Privacy Policy -

Privacy Statement

Last updated on [09-08-2023].We care about your privacy and are committed to protecting your personal data.This privacy statement will inform you how we handle your personal data, yourprivacy rights and how the law protects you. Please read this privacy statementcarefully before using our Services.

This privacy statement appliesto your use of any products, services, content, features, technologies, orfunctions, and all related websites, mobile apps, mobile sites or other onlineplatform or applications offered to you by us (collectively the "Services/Platform").

1.     Who are we?

DEALONLINE India Private Limited, a company incorporated and registered in India,is the data controller for the personal data collected through this Platform.

2.     What data do we collect aboutyou?

2.1.1 Data providedthrough direct interactionsRegistrationand other account information

When youregister to use our Services, we may collect the following information aboutyou:

If youregister using your Google account: first name, last name and emailaddress; If you register using your Facebook account: we collect first name andlast name as appeared on your Facebook account, Facebook IDs and the URL toyour Facebook profile picture. In the event you have provided permission toFacebook through their in-app privacy option (which appears just before youregister on our Platform), we may collect your gender, age or email iddepending on the permissions granted by you. ; and If you register using yourmobile number we collect your mobile number. If you register using your AppleID: your first and last name and email address; you can decide whether to shareyour email address with us when you sign in your Apple account.

Dependingon the choices you make during the log-in to our Services or during the processof engaging our Services, you may opt to give the following additional personaldata:

o   Yourname;

o   E-mailaddress;

o   Mobilenumber;

Yourcredit card/debit card details in case you choose to purchase our paid servicesas defined in our Terms of Use using your credit/debit card. Copy ofyour identity proof (driving license, passport or other card, whichever isconvenient for you) and real time image of your face, in case you have optedfor the KYC verification as available on the platform. Please note that the KYCverification is currently available to a limited number of users. A copy of theregistration certificate (RC) of your car in case you have opted to provide itwhile listing your car on our Services. Please note that the option to provideRC is currently available to a limited number of users.

Validationof your DEAL ONLINE account

Wevalidate the accounts of DEAL ONLINE users by using SMS verification to ensurethat each account is associated with a real and unique user. This validationprocess is initiated once you proceed with posting your first ad listing on ourServices. In order to validate your DEAL ONLINE account before posting your adlisting, we will send you an SMS on a valid mobile number providedby  you. This process is entirely free of charge.

If youdo not agree to validate your account, then your account will remain active andyou will be able to use our Services with limited functionality. This limitedfunctionality of an account implies that you cannot publish new ad listings oredit, update, promote, extend, reactivate, deactivate or delete existing adlistings until your account is verified by SMS. You will also not be able toreceive or reply to any messages from other users.

In caseyou create several DEAL ONLINE accounts using the same mobile number andvalidate all those accounts via SMS verification, all such accounts will have alimited functionality and you will be asked to choose one of them. The accountchosen by you will return to full functionality, and the rest of the accountswill remain to have  limited functionality.

Everyuser can request a maximum of 5 SMS messages with verification codes, within 24hours. Account validation is done only once for each account, until it issuccessfully verified via SMS by the user.

Once youhave validated your DEAL ONLINE account, it will remain associated with themobile number used for the SMS verification. If you wish to change the mobilenumber associated with your DEAL ONLINE account, you will need to contact ourCustomer Support team.

Communicationthrough the chat feature on our Platform

When youuse our chat feature to communicate with other users, we collect informationthat you choose to provide to other users through this feature.

Takingpart in our user surveys

We willoccasionally provide you with our user surveys in order to measure your overallsatisfaction with the quality of our Services. For this purpose, we will onlyuse a session log (this is a random identifier assigned to you when you aredownloading our mobile app or visit our website). Furthermore, you may chooseto provide us with your contact details such as your email and your mobilenumber upon our request to contact you and invite you to attend one of our userexperience (UX) tests or an interview with our team. Please be aware that theinformation you give us in relation to our survey questions may occasionallycontain personal data as voluntarily provided by you in your answers.

2.1.2 Data wecollect automatically when you use of our Services

When youinteract with our Services, we automatically collect the following informationabout you:

DeviceInformation

Wecollect device-specific information such as operating system version, uniqueidentifiers. For example, the name of the mobile network that you are using. Weassociate the device identifiers with your DEAL ONLINE account.

Locationinformation

Dependingon your device permissions, if you post an item on our Platform, weautomatically collect and process information about your actual location. Weuse various technologies to determine location, including IP address, GPS,Wi-Fi access points and mobile towers. Your location data allows you to seeuser items near you and helps you in posting items within your location. Incase we need your location data, we will first show you a pop-up which will askyou to choose to allow or not to allow us to access your location data. If youdo not allow us to have access to your location data, you will still be able touse our Services but with limited functionality. If you do allow us to accessyour location data you can always change this later by going to the settings onour Website or App our Platform and disable the permissions related to locationsharing.

Clientand Log data

Technicaldetails, including the Internet Protocol (IP) address of your device, time zoneand operating system. We will also store your login information (registrationdate, date of last password change, date of the last successful login), typeand version of your browser.

Clickstreamdata

Wecollect information about your activity on our Platform, which includes thesites from which you accessed our Platform, date and time stamp of each visit,searches you have performed, listings or advertisement banners you clicked,your interaction with such advertisements or listings, duration of your visitand the order in which you visit the content on our Platform.

Cookiesand Similar Technologies

We usecookies to manage our users’ sessions, to store your preference languageselection and deliver you relevant advertisements. "Cookies" aresmall text files transferred from a web server to the hard drive of yourdevice. Cookies may be used to collect the date and time of your visit, yourbrowsing history, your preferences, and your username. You can set your browserto refuse all or some cookies, or to alert you when websites set or accesscookies. If you disable or refuse cookies, please note that some parts of ourServices/Platform may become inaccessible or not function properly.

3.     Why do we process your personalinformation?

We willonly use your personal data when the law allows us to. Most commonly, we willuse your personal data in the following circumstances:

Where weneed to perform the contract we are about to enter into or have entered intowith you.

Where itis necessary for our legitimate interests to improve our Services and toprovide you a safe and secure Platform.

Where weneed to comply with a legal or regulatory obligation.

Incertain circumstances, we may also process your personal data based on yourconsent. If we do this, we will let you know the purpose and the category ofpersonal data to be processed at the time we seek your consent.

We haveset out below a description of the reasons for which we use your personal data,[and which of the legal bases we rely on to do so. We have also identified whatour legitimate interests are, where appropriate].

3.1 For providing access and delivering Services through ourPlatform

1.               If you log in using your mobilenumber or email id, we use your first name and last name, mobile number and/ore-mail address to identify you as a user and provide access to our Platform.

2.     If you log in using yourFacebook account or Google account or your Apple ID, we use your first name andlast name and your email address of such account, as well as the URL to yourprofile picture (except for Apple ID) we use your first name and last namefrom your Facebook profile and the Facebook e-mail address to identify you as auser on our Platform and to provide you access to our Platform.

3.     We use third party paymentservice providers to process any payment you make to our Services. Depending onthe method of payment, you may be requested to provide us with your payment andcredit card details which we will then provide to the payment service providerin order to process your payment. We do not store your credit card information,unless you choose the option to save such information in order to makerecurring payments easier without having to re-enter your details each time. Insuch cases, we only store your card holder name, the card expiry date, yourcard type and the last four digits of the card number. We do not store anycredit card code verification values and merely forward such values and yourcredit card number in an encrypted manner for the purpose of processing yourpayment by our payment service provider.

Weprocess the above information for adequate performance of our contract withyou.

3.2For improving your experience on the Platform and developingnew functionalities of the Platform

4.               We use clickstream data to:

Offeryou tailored content, such as giving you more relevant search results whenusing our Services.

Todetermine how much time you spend on our Platform and in what manner younavigate through our Platform in order to understand your interests and toimprove our Services based on this data. For example, we may provide you withsuggestions on content that you can visit based on the contents you haveclicked. To monitor and report the effectiveness of the campaign delivery toour business partners and internal business analysis.

5.               If you choose to provide uswith your location data, we use your location data for following purposes:

Tocompile anonymous and aggregated information about the characteristics andbehavior of DEAL ONLINE users, including for the purposes of business analysis,segmentation and development of anonymous profiles. To enhance the performanceof our Services and to personalize the content we direct towards you. Forexample - with the help of location data we display ad listings which are inyour vicinity to improve your buying experience. For this purpose, Google Mapsis integrated into our Platform. This means that both Google and we areresponsible for the processing of your location data in the context of GoogleMaps. In any case, we will not process your location data for any otherpurposes but those explained in this Privacy Statement. However, Google mightprocess such location data for their own purposes as explained in the GooglePrivacy Policy which can be reviewed Your use of Google Maps through ourPlatform is subject to Google Maps’ Terms of Service. To measure and monitoryour interaction with the third-party advertisement banners, we place on ourPlatform.

6.               With the help of your accountinformation, which includes your email ID and phone number, we map thedifferent devices (such as desktop, mobile, tablets) used by you to access ourPlatform. This allows us to associate your activity on our Platform acrossdevices and helps us in providing you a seamless experience no matter whichdevice you use. 

7.     We use the images you upload,the descriptions and prices you provide in your ad listings to train machinelearning models to personalize search results in relation to ad ranking anduser interest, to improve the identification and presentation of ad listings,to improve the search function and to increase the likelihood of a successfulsale. This helps us to improve our Services and to provide you with a betteruser experience. 

8.     To show and recommend adlistings on our Services that may be of interest to you, we make use ofalgorithms that use information related to your browsing behavior, items youbought, clickstream data, your user ID and your location data if you have givenus permission to use this. We use this form of automated decision-making on thebasis of our legitimate interest in improving our Services and provide a betteruser experience by offering you more relevant ad listings. 

9.     We access and analyze your chatmessages with other users conducted through the chat function on our Platform,for product enhancement and to provide you with a better user experience (e.g.to identify sold items and to provide you with active listings only).Therefore, we develop and train machine learning models and algorithms toautomatically analyze your chat content. To build and train our machinelearning models our machine learning specialists may review exemplary chatcontent manually. In these circumstances highly restricted access rights applyto selected machine learning specialists analyzing the chat content. Duringthis analyzation process, we are de-identifying chat content as much aspossible by applying a scanning filter to detect and hide personal data such asnames, phone numbers, e-mail addresses. However, there may still be casesbeyond our control in which the chat content may show certain personal datathat you have chosen to provide. 

10.  In case you agree to opt forKYC verification as available on our Services, depending on the device camerapermission, we will request you to click in real time an image of your face andan image of your identity proof in quick succession in order to verify youridentity. Upon completion of the KYC process, in case the image on the identityproof matches with the image of the face captured, your account will beconsidered as verified. Such verification will help you to build trust amongother users and receive better responses to your listings.

11.  In case you agree to providethe RC while posting an ad for your car on our Services, we will request toprovide an image of your RC during the posting flow, along with images of yourcar. Upon submitting your listing, if the RC details match the registrationnumber of your car, your ad listing will state “RC reviewed by DEAL ONLINE”.Such verification will help you to build trust among other users and receivebetter responses to your listings. The RC will be reviewed internally and nodetails of the RC will be displayed on our Services.

Weprocess the above information for adequate performance of our contract with youand on the basis of our legitimate interest to improve your experience of ourServices.

3.3 To take your feedback, promote and offer you Servicesthat may be of your interest 

12.            We use your mobile number, logdata and unique device identifiers to administer and protect our Platform(including troubleshooting, data analysis, testing, fraud prevention, systemmaintenance, support, reporting and hosting of data). 

13.  We access and analyze your chatmessages with other users conducted through the chat function on our Servicesfor customer satisfaction, safety and for fraud prevention purposes (e.g. toblock spam or abusive messages that may have been sent to you by other users).Therefore, we develop and train machine learning models and algorithms helpingus to automatically detect and prevent inappropriate and fraudulent userbehavior. During the analyzation and training process, we are de-identifyingchat content as much as possible by anonymizing the unique identificationvalues assigned to users. However, there may still be cases beyond our controlin which the chat content may show certain personal data that you have chosento provide. Only in limited cases and circumstances, our customer safety andsecurity specialists review chat content manually, for example, if we havestrong indications leading to the urgent suspicion of fraudulent activities. Inthese circumstances highly restrictive access rights apply to selected customersafety and security specialists analyzing the chat content. 

14.  To prevent and detect fraud onour Services, we make use of algorithms that recognize suspicious or fraudulentuser behavior based on certain information such as user activity and postedcontent, which may lead to us banning certain user accounts. Automated banninghappens when there is a very high degree of certainty that an account or actionis fraudulent. Otherwise human review takes place by selecting customer safetyand security specialists on the basis of highly restrictive access rights. Weuse this form of automated decision-making on the basis of our legitimateinterest to detect and prevent fraud and to keep our Services safe and securefor our users. If you think that your account was wrongfully banned, you cancontact our Customer Support team, in which case our team will review thedecision to ban your account.

15.  We collect certain informationfrom and in relation to the electronic device from which you are accessing ourServices on the basis of our legitimate interest in preventing fraud on ourServices. The information we collect includes your user ID (depending onwhether you are logged in), DEAL ONLINE country domain, IP address, devicelanguage settings, device brand and type, device operating system and version,browser type and version, and device specific software information such asfonts, system and browser Time zone, available video and audio formats. Thedevice related information is used to determine whether the same device isbeing used when users interact with our Services. We associate such informationwith a user fraud score on the basis of which we may ban certain users. Formore information on this, please be referred to our Policy for Cookies andSimilar Technologies. If you think that your account was wrongfully banned, youcan contact us through our customer support helpline in which case our teamwill review the decision to ban your account.

3.4 To take your feedback, promote and offer you Servicesthat may be of your interest

16.            We may contact you through yourregistered mobile number or email id in order to take feedback from you aboutour Services.

17.  We use your email address andmobile number (by SMS) to make suggestions and recommendations to you about ourServices that may be of interest to you.

18.  We use clickstream data tomonitor and report the effectiveness of the campaign delivery to our businesspartners and internal business analysis.

19.  If you choose to provide uswith your location data, we may use your location data to measure and monitoryour interaction with the third-party advertisement banners we place on ourServices.

Weprocess the above information based on our legitimate interest in undertakingmarketing activities to offer you Services that may be of your interest.Specifically, you may receive certain marketing communications from us:

By anypreferred means of communication if you have requested such information fromus. By email or phone, regarding similar products and services, if you alreadyuse our Services or acquired some of our products.  By phone or email, ifyou provided us with your details when you entered a competition; or  Byphone or email if you registered for a promotion.  By phone or email, ifyou have provided your feedback for our Services through our Platform, socialmedia, or any other means.

Being aregistered user on our Platform, please note that if you have registeredyourself on DND/DNC/NCPR services, you will still receive the abovecommunications.

You canask us to stop sending you such marketing communication at any time by clickingon the opt-out link in the email sent to you or by changing your notificationsettings in your account or by stating our calling agent that you do not wishto be contacted for the above marketing communications.

4.     How will we inform you aboutchanges in our privacy statement?

We mayamend and update this privacy statement from time to time. We will notify youof material changes to this privacy statement as appropriate under thecircumstances and as required by applicable laws, e.g. by placing a prominentnotice within our Services or by sending you a message via our Services or bysending you an email. If you do not agree with the way we are processing yourpersonal data and the choices we are providing to you, you may close youraccount at any time by going into your account settings and select deleteaccount.

5.     Communication

We willcommunicate with you by email, SMS or in the app notification in connectionwith our Services/Platform to confirm your registration, to inform you in caseyour ad listing has become live/expired and other transactional messages inrelation to our Services. As it is imperative for us to provide you suchtransactional messages you may not be able to opt -out of such messages.

6.     Who do we share your data with?

We mayhave to share your personal data with the parties set out below for thepurposes set out in 

section3

above.

Corporateaffiliates:

We mayshare your data with our group companies, which are located within as well asoutside India and help us in providing business operation services such asproduct enhancements, customer support and fraud detection mechanism.

ThirdParty Service Providers: 

We usethird party service providers to help us deliver certain aspect of our Servicesfor example, cloud storage facilities.

Weconduct checks on our third-party service providers and require them to respectthe security of your personal data and to treat it in accordance with the law.We do not allow them to use your personal data for their own purposes and onlypermit them to process your personal data for specified purposes and inaccordance with our instructions.

Advertisingand analytics providers:

In orderto improve our Services, we will sometimes share your non-identifiableinformation with analytics providers that help us analyze how people are usingour Platform/Service. We, share your information with them in non-identifiableform for monitoring and reporting the effectiveness of the campaign delivery toour business partners and for internal business analysis. For further detailsabout our advertisers and analytics providers, please refer to our < Policy for Cookies and similar Technologies>.

Lawenforcement authorities, regulators and others:

We maydisclose your personal data to law enforcement authorities, regulators,governmental or public bodies and other relevant third parties comply with anylegal or regulatory requirements.

We maychoose to sell, transfer, or merge parts of our business or our assets.Alternatively, we may seek to acquire other businesses or merge with them. If achange happens to our business, then the new owners may use your personal datain the same way as set out in this privacy statement.

Publiclyavailable information:

When youpost an item for sale using our Services, you may choose to make certainpersonal information visible to other DEAL ONLINE users. This may include yourfirst name, last name, your email address, your location and your contactnumber. Please note, any information you provide to other users can always beshared by them with others so please exercise discretion in this respect.

7.     Where do we store your data andfor how long?

The datawe collect about you will be stored and processed in secure servers in order toprovide the best possible user experience. For example – for fast website ormobile application build up.

We willonly retain your personal data for as long as necessary to fulfil the purposeswe collected it for, including for the purposes of satisfying any legal,accounting, or reporting requirements.

Todetermine the appropriate retention period for personal data, we consider theamount, nature, and sensitivity of the personal data, the potential risk ofharm from unauthorized use or disclosure of your personal data, the purposesfor which we process your personal data and whether we can achieve thosepurposes through other means, and the applicable legal requirements.

8.     Your rights - data deletionrequests

 Toexercise your privacy rights and choices, if you do not want us to process yourdata, then you can use the Data Deletion Requests feature to issue a requestfor its removal. The option to request data deletion isvisible under Account > Settings> "Deactivate accountand delete my data"

Theremay be situations where we cannot grant your request — for example, if you askus to delete your transaction data and DEAL ONLINE is legally obligated tokeep a record of that transaction to comply with law.

9.     Technical and organizationalmeasures and processing security

All theinformation we receive about you are stored on secure servers and we haveimplemented technical and organizational measures that are suitable andnecessary to protect your personal data. DEAL ONLINE continually evaluates thesecurity of its network and adequacy of its internal information securityprogram, which is designed to (a) help secure your data against accidental orunlawful loss, access or disclosure, (b) identify reasonably foreseeable risksto the security of the DEAL ONLINE network, and (c) minimize security risks,including through risk assessment and regular testing. In addition, we ensurethat all payment data are encrypted using SSL technology.

Pleasenote, despite the measures we have implemented to protect your data, thetransfer of data through the Internet or other open networks is nevercompletely secure and there is a risk that your personal data may be accessedby unauthorized third parties.

10.  Links to third-party websites

OurPlatform may contain links to third party websites or apps. If you click on oneof these links, please note that each one will have its own privacy policy. Wedo not control these websites/apps and are not responsible for those policies.When you leave our Platform, we encourage you to read the privacy notice ofevery website you visit.