they carried out. If you are a member of our Website, you may manage your email preferences by using the settings on the "My Account - Edit Profile" page to customize what type of email communications you wish to receive. All calls made to Website / ManoramaOnline will be recorded. Where call recording facilities are being used, Website will inform the caller that their call is being monitored/recorded for quality/training purposes so that the caller has the opportunity to give consent by continuing with the call or refuse consent by terminating the call. Where calls are made for amendment of details in a profile, the Website may ask for non-financial personal information to authenticate the caller. Under normal circumstances, a call will not be retrieved or monitored unless: it is necessary to investigate a complaint it is part of a management 'spot check' that customer service standards are being met. there is a threat to the health and safety of staff or for the prevention or detection of crime. it is necessary to check compliance with regulatory procedures. it will aid standards in call handling, through use in training of Website staff. Personal data collected in the course of recording activities will be processed fairly and lawfully in accordance with data protection law. It will be: adequate, relevant and not excessive used for the purpose(s) stated in this policy only and not used for any other purposes accessible only to managerial staff after securing permission from the System Administrator. treated confidentially stored securely not kept for longer than necessary and will be securely destroyed once the issue(s) in question have been resolved. The recordings shall be stored securely, with access to the recordings controlled and managed by one individual. Recordings of calls will be stored securely and deleted after one year of recording unless required to be kept for a longer time under govt regulations. Access to call recordings will be given to System Administrator for the purposes listed above. Browsing of recordings without any valid reason is not permitted. Every user of the Website has the right to be provided with the information that the Website stores about such user. . This includes recorded telephone calls. Therefore, the recordings will be stored in such a way to enable the retrieval of information relating to one or more individuals as easily as possible. The Website will not call any person and ask for personal details and if any such call is received by the user from any person claiming to be from the Website such request for information should be ignored and such calldisconnected at the earliest. The Website shall not be responsible for any data shared over such calls received by users from persons claiming to represent the Website. |
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| 85 | | The Malayala Manorama Co. (P) Ltd. |
| 85 | 30. We maintain administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, loss, modification, disclosure, and any form of unlawful processing of personal data in our custody and control, and our service providers are bound to maintain similar safeguards. These measures also aim at preventing unnecessary collection and further processing of personal data. Keeping in mind the security of our users, the ManoramaOnline application and database are hosted on servers of Amazon AWS. The said facility is a certified data centre meeting highest level of standards in storing personal data. You can get more information about AWS at (https://aws.amazon.com/compliance/cispe/ and https://aws.amazon.com/compliance/data-privacy-faq/). Further to ensure fastest content delivery to the User, we have availed the services of Akamai. (https://www.akamai.com/uk/en/privacy-policies/privacy-statement.jsp https://www.akamai.com/uk/en/privacy-policies/). Although we take appropriate measures to safeguard the personal data in our custody and control, and we require similar safeguarding measures from our service providers, we need you to understand that we are unable to guarantee the security of your personal data. To provide you with an increased level of security online, access to your personal data on our websites may be protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any communication. In the unlikely event that there is a serious data breach that is likely to impact upon your rights and freedoms we will notify you of that breach. |
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| 87 | | P.B No. 26 |
| 87 | 31. We will take reasonable steps to accurately record the personal data that you provide to us and any subsequent updates. We will retain your personal data as long as necessary to fulfill the purposes for which it was collected. Thereafter, we will either delete your personal data or de-identify it so that it cannot be attributed to your identity. Please note that we may continue to retain personal data for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. You have the right to request that we delete your personal data by sending an email with your instructions, to our Data Protection Officer. |
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| 89 | | K.K Road, Kottayam. |
| 89 | 32. If certain information has been provided to third parties in accordance with this Privacy Policy, retention of that information will be subject to the policies of the relevant third party. |
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| 91 | | Kerala - 686001 |
| 91 | 33. We will provide you with access upon request to the Personal Data held by us in relation to you except to the extent that: (i) giving access would be unlawful; or (ii) denying access is required or authorized by or under a relevant law, regulation or court order. To request access to your Personal Data, you may send an email with your instructions to our Data Protection Officer. Following your request, we will contact you within one (1) month from the date of receipt of your request and provide you with the Personal Data requested, unless we have determined that some reason or obligation exists requiring us to withhold access to the Personal Data. |
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| 93 | 34. We do not sell your Personal Data to any third parties. Unless specifically referred to in this Privacy Policy, we also do not disclose your Personal Data to any third parties for other business purposes. However, notwithstanding this, you may at any time request, by sending an email with your instructions to our Data Protection Officer, that we provide confirmation that your Personal Data has not been sold to a third party, or to request details of any third party to which your Personal Data has been sold or disclosed for business purposes. |
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| 95 | 35. Insofar as it does not adversely affect the rights and freedoms of others and where you have communicated a request to us: (i) where we have employed an automated means to process your Personal Data, we will provide you with a copy of such Personal Data in a structured, commonly used and machine-readable format; and (ii) At your request, where technically feasible, we will transmit your personal data directly to another data holder. |
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| 97 | 36. Where providing you access to your Personal Data would reveal commercially sensitive information, we are unable to give you access to that information. However, we will provide you with the reasoning behind our determination. |
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| 99 | 37. Where we cannot directly provide you with access to your Personal Data we may, if it is reasonable, engage the services of an intermediary to do so. |
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| 101 | 38. It is your responsibility to ensure that the information you provide to us is accurate and to update your Personal Data as soon as there is any change in the information provided to us. If for any reason you are unable to correct any Personal Data held by us, please contact us, by sending an email with your instructions to our Data Protection Officer. If after receiving your request we choose not to correct your information, we will notify you within one month of the reason of our refusal and the mechanisms available to you to object to our refusal. |
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| 103 | 39. If you wish to have your Personal Data erased, please communicate your request to us by sending an email with your instructions to our Data Protection Officer. The only circumstances in which we will not take reasonable steps to erase your Personal Data are where we need to keep it in accordance with another provision of this Privacy Policy, or for any other legal reason. However, our deleting of your Personal Data may result in the deletion of your account with our Website and will mean you are unable to access our Services. |
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| 105 | 40. If we correct or erase Personal Data about you that we previously disclosed to a third party in accordance with our Privacy Policy, we will take reasonable steps to notify the third party of the correction or erasure and to request that they do the same. |
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| 107 | 41. If at any time we refuse or deny you access to your Personal Data, or refuse to correct or erase your Personal Data, we will provide you with reasons for such denial or refusal. |
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| 109 | 42. You may request that we limit or restrict the manner in which we deal with and process your Personal Data, by sending an email with your instructions to our Data Protection Officer, in which case we will only process your Personal Data: with your consent; for the establishment, exercise or defense of legal claims against us; or for the protection of the rights of another person. |
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| 111 | 43. Access to, erasure and rectification of your Personal Data, including any communications related thereto, will generally be provided free of charge. Where your requests are manifestly unfounded or excessive in nature (particularly due to repetitiveness) we may charge you a reasonable fee for providing the information or communication, or taking the action requested. Where your requests are manifestly unfounded or excessive in nature, we may also refuse your request. |
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| 113 | 44. If it becomes necessary for us to process your Personal Data without your consent for reasons of: (i) performing a task in the public interest; (ii) the exercise of an official authority that has been vested in us; or (iii) where it is in our legitimate interests or the legitimate interests of a third party to do so; you will have the right to object to such use. |
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| 115 | 45. If you object to our use of your Personal Data we will refrain from using your Personal Data unless compelling legitimate grounds exist for us to use that Personal Data, or for the establishment, exercise or defense of legal claims. |
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| 117 | 46. If we have collected your Personal Data in accordance with this Privacy Policy and elect to use such Personal Data for the purposes of direct marketing (to which you have consented), you still have the right to object at any time to such use. |
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| 119 | 47. Upon receiving an objection to use of your Personal Data for purposes of direct marketing, we will, as soon as is reasonably practical, cease using your Personal Data for the purposes of direct marketing. |
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| 121 | 48. If you believe that we have used or disclosed your Personal Data in a manner which is contrary to this Privacy Policy or that otherwise breaches an applicable law, then you should send an email to our Data Protection Officer. We will notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with the steps taken by us. |