Privacy Policy
1. INTRODUCTION
GOLPO KHURO Publications Private Limited is an entity registered in India. We are engaged in the business of providing, managing, operating and hosting a digital platform, under the brand GOLPO KHURO, that allows users to access and share audio content, including audiobooks, podcasts, etc. as well as literary content such as Pocket Novels across different languages. We are committed to ensuring that privacy of our clients, visitors, and other users of the website at https://www.golpokhuro.com or any other website, mobile version of the Website or mobile application of GOLPO KHURO Private Limited or any of its affiliates or licensees (collectively, the “Website”) is always respected. In this Policy, “GOLPO KHURO”, “we”, or “us” refers to GOLPO KHURO Private Limited and its affiliates, successors and assigns, and “you” refers to a user who has provided any information including Personal Information (as defined below) and using any features therein.
The protection and security of your Personal Information and Usage Information (as defined below) is one of our top priorities. This Privacy Policy discloses and explains how we collect, use, share and protect Personal Information, Usage Information or any other information about you. We also provide information regarding how you can access and update your Personal Information and make certain choices about how your Personal Information is used by us. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources.
This Privacy Policy explains what information of yours will be collected by GOLPO KHURO when you access the Website, how the information will be used, and how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy. The use of information collected through our Website shall be limited to the purposes under this Privacy Policy.
2. INFORMATION COLLECTION BY GOLPO KHURO
2.1 Data Controller and Data Processor:
GOLPO KHURO controls, collects, owns and directs the use of the Personal Information and Usage Information on its Website and GOLPO KHURO is the data controller and data processor as regards the Personal Information and Usage Information collected on its Website. For any queries regarding this Privacy Policy and the collection and use of data collected or processed under this Privacy Policy, you may write to us at the e-mail address mentioned under Section 14 (Grievance Redressal)
2.2 Legal basis for collection and processing of Personal/Usage Information:
The legal basis for the collection and processing of any information collected and processed by GOLPO KHURO including the Personal Information is (i) your consent at the time of providing the Personal Information; (ii) where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Website). In some cases, we may also have a legal obligation to collect information about you, or may otherwise need the information to protect your vital interests or those of another person. We may also process information to comply with a legal requirement or to perform a contract.
2.3 Basic Information
GOLPO KHURO may ask you to provide certain categories of information such as personal information, which is information that could reasonably be used to identify you personally, such as your name, company address, e-mail address, date of birth and mobile number (“Personal Information”), when you access the Website, in order to provide you with the relevant information requested.
Additionally, we may collect this information through various forms and in various places through the Website, including when you first register with us, when you create a transaction, when you contact us, when you update your information or from time to time or when you otherwise interact with us. GOLPO KHURO may include registration, surveys, and other online forms where users will need to provide Personal Information.
2.4 Additional Information
2.4.1 Cookies:
GOLPO KHURO may use standard “cookie” browser application features to collect and understand website usability trends. Cookies are text files that we may place in your computer browser to store your preferences. Cookies are used to record various aspects of your visit and assist us in providing you with uninterrupted products or services. One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content. However, no personal information identifying the user is collected nor any data capture mechanism is employed. The user may change browser settings to accept or reject cookies on personal preference. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify the browser setting to decline cookies if you so prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Website that may depend on cookies. If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated. We process and keep all data for our own use and, if you wish to opt-out from tracking by GOLPO KHURO you can do so by mailing us at the E-mail ID mentioned in Section 18.2 (Customer Services).
2.4.2 Information Collected Automatically:
In addition to any Personal Information or other information that you choose to submit to us, we may use a variety of technologies that automatically (or passively) collect certain information whenever you access the Website (“Usage Information”). This Usage Information may include the browser you are using, the URL that referred you to our Website, and other information. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information with your Personal Information, we will treat it as Personal Information and the conditions relating to Personal Information under this Privacy Policy will be followed. Traffic data, while anonymous, is gathered and analysed for business needs.
2.4.3 Information Third Parties Provide About You:
We may, from time to time, supplement the information we collect about you through our Website with outside records from third parties obtained rightfully in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to use such of our products or services that we believe may be of interest to you. We may combine the information we receive from such third-party sources with information we collect through the Website or through independent research conducted by GOLPO KHURO, with your consent. In these cases, we will apply this Privacy Policy to any Personal Information received, unless otherwise provided. We may process such information received from third parties for the legitimate commercial purposes or to enter into contractual obligations with you or to fulfil certain contractual obligations or where you have requested third parties to provide information about yourself to us
2.5 Processing of Data:
GOLPO KHURO may also process any Personal Information or Usage Information collected from you for legitimate commercial purposes including to provide you with the requisite information requested. A list of uses of the Personal Information and Usage Information collected is provided in Section 3 of this Policy (Use of Information Collected).
GOLPO KHURO implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals such as (i) only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible; (ii) using secure servers to store your information; (iii) verifying the identity of any individual who requests access to information prior to granting them access to information; and (iv) using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.
2.6 Right of a user in relation to data submitted:
Any user who has submitted Personal Information on the Website has the right to (i) access, correct, or delete such Personal Information subject to us successfully verifying your identity; (ii) object to us processing your Personal Information on legitimate grounds; (iii) to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information; (iv) opting out of receiving any promotional or marketing material by clicking on the “Unsubscribe” button or by contacting us at the E-mail ID mentioned in Section 18.2 (Customer Services). Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent; (v) right to have the Personal Information transferred to another data controller; and (vi) lodge a complaint with a supervisory authority, of an alleged infringement of applicable data protection laws. Any request received by us by the user in relation to the aforesaid shall be acknowledged by us within 72 (seventy-two) business hours.
3. USE OF INFORMATION COLLECTED
3.1 Business Purposes:
GOLPO KHURO does not share any Personal Information with any third party without your consent, except when directed by the law. GOLPO KHURO can use this data to verify user identity in line with engagement initiated by the user. We will communicate with you using the contact information provided by you in order to respond to any queries that you may have and to provide any information that you may request regarding the Products or services. We may communicate with you by writing, physically, via email, telephone, SMS or via notifications on your mobile device. We may also send strictly product or service-related announcements to you periodically and when it is necessary to do so. For instance, if our products or services are temporarily suspended for maintenance, we might send you an email, text message, flash notification or telephone call. If you do not wish to receive such alerts, you have the option to unsubscribe from such emails by writing to us at the E-mail ID mentioned in Section 18.2(Customer Services).
We may use Personal Information or Usage Information collected through the Website in the following ways:
to operate and improve our Website and the tools associated with the Website;
to create aggregated and anonymized information to determine which Website features are most popular and useful to users, and for other statistical analyses;
to prevent, discover and investigate violations of this Privacy Policy or the Terms and Conditions, and to investigate fraud or other matters;
To customize the content or the products or services on the Website for you, or the communications sent to you through the Website.
To help provide you with the products or services on the Website;
To observe, improve and administer the quality of products or services on the Website;
To analyze how the Website is used, diagnose technical problems;
Remember the basic information provided by you for effective access;
To confirm your identity in order to determine your eligibility to use the Website and avail of the products or services;
To notify you about any changes to the Website;
To enable GOLPO KHURO to comply with its legal and regulatory obligations;
For the purpose of sending administrative notices, products or service-related alerts and other similar communication with a view to optimizing the efficiency of the Website;
Doing market research, troubleshooting, protection against error, project planning, fraud and other criminal activity; and
To reinforce GOLPO KHURO’s Terms of Use available at - https://www.golpokhuro.com/terms-and-conditions
3.2 Anonymous:
We may share non-Personal Information, such as aggregated user statistics and log data, with our business partners for industry analysis, demographic profiling, to deliver targeted advertising about other products or products or services, or for other business purposes. This information is solely used to analyze the company websites and understand usage statistics, as mentioned above, is anonymous. The company may share this data with its business partners on an anonymous basis. We do not sell, share, rent or trade the information we have collected about you, including Personal Information, other than as disclosed within this Privacy Policy or at the time you provide your information. We do not share your Personal Information with third parties for those third parties' direct marketing purposes unless you consent to such sharing at the time you provide your Personal Information.
3.3 Administrative and Legal Reasons:
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of GOLPO KHURO, our products or services, the Website or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without notice to you.
3.4 Business Transfer:
We may share your information, including your Personal Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Website or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process. You will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. We will endeavour that the transferee who is the recipient of Personal Information and Usage Information commits to privacy measures that are substantially similar to the measures under this privacy policy.
4. THIRD-PARTY CONTENT AND LINKS TO THIRD-PARTY PRODUCTS OR SERVICES
We do not include or offer third-party products or services on our website.
5. DATA TRANSFER
Your information may be stored and processed in India or any other country in which GOLPO KHURO or its subsidiaries, affiliates or products or service providers maintain facilities. GOLPO KHURO may transfer information that we collect about you, including Personal Information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. We have taken appropriate safeguards to require that your information will remain protected in accordance with this Privacy Policy.
6. DATA RETENTION
Your information will be retained with GOLPO KHURO as long as GOLPO KHURO needs it to provide products or services to you. If you wish to cancel your account or request that GOLPO KHURO no longer uses your information to provide products or services, you may contact us at the E-mail ID mentioned in Section 18.2 (Customer Services.). GOLPO KHURO will promptly delete the information as requested. GOLPO KHURO will retain and use your information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes. When GOLPO KHURO has no ongoing legitimate business need to process your information, we will either delete or anonymize it.
7. CHILDREN
GOLPO KHURO’s Terms of Use available at https://www.golpokhuro.com/terms-and-conditions contain restrictions on how minors can access and use the Website. You are required to carefully read and comply with the same.
Any collection of Personal Information of children is intended to comply with applicable law in each relevant jurisdiction, including the Children’s Online Privacy Protection Act applicable in the United States of America. GOLPO KHURO requires parental consent before Personal Information belonging to children is submitted or collected, unless the information concerned falls within an exception recognized under applicable law. GOLPO KHURO does not make Personal Information collected from children publicly available nor do we enable children to do so on the Website. A child’s participation in any activity or service contained on the Website is not conditional upon disclosure of more Personal Information than reasonably necessary to participate in such action or service.
Parents may contact us at the E-mail ID mentioned in Section 18.2 (Customer Services) to review, update or delete any of their children’s Personal Information and to elect for us not to collect any additional Personal Information from their children. We will not change how we handle previously collected information without providing notice and obtaining parental consent wherever necessary.
8. SECURITY
This website, in compliance with applicable norms, has a number of security measures to ensure there is no loss, misuse or illegal alteration of information collected from its users. Personal Information and Usage Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply won't be intercepted while being transmitted to us over the Internet or wireless communication and any information you transmit to GOLPO KHURO you do at your own risk. If, despite our best efforts, an unauthorised breach of our security measures occurs, resulting in the unauthorised access, duplication, removal or alteration of any Personal Information, Third Party Information, or Usage Information, GOLPO KHURO, its directors, officers, employees, promoters, or affiliates will not be held responsible for any loss resulting from such breach.
9. COMPROMISE OF PERSONAL INFORMATION
In the event that Personal Information is compromised as a breach of security, GOLPO KHURO will notify the supervisory authority in compliance with applicable law, within 72 (seventy-two) hours of the breach coming to its notice.
10. CONTACT & POLICY UPDATES
In case of any queries on this privacy policy, please contact us at the E-mail ID mentioned in Section 18.1 (Legal and Notices). GOLPO KHURO reserves the right to update or modify any part of this policy or make any changes without prior notice to the user. The user is advised to check this page periodically to stay abreast of any policy changes by us.
11. CHANGE OF INFORMATION AND CANCELLATION OF ACCOUNT
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer desire to access the Website, you may correct, delete inaccuracies, or amend information by contacting us through at the E-mail ID mentioned in Section 18.2 (Customer Services) and we shall endeavour to respond within 72 (seventy-two) hours of receipt of the communication.
You have the right to request that we rectify or delete the personal data or restrict the processing of your personal data, if you think they are inaccurate. Furthermore, you have the right to object to the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant. You have a right to lodge a complaint with your local supervisory authority.
You may also cancel or modify the communications that you have elected to receive from the Website by logging into your user account and changing your communication preferences.
If you wish to cancel your account or request that we no longer use your information to provide you details with respect to our products or services and the Website, please write to us at the E-mail ID mentioned in Section 18.2 (Customer Services).
12. OPT-IN
If you wish to opt for receiving non-essential communications such as promotional and marketing-related information regarding the Website and the products or services, please send GOLPO KHURO an email at the E-mail ID mentioned in Section 18.2 (Customer Services).
13. CHANGES TO THE PRIVACY POLICY
Occasionally, we may update this Privacy Policy to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy on the Website. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
14. GRIEVANCE REDRESSAL
If you have any questions or concerns about this Privacy Policy usage and processing of your personal information and content which violates the Privacy Policy and/or our Terms and Conditions please write to us at the E-mail address mentioned in Section 18.3 (Grievance Redressal) or using the details provided on our ‘Contact Us page. We will use reasonable efforts to respond promptly to requests, questions or concerns you may have regarding our use of personal information about you. Except where required by law, GOLPO KHURO cannot ensure a response to questions or comments regarding topics unrelated to this policy or Company’s privacy practices.
15. CONSENT
By consenting to the terms under this Privacy Policy, you are expressly granting GOLPO KHURO the right to collect, share, transfer, store, retain, disseminate or use the Personal Information/Usage Information collected by GOLPO KHURO from your usage of the Website in accordance with the terms of the Privacy Policy. You may, at any time, withdraw consent for the collection or processing of Personal Information/Usage Information by sending an email to the E-mail ID mentioned in Section 18.2 (Customer Services). GOLPO KHURO shall endeavour to reply, shall within 72 (seventy-two) hours and delete or anonymize the data collected from you.
16. GOVERNING LAW
This Policy is published and shall be governed by and construed in accordance with the applicable laws of India as amended from time to time, without reference to conflict of laws principles. The courts in Bengaluru shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, this Privacy Policy.
17. AMENDMENT
Occasionally, we may update this Privacy Policy to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Privacy Policy on the Website. If we make any material changes, we will notify You by email (sent to the e-mail address specified in Your account) or by means of a notice on the Website prior to the change becoming effective. We encourage You to periodically review this page for the latest information on our privacy practices.
18. GOLPO KHURO COMMUNICATIONS
18.1 LEGAL AND NOTICES
To send us any notice or for any legal concerns or in case your intellectual property rights have been infringed you may write to us at [email protected] audio books
18.2 CUSTOMER SERVICES
For any queries /concerns regarding your account and/or its termination, payments, coins, business purpose or partnerships etc. you may write to us at [email protected].
18.3 GRIEVANCE OFFICER
In case you have any concerns in relation to the usage and processing of your personal information, or content that violates our Privacy Policy/Terms and Conditions then you may contact our Grievance Officer at the below:
Name: Chiranjit Nath
Address: 339/1/11, Kalipada Mukherjee Road, behala East Park, Kolkata-700008
Office Hours: 10:00 A.M. to 1:00 P.M.
Email: [email protected]