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Privacy Policy

We value the trust you place in us and recognize the importance of information privacy. This Privacy Policy describes how Scrawlr Development Inc (collectively referred to as "Scrawlr", "us", "our" or "we"), its affiliates and group companies, who provides a social media platform that allows individuals to create, share, discover, and interact with content (collectively referred to as "Services") to collect, use, share or otherwise process your personal information through the website www.scrawlr.com and its sub-domains; mobile application, browser extension and any other related application (hereinafter, collectively referred to as "Platform").
By visiting the Platform, providing your information or using our Services offered on the Platform, you expressly agree to be bound by the terms and conditions of this Privacy Policy, the Terms of Use and any applicable Services' terms and conditions. Your personal information will be primarily stored and processed in Canada and may have data protection laws that are different from those that apply in the country in which you are located. By using the Platform and our Services, you consent to the transfer of information outside of your country of residence. If you do not agree to the Terms of Use or terms of this Privacy Policy, please refrain from accessing our Platform or using our Services.
We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.

Collection

We may collect your personal information directly from you (e.g., when you create an account); in course of our relationship with you (e.g., if you contact us); when you make your personal information public (e.g., if you make a public post about yourself); when you download, install or use any of our Services. We may also receive information about you from third parties (e.g., Google SSO). We may also create information about you, such as records of your interactions with us or combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities. Scrawlr is not responsible for personal information you volunteer about yourself in the public domains. This Privacy Policy does not cover the practices of third parties who may provide information about you to Scrawlr. Some of the information that we may collect includes but is not limited to:

  • Information provided to us during sign-up/registering or using our Platform such as your username or login details; e-mail address

  • Demographic information such as gender, nationality, age/date of birth

  • Location information that describes the precise geographic location of your device

  • Data either created by you or by a third party and which you wish to store on our servers such as image files, documents etc.

  • Any other information that you may share with us or collected from you while you visit, access or use our Platform or contact us for query resolution (e.g., the type of device you are using, I.P address, the internet service provider, browsing history, device identity, mobile operator, WI FI Connection, service set identifier (“SSID"), International Mobile Subscriber Identity (“IMSI"), and International Mobile Equipment Identity etc.)

Use

We use your personal information to provide the Services you request. Some of purposes for which we use your information are:

  • Provide you with the requested services, such as creating a user account, and communicating with you about updates to the Platform

  • Send verification emails to authorize your account

  • Send you marketing communications about products and services that may be relevant to you

  • Maintain and improve the Platform, tailor the user experience, and for internal training

  • Protect your information and the Platform

  • Manage our IT systems i.e., identification and mitigation of fraudulent activity; compliance with applicable law; and improving our Services

  • Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands

We will ask for your permission wherever required to allow us access to SMS, contacts in your directory, camera, photo gallery, location and device information: (i) to send communication regarding your orders or other products and services; (ii) enhance your experience on the platform and provide you access to the products and services offered on the Platform. You understand that your access to Services may be affected in the event permission is not provided to us. We will occasionally ask you to complete surveys conducted either by us or through a third- party market research agency. These surveys may ask you for personal information, contact information, gender, date of birth, demographic information (like pin code, age or income level) attributes such as your interests, household or lifestyle information, and other such information that you may choose to provide. The survey may involve collection of voice data or video recordings. Participation in these surveys is purely voluntary in nature. We use this data to tailor your experience at our Platform, providing you with content that we think you might be interested in and to display content according to your preferences. By sharing this information with us or by participating in such surveys, you consent us in processing your personal information.

Cookies

We use data collection devices such as "cookies" on certain pages of the Platform to help analyze our web page flow, measure promotional effectiveness, and promote trust and safety. "Cookies" are small files placed on your hard drive that assist us in providing our services. We store page views, clicks and search terms used for ad personalization targeting separately from your personal information. We can't identify you personally through the use of these cookies, but third parties who provide these cookies may be able to. We offer certain features that are only available through the use of a "cookie". We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline/delete our cookies if your browser permits, and you may be required to re-enter your password more frequently during a session. Additionally, you may encounter "cookies" or other similar devices on certain pages of the Platform that are placed by third parties. We do not control the use of cookies by third parties. We use cookies from third-party partners such as Google Analytics for marketing and analytical purposes. Google Analytics helps us understand how our customers use the site. You can read more about how Google uses your personal information here: https://www.google.com/intl/en/policies/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Services.

Lawful basis for processing your personal information

We may process your personal information where:

  • You have given your consent (this legal basis is only used in relation to processing that is entirely voluntary, it is not used for processing that is necessary for meeting our obligations, required under applicable law or for legitimate interests)

  • Processing is necessary for a contract between you and us or for legitimate interests

  • Processing is required by applicable law

  • Processing is necessary for prompt action, such as in events of medical emergencies, disasters, and breakdowns of law and order

  • Processing is necessary for reasonable purposes, such as whistleblowing, mergers and acquisitions etc.

  • Processing is necessary for legal purposes or where we have a valid and legitimate interest in processing.

Sharing

We may share/disclose your personal information internally with our group companies or with other third parties and affiliates to provide you access to products and services offered by them. These entities and affiliates may market to you as a result of such sharing unless you explicitly opt-out.
Some of the instances where we may share your personal information are:

  • With our data processors who provide storage and other related services to you on our behalf such as cloud service providers, payment gateways, customer service providers, survey distributors or any other third-party for the purposes of prevention, detection mitigation, and investigation of fraudulent or illegal activities related to our Services or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security, compliance with our legal obligations, enforcement of our user agreement, facilitate our marketing and advertising activities.

  • With your consent we may liaise with third party advertising service companies for online behavioural advertising or otherwise, and perform related services when you use our Services. Often, these third-party advertising companies employ cookies and other technologies to measure the effectiveness of websites, applications and to understand the usage behaviour of the user. We also engage third party providers to assist with the segmentation of this data.

  • With outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality.

  • With our group companies or affiliates who need to know or have access to such information in relation to provisioning of Services.

  • With government agencies or other authorized law enforcement agencies if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process.

  • With any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a transaction occur, that other business entity (or the new combined entity) will be required to follow this privacy policy with respect to your personal information.

  • We adhere to appropriate security measures to protect your personal information while we share with them for processing. Further, wherever applicable, we bind these third parties with appropriate agreements and require them to process your personal information only for specific purposes along with confidentiality and with appropriate security measures.

  • When you use a co-branded service (a service operated with a partner of Scrawlr), or register or otherwise provide information on a co-branded site, you grant us permission to pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services.

  • We may share your information with our partners such as your name, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine user information about you received from Scrawlr with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.

Due to the international nature of our business and in connection with the purposes set out in this Privacy Policy, we may share your personal information internationally with Scrawlr Group of companies and to other third parties located in countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. We would ensure appropriate security measures while we transfer these information.

Links to other sites

The scope of this Privacy Policy is limited to the Platform. Our Platform may provide links to other websites. If you are accessing any other third-party websites or applications, please refer to their respective privacy policies to understand how they process your personal information.

Security precautions

To protect your personal information from unauthorised access or disclosure, loss or misuse we have adopted reasonable security practices and procedures in line with industry standards. Whenever you change or access your account information, we offer the use of a secure server. The transmission of information is not completely secure for reasons beyond our control. We adopt industry standard security measures and keep updating our systems from time to time to protect your personal information against any hacking or virus dissemination. However, by using the Platform, the users accept the security implications of data transmission over the internet and the world wide web which cannot always be guaranteed as completely secure, and therefore, there would always remain certain inherent risks regarding use of the Platform. Users are responsible for ensuring the protection of login and password records for their account. We are not responsible for any breach of security occurring on a third-party platform that you may decide to transact with.

Data retention

We retain your personal information for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. Online data related to online behavioural advertising is kept by Scrawlr for not more than 365 days after which it will expire, subject to certain conditions. However, the 365 days period may commence again if the same user subsequently visits or interacts with an ad, email, the Services or a channel. We may retain data related to you if there is a legal obligation to retain the data; if required to comply with any applicable statutory or regulatory retention requirement by law; if we believe it may be necessary to prevent fraud or future abuse; to enable Scrawlr to exercise its legal rights and/or defend against legal claims; or for other legitimate purposes. We may continue to retain your data in anonymized form for analytical and research purposes.

Your rights

We take every reasonable step to ensure that your personal information that we process is accurate and, where necessary, kept up to date, and any of your personal information that we process that you inform us is inaccurate (having regard to the purposes for which they are processed) is erased or rectified. You may access, correct and update your personal information directly through the functionalities provided on the Platform. You may delete certain non-mandatory information or delete your user account by logging into our website and visiting profile and settings sections. You can also write to us at to assist you with these requests.

Consent

By visiting our Platform or by providing your information, you consent to the collection, use, storage, disclosure and otherwise processing of your information (including sensitive personal information) on the Platform in accordance with this Privacy Policy. If you disclose to us any personal information relating to other people, you represent that you have the authority to do so and to permit us to use and share the information in accordance with this Privacy Policy.
You, while providing your personal information over the Platform or any partner platforms or establishments, consent to us (including our other corporate entities, affiliates, partners, technology partners, marketing channels, business partners and other third parties) to contact you through SMS, instant messaging apps, call and/or e-mail for the purposes specified in this Privacy Policy.
You have an option to withdraw your consent that you have already provided by writing to us at . Please mention “for withdrawal of consent" in your subject line of your communication. We will verify such requests before acting on our request. Please note, however, that withdrawal of consent will not be retroactive and will be in accordance with the terms of this Privacy Policy, related terms of use and applicable laws. In the event you withdraw consent given to us under this Privacy Policy, may hamper your access to the Platform or restrict provision of our Services for which we consider such information to be necessary.

Choice/Opt-Out

We provide all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partners, and from us in general, after setting up an account. If you do not wish to receive promotional communications from us then please unsubscribe by clicking on the unsubscribe link in the email or write to us at .

Changes to this privacy policy

Please check our Privacy Policy periodically for changes. We may update this Privacy Policy to reflect changes to our information practices. We will alert you to significant changes by posting the date our Privacy Policy got last updated, placing a notice on our Platform, or by sending you an email when we are required to do so by applicable law. Your continued access to or use of any of the Services shall be deemed your acceptance of the Privacy Policy.

Contact us

If you have a query, concern, or complaint in relation to collection or usage of your personal information under this Privacy Policy, please contact us at .

Grievance Officer

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Attn: Grievance Officer
1820-999 W Hastings St, Vancouver, BC, V6C 2W2, Canada