This document (“Privacy Policy”) is published by virtue of the legal requirement under the provisions of the Information Technology Act, 2000 that require intermediaries to publish the rules and regulations, privacy policy and terms for access or usage of their website/mobile app and is primarily governed by Rule 3 (1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
Commitment
CAPTRUST intends to protect the privacy of its users and members on its Website and the privacy of the data provided by them to CAPTRUST from time to time. For the purpose of this Privacy Policy, Website means and includes the website (www.captrust.in).
The privacy of our Website users, whether you are our former or existing registered user or merely a visitor to our Website, is important to us and we are strongly committed to your right to privacy and to keeping your personal and other information secure. We encourage you to read our privacy statement to understand what types of personally identifiable information we collect and how we use this information.
What type of information does CAPTRUST.in collect from you?
Personal Information
For the purpose of providing you services, we require you to enrol yourself on our Website and get yourself registered.
- If you choose to become a registered member or applicant of our Website, you are required to share your name, e-mail address, gender, date of birth, postal address, phone number, a unique login name, password, password validation, income tax details, marital status, family details, business information and other details shared via application form or via email or via any other medium (Personally Identifiable Information).
- CAPTRUST may also collect other information specific to provide you service each time such as name, bank statements, KYC documents, personal details, business details, income tax details, marital status, family details and other information via application form or via email or via any other electronic medium or via printed form (Service Information). All Personally Identifiable Information and Service Information shall be collectively known as “Information”.
- In addition to the Information made available to us, we may seek your consent and request access to your email account. On receipt of the consent, CAPTRUST may access the said account for collecting information like bank statement details, and such other financial and transactional information to process your loan application or provide you products/services. CAPTRUST’s access to the email account(s) is authorized through the email provider’s access mechanism. If you permit CAPTRUST to access your bank statements, CAPTRUST will securely store bank account details. We only read emails from financial service providers and do not open, read or access any personal e-mails. We hereby confirm that we do not access any other personal information. For the sake of clarity, CAPTRUST employs automated processes for accessing and analysing information provided by you; where we may need to use our algorithm to access a password-protected document utilizing information provided by you.
- Additionally, CAPTRUST collects your other details including but not limited to your feedback, suggestions, views, opinions, etc. shared on our Website (User Information) that may be shared/volunteered by you on our discussion forums or other pages of our Website. Such information being in the public domain is available for access to all our Website’s users and visitors. You are advised to exercise discretion before you make such details public, as such information is vulnerable to misuse and can be easily misused. CAPTRUST in this regard fully disclaims any liability (ies) or claim(s), which may arise by use/misuse of User Information shared by you, by any third party or any party not known to CAPTRUST.
- Information exchanged by you with CAPTRUST in the form of written communication, responses to emails, feedback required from you, participation in discussions, etc. is handled with confidentiality.
Non-Personal Information
CAPTRUST also collects certain other information from you on your visit to our Website such as information about your operating system, browser type, the URL of the previous website you visited, list of third-party applications being used by you, your internet service provider and your IP Address (Non-personal Information). This information cannot be easily used to personally identify you. We use Non-personal Information for the purposes including but not limited to troubleshoot connection problems, administer the Website, analyze trends in the market, gather demographic information, to ascertain how our visitors use our Website, including information relating to the frequency of visits to our Website, average length of visits, pages viewed during a visit, ensuring compliance with the applicable law, co-operating with law enforcement activities, etc. This information is used to improve the Website content and performance. You also agree that CAPTRUST may gather usage statistics and usage data from your use of our Website to evaluate your use of our products/services, to improve our products/services, Website content and to ensure that you are complying with the terms of the applicable agreements between you and CAPTRUST. The statistics and data collected may or may not be aggregated. These statistics contain no information that can distinctly identify you.
We may in future also share this information with third party service providers or third party advertisers to measure the overall effectiveness of our online advertising, content, programming and for other bonafide purpose, as we may desire. By usage of our Website you expressly permit CAPTRUST to access such information for one or more purposes deemed fit by CAPTRUST.
Cookies
Similar to other commercial web sites, our Website utilizes standard technology called “Cookies” and Web server logs to collect information about how our Website is used. Cookies are small pieces of information that are stored by your browser on your device’s hard drive. Cookies are only read by the server that places them, and are unable to inter alia run programs on your device, plant viruses or harvest your personal information. Cookies allow Web servers to recognize your device each time you return to our Website including the date and time of visits, the pages viewed, time spent at our Website, and the websites visited just before and just after our Website, verify your registration or password information (in case of registered users) during a particular session so that you do not have to input your password multiple times as you navigate the site and suggest products or services that may interest you. This information is collected on an aggregate basis. None of this information is associated with you as an individual.
Most web browsers automatically accept cookies. By changing the options on your web browser or using certain software programs, you can control how and whether cookies will be accepted by your browser. CAPTRUST understands and supports your right to block any unwanted Internet activity, especially that of unscrupulous websites. However, blocking CAPTRUST cookies may disable certain features on our Website and may make it impossible for you to use certain services available on our Website.
Session Data
We automatically log generic information about your device’s connection to the Internet, which we call “session data”, that is anonymous and not linked to any personal information. Session data consists of information such as the IP address, operating system, type of browser software being used by you and the activities conducted by you on our Website. An IP address is a number that lets device attached to the Internet, such as our web servers, know where to send data back to the user, such as the pages of the site the user wishes to view. We collect session data because it helps us analyze things such as the items visitors are likely to click on most, the manner in which visitors click preferences on our Website, number of visitors surfing to various pages on the Website, time spent by the visitors on our Website and frequency of their visit. It also helps us diagnose problems with our servers and lets us better administer our systems. Although such information does not identify any visitor personally, it is possible to determine from an IP address a visitor’s Internet Service Provider (ISP), and the approximate geographic location of his or her point of connectivity.
Sharing of Information
CAPTRUST may share your Information, including the bureau reports, with its service providers, affiliate(s), agents, partners and such other third parties for the purposes of (i) providing the services and to perform the functions on your behalf or on behalf of CAPTRUST; (ii) marketing new products and services by CAPTRUST or by any of its affiliate(s), service partners and third parties; or (iii) marketing of services provided by such third parties, affiliates and service partners of CAPTRUST. It is hereby expressly declared that CAPTRUST shall not be responsible for use of your Information by such third parties and service partners and their privacy policies.
Third Party Products and Services
There are services and/or products offered by third parties on the Website. If you choose to apply for these third-party products and/or services, then their use of your Information shall be governed by their privacy policies and CAPTRUST shall not be responsible for their use of your Information and their privacy policies.
CAPTRUST shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such site or resource.
New Products and Services
CAPTRUST may use your Information to intimate you for any new products, services, offers and/or promotions being offered by CAPTRUST or any of its affiliate(s), third partners or service partners.
Other
We may from time to time add or enhance products/services available on our Website. To the extent these products/services are provided to and used by you, we will use the information you provide in this regard to facilitate the products/service requested. For example, if you email us with a question, we will use your email address, name, nature of the question, etc. to respond to your question. We may also store and publish such information to assist us in making the Website better and easier to use.
CAPTRUST’s use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
Promotional Initiatives
CAPTRUST may have presence on social networking websites including but not limited to LinkedIn, Facebook, Twitter, YouTube and blogs which are promotional and business initiatives to connect to a larger group of people. The domain links contained therein may either direct you to our Website or request your participation by way of feedback, suggestions. CAPTRUST in this regard fully disclaims any liability (ies) or claim(s), which may arise by use/misuse of your feedback, suggestions, views, etc. on any of the aforementioned networking websites or blogs, by any third party whether or not known to CAPTRUST.
Links to Other Sites
Our Website may contain links to other websites. If you click on a third-party link, you will be directed to that website. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the privacy policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Does CAPTRUST protect my Personal Information?
CAPTRUST is committed to protecting the privacy and the confidentiality of your Personal Information. Whenever CAPTRUST obtains Information from you, our Website uses commercially reasonable efforts and general industry standards to protect it from any unauthorized access or disclosure. CAPTRUST uses its best endeavours to maintain physical, electronic and procedural safeguards that aim to protect your information against loss, misuse, damage, modification, and unauthorized access or disclosure. However, CAPTRUST assumes no liability whatsoever for any disclosure of Information to any third party(ies) and/ or service partners for providing any services to you by such third parties and/ or service partners. CAPTRUST disclaims any liability for the use of your Information by such third party(ies) and/or service partners and their privacy policies.
Does CAPTRUST secure the content its users post from other users?
The content that you store, post, or transmit on or through our Website, may be accessed by other users (registered or unregistered), including people that you do not know. The content/images that you post/share on our Website may be prone to misuse by a party not known to you. CAPTRUST in this regard fully disclaims any liability (ies) or claim(s), which may arise by use/misuse of such content, by any third party or any party not known to CAPTRUST. We suggest that you exercise care and caution in communicating with other users and only disclose your information to other users that you know to be trustworthy. You should not assume that your content will be kept private.
How does CAPTRUST use the information that it collects?
Information shared by you is used by us and/or authorized third parties/service partners/affiliate(s) to support your interaction with us, to offer you services in the best possible manner and to contact you again about other services and products that we and/or authorized third parties/service partners/affiliate(s) offer. By submitting your Information to CAPTRUST, you expressly acknowledge and consent to CAPTRUST to use such Information and to process the same in a manner deemed fit by CAPTRUST. This may involve conducting data analysis, research based on reviews about deals, transfer of your Information to third party experts for the purpose of outsourcing services offered to you by CAPTRUST, transfer your Information to third parties/ service partners for providing you services offered by such third parties and service partners etc.
What security precautions are in place to protect against the loss, misuse, or alteration of your information?
CAPTRUST makes every reasonable effort to preserve the privacy and confidentiality of your information shared with us. We implement standard measures to protect against unauthorized access to and unlawful interception of Personal Information. However, no Internet website can fully eliminate security risks.
We reserve the right to disclose information shared by you without your consent (express or implied) and without any liabilities to you when required or permitted by law and we have a good-faith belief that (i) such action is necessary to comply with an appropriate law enforcement investigation, current judicial proceeding, a court order or legal process served on us or (ii) to conform to the legal requirements, compliance/reporting to administrative and judicial authorities, as may be required (iii) protect and defend the rights or property of the website owners of CAPTRUST, or the users of CAPTRUST, (iv) person(s) or company (ies) who provide certain support services to us, or (v) person(s) or company (ies) who share certain responsibilities/obligations of CAPTRUST and (vi) to third parties/ service partners for providing you services offered by such third parties and service partners. Further, we reserve the right to disclose Information shared by you without your consent with entities engaged in providing the credit scores or credit information related services like CIBIL, etc.
I have more questions about privacy policy
If you have any questions about this Privacy Policy, the practices of this Website, or your dealings with this Website, please contact us at grievance@CAPTRUST.com.
Will CAPTRUST change privacy policy in the future?
This policy provides a general statement of the ways in which CAPTRUST aims to protect your information. You may, however, in connection with specific products or services offered by CAPTRUST, be provided with privacy policies or statements that substitute or supplement this policy. The terms and conditions of this Privacy Policy may be changed from time to time, without your consent (express or implied) to reflect changes in our practices concerning the collection and use of your information. The revised Privacy Policy will be effective immediately upon posting to our Website unless otherwise mentioned. This version of the policy is effective from 22nd July, 2021. The revised Privacy Policy shall bind you and it is your sole responsibility to check the same from time to time. You acknowledge that no knowledge of the revised Privacy Policy shall not be a defence in any proceedings with regard to the Privacy Policy.
Your Consent
By accessing our Website and using it on a continued basis, you expressly consent and confirm to CAPTRUST collecting, maintaining, using, processing and disclosing your Personal Information and other information in accordance with this Privacy Policy.
I have a complaint/concern
In accordance with the relevant provisions of the Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Grievance Officer who can be contacted with respect to any complaints or concerns including those pertaining to breach of CAPTRUST’s Terms of Use, Privacy Policy and other polices or questions are published as under: