THRIVE INDIA
PRIVACY POLICY

A. PURPOSE AND SCOPE
We, Thrive India (“TI” or “we” or “our” or “us”), are committed to protecting the
privacy of the information provider (“you” / “your” / “yourself”). We consider
privacy and protection of your data/ information to be of high importance. Our
practices and procedures in relation to the collection and use of your data/
information has been set-out below in this privacy policy (“Privacy Policy”). This
Privacy Policy will familiarize you with the manner in which TI may collect, use,
share, transfer and disclose your data/ information through
https://www.thriveindia.org, associated mobile applications or any other
platforms including social media platforms (the “Website”). This Privacy Policy
forms an integral part of our General Website Terms [of use] to use our Website
(“General Website Terms”).
TI reserves the right, at its discretion, to change, modify, amend, add or remove
portions of this Privacy Policy at any time without notice. We recommend that
you review this Privacy Policy periodically to ensure that you are aware of the
current privacy practices of TI. By visiting our Website, you agree to be bound by
the terms and conditions of this Privacy Policy (which includes the General
Website Terms).
This Privacy Policy shall be construed to be provided in compliance with the
Information Technology Act 2000 (“IT Act”) and applicable rules framed
thereunder, as amended from time to time, and shall be read with the Information
Technology (Reasonable Security Practices and Procedures and Sensitive
Personal Data or Information) Rules 2011 (“SPDI Rules”), as applicable.
Our Commitment to Our Donors
We will not sell, share or trade our donors’ names or personal information with
any third party other than local Thrive organizations and our service providers,
nor send mailings to our donors on behalf of other organizations.
This Privacy Policy applies to all personal information received by TI, both online
and offline, on the Website), as well as any electronic, written, or oral
communications.
B. COLLECTION OF INFORMATION
1. In this Privacy Policy, unless the context otherwise requires ‘Personal
Information’ means any information that relates to a natural person which, either
directly or indirectly, in combination with other information available or likely to
be available with TI, is capable of identifying such person and shall include the
following:
a) information such as your name, job title, postal address (home and
business), telephone number, mobile phone number and email address;
b) any business information in connection with any project or any contractual
relationship with TI or provide by you voluntarily;
c) your user id and password and other security related information for
accessing the Website;
d) information collected from publicly available resources, public data bases
and credit rating agencies;
e) information about any litigation or other legal proceedings against you;
f) information about your health to understand you have any disability or
require any special assistance;
g) information provided in your application for any job with TI like your
experience, qualifications, your current compensation package and
expected compensation package, references etc;
h) details of all your visits to TI’s premises;
i) information to verify your identify which may be required to provide you with
the response that you may seek through our ‘contact us’ link.
j) Email communications which may be sent to TI will be routed through our
systems and stored in our systems;
k) Tracking technologies may automatically record information such as
domain and host names, other information about your geographic location,
IP addresses, browser software and operating system types, your manner
of connecting to the Internet (e.g., connection speed through narrowband
or broadband access), and dates and times that our Website is accessed,
hardware model, device hardware information, IMEI number and other
unique device identifiers, phone number, serial number, current software
version, mobile country code, mobile network, MAC address, cookies,
pixels and settings of the devices you use to access our Website;
l) information which you may provide including your profile photo, profile
name etc;
m) your facial scanning though facial recognition software;
n) your location through your device’s GPS signal or information about nearby
Wi-Fi access points and cell towers that may be transmitted to us when you
use certain services and enable the location function on your device;
o) other personal data notwithstanding its relevance to the services provided
by TI;
p) personal data about your membership of a professional or trade association
or union, personal health data;
2. We may collect personal information about you under number of circumstances
including (i) when you or your organisation visit, make an enquiry or otherwise
interact on the Website;(ii) personal meetings and exchanging business cards
and contacts; or (iii) when you or your organisation offer to provide services to
us.
3. You represent that the information or data you provide from time to time is and
shall be correct, current and updated and you have all the rights, permissions
and consents to provide such information or data. Your providing the data/
information and TI’s consequent storage, collection, usage, transfer, access or
processing of the same shall not be in violation of any third -party agreement,
laws, judgments, orders or decrees.
4. In general, the users to the Website can access the Website’s home page and
browse some areas of the Website, without disclosing any Personal Information.
5. However, TI tracks information provided by visitor’s browser, including the
website the visitor came from (known as the referring URL), the type of browser
used and other information that does not personally identify any visitor of the
Website. This may include installation of cookies and collection of other session
data.
6. We do not have any system to collect Personal Information automatically. In
order to use our services, you will have to register with us and provide Personal
Information. It is completely optional on your part to provide Personal Information
and register with us.
7. If any Personal Information of any third party such as your office colleagues, directors
or employees or someone with whom you have business dealings are shared with TI
then you must ensure that you have the authority and entitled to disclose that Personal
Information to us and we may collect, use and disclose that Personal Information as
described in this Privacy Policy without taking any further steps or actions on behalf of
TI. In particular, you should ensure that the concerned individual is aware this Privacy
Policy, including our identity, contacting us, purposes of collection, use and processing
of Personal Information, transferring and sharing Personal Information, the individual’s
right to obtain access to the Personal Information and make complaints about the
handling of the Personal Information, and the consequences if the Personal Information
is not provided (such as our inability to provide services).
8. Some elements of the Website may ask you to submit Personal Information in
order for you to benefit from the specified features or participate in a certain
activity.
9. We may combine information you submit through the Website with other
information we have collected from you, whether online or off-line.  We will treat
the combined information in accordance with this Privacy Policy.
10. Unless we specifically request or invite for it, we ask that you not send or
otherwise disclose to us your racial or ethnic origin, political opinions, religion or
other beliefs, health, criminal background, or trade union membership.  In those
cases where we may request or invite you to provide the foregoing information,
we will only do so with your express consent, in accordance with applicable data
protection law requirements.  Where you provide us with such information without
request from TI, we reserve the right (but do not have any obligation) to erase
any such information at our discretion.
11. The Website is not intended for persons under the age of 16.  We do not
knowingly collect Personal Information from persons in this age group.  We
reserve the right to delete any information identified as having been provided by
such persons at our discretion.
12. Any comment system on the Website may utilize an opt-in geolocation service in
accordance with a prevailing community standard such as HTML 5.  Such
geolocation opt-in ability is managed by the user’s browser settings.  If a user
chooses to opt-in to the geolocation service, the user’s comments may be
associated with the user’s location, both internally within TI and publicly on the
Website.
13. As you navigate the Website, certain Personal Information may be passively collected,
meaning it is gathered automatically without your actively providing it.  This is done using
the following techniques in the following ways:
a) IP Addresses:  An IP address is a unique identifier that certain electronic
devices use to identify and communicate with each other on the
Internet.  When you visit our Website, we may view the IP address of the
device you use to connect to the Internet.  We use this information to
determine the general physical location of the device and understand from
what geographic regions our website visitors come.  We also may use this
information to enhance our Website.
b) Through your browser:  Certain information is collected by most browsers,
such as your Media Access Control (MAC) address, computer type and
operating system type and version screen resolution, and Internet browser
type and version.
c) Social Media Widgets:  Our Website may include social media tools,
including social media widgets or plug-ins, to connect you to your social
media accounts. These features may set a cookie or use other automatic
collection and tracking technologies to collect information about you and
your use of the social media features through and in connection with our
Website.  These social media tools may be hosted by a third party.  Your
interactions with these tools and the corresponding social media platforms
are governed by the privacy policies of the companies that provide such
platforms.
d) Like any other website, www.thriveindia.org uses ‘cookies’. These cookies
are used to store information including visitors’ preferences, and the pages
on the website that the visitor accessed or visited. The information is used
to optimize the users’ experience by customizing our web page content
based on visitors’ browser type and/or other information.
For more general information on cookies, please
read http://www.aboutcookies.org. You can
visit https://tools.google.com/dlpage/gaoptout for information on how to opt
out of Google Analytics cookies.
e) Google Analytics:  We use Google Analytics, which is provided by Google
Inc.  It uses cookies to collect, for example, information about the operating
system and the browser that you use, your IP address, the website you
previously accessed (referrer URL) and the date and time of your visit to
the Website.  On subsequent repeated visits to the Website, frequently
used information is automatically displayed for you.  We are able to track
your usage patterns with the help of the cookies.  The information
generated by cookies about the use of the Website is transmitted to a
Google server. Google will use this information to evaluate your use of the
Website. Google may transfer these rights to third parties insofar as it is
required to do so by law or in order that data may be processed on Google’s
behalf.
C. USE AND PROCESSING OF DATA/ INFORMATION
1. We use Personal Information submitted by you or otherwise collected through
the Website and through other sources for the purposes described in this Privacy
Policy and as otherwise described to you at the point of collection.  Generally, we
use the information you provide to us for the reason for which it was provided. For
example, if you sign up to receive email notifications, we will contact you by
email.  If you provide us with information to make a donation, we will use the
information to process your donation.   The information collected by TI may be
used for a number of purposes connected with our objects and activities which
may include the following:
a) to verify your identity and confirm your eligibility to access and use our Website
and the features made available through our Website;
b) to manage and oversee your or your organisation’s relationship with TI,
including payments receipts, accounting, auditing, billing and collection;
c) to comply with our legal obligations, compliance obligations (including
obligations under trade sanction and embargoes, money laundering,
financial and credit check, fraud and crime prevention and detection
purposes) and may contact you to confirm your identity which may be
relevant for compliance purposes;
d) to allowing you to create your own profile on our Website in order to avail
our services without having to provide personal information again every
time you access our Website;
e) to analyse and improve our services and communications with you;
f) to secure and manage access to our premises, information technology and
communication systems, online platforms, websites and other systems and
to prevent and detect security threats, fraud or other criminal or malicious
activities;
g) to monitor and check compliance with our policies and standards;
h) to comply with our legal and regulatory obligations including reporting to
and/or being audited by national and international regulatory authorities;
i) to enable vendors and service providers to provide various services
subscribed by you including contact information verification, payment
processing, customer service, website hosting, data analysis, infrastructure
provision, information technology services, and other similar services;
j) to comply with court orders and exercise and/or defend legal rights of TI;
k) for any purpose related, incidental and/or ancillary to any of the above or
any other purpose for which your Personal Information was provided to us.
l) if you submit your review about our services then it will be published on our
Website and other donors/sponsors will be able to view you reviews and
experiences and other details shared with us;
m) to respond to your inquiries and to send you information that you request
and to process your donations;
n) to send you important information regarding our relationship with you or
regarding the Website, changes to our terms, conditions, and policies, and
other administrative information;
o) dealing with requests, enquiries and complaints, customer services and
related activities;
p) to notify you about upcoming events and donations;
q) to promote our mission and initiatives, and the missions and initiatives of
our affiliates;
r) for our business purposes, such as data analysis, audits, recordkeeping,
developing new products or services, enhancing the Website, improving our
services, identifying Website usage trends, optimizing your experience on
the Website, and determining the effectiveness of our fundraising
campaigns;
s) if you choose to complete a survey, we may use the information for
purposes of evaluating your feedback from the survey;
t) to conduct survey about how satisfied our customers are and for improving
our performance and provide better services to the customer;
u) legitimate business purposes; and
v) responding to judicial process and provide information to law enforcement
agencies or in connection with an investigation on matters related to public
safety, as permitted by law.
w) if we intend to collect and use Personal Information for another purpose, we may
seek your permission at the time the information is collected.
x) We may use any information that does not personally identify you, your
computer, or your device for any purpose.
2. In addition, the processing may be based on your consent where you have
expressly given that to us.
D. DISCLOSURE AND TRANSFER OF YOUR PERSONAL INFORMATION
1. TI does not sell your Personal Information.
2. We may share your Personal Information with third parties only as described in
this Privacy Policy or as otherwise described at the point where we collect the
information from you, including:
a) to our affiliates and other Thrive organizations, for the purposes described
in this Privacy Policy;
b) to the companies or individuals that we hire to provide services to us,
such as website hosting services, relationship management services, and
payment processing; and
c) to a third party in the event of any reorganization, merger, sale, joint venture,
assignment, transfer, or other disposition of all or any portion of our business, or
assets (including in connection with any bankruptcy or similar proceedings).
3. We may share your Personal Information to our partners, associates, service
providers and third parties who may handle our data management, newsletter
and email distribution, conducting surveys, events, and promotions, as
necessary or appropriate:
a) to carry out services on behalf of TI under contract;
b) in any manner permitted under applicable law, including laws outside your country
of residence;
c) to comply with any legal process whether local or foreign;
d) to respond to requests from public and government authorities, including public
and government authorities outside your country of residence;
e) to enforce our General Website Terms and policies;
f) when TI, in its sole discretion, deems it necessary in order to protect its rights or
the rights of others;
g) to protect our rights or property, privacy, safety or property, and/or that of our
affiliates, you or others;
h) to allow us to pursue available remedies or limit the damages that we may sustain;
i) to third parties on a confidential basis for the purposes of collecting your feedback
and to help us measure our performance and to improve and promote mission
and objectives;
j) with companies providing services for money laundering activities, credit risk and
other fraud and crime prevention activities and companies providing similar
services, including financial institutions, credit rating agencies and regulatory
bodies;
k) with courts, law enforcement agencies, regulatory bodies or lawyers or other
parties where it is reasonably necessary for TI to exercise or defend a legal or
equitable claim;
l) with third party service providers to process personal data on our behalf and in
accordance with our instructions only. TI will be responsible for your Personal
Information and have control over the same and will use appropriate safeguards
as required by applicable law to ensure the integrity and security of your Personal
Information when engaging such service providers;
4. Your data/ information will be kept confidential to the maximum possible extent and in
accordance with the provisions set out herein.
5. Your personal information will be retained with us as long as you continue to use your
account on our Website or as long as we continue to have a business need to do so,
unless a longer period is required by applicable law.
E. LINKS TO THIRD PARTY SITES
The Website may contain links to other websites for the convenience of users in
locating information, products, or services that may be of interest.  If you access
a third-party website from a link on this Website, any information you disclose on
that website is not subject to this Privacy Policy.  It is possible that these links
may be used by third parties or others to collect personal or other information
about you. TI is not responsible for the privacy practices of such websites,
advertisers, or third parties or the content of such websites and it is your sole
obligation to review and understand the privacy practices and policies of these
other websites. TI does not control these third parties’ use of cookies, collection
of information, or how they manage such information. It is solely your obligation
to review and understand the privacy practices and policies of these other
websites, advertisers and any third parties.
F. SOCIAL MEDIA SHARING FEATURE
We have our social media platforms and you will be able to connect us through
such social media platforms. In such case we may be able to identify you and
relate the information shared through social media platforms with the information
that we already have about you. Depending on your usage settings on social
media platforms, all information shared by you may be available to others
including your friends and general public.
G. SECURITY
TI will take reasonable steps to protect the information collected and provided
via the Website from loss, misuse, and unauthorized access, disclosure,
alteration, or destruction.  We have taken steps and adopted industry-standard
security measures to maintain the safety of your personal information. All
electronic financial transactions performed through our Website are covered by
encryption technology. All your personal information and data are stored on
secured servers and are password and firewall protected. However, you should
understand that no transmission over the Internet is ever fully secure.  As such,
we cannot guarantee or certify the safety of any information transmitted or
otherwise provided to us or received from us. Also, TI uses reasonable efforts to
ensure that the Website is generally available.  However, there will be occasions
when access to the Website will be interrupted or unavailable.  TI will use
reasonable efforts to minimize such disruption where it is within its reasonable
control. You accept the inherent security implications of providing information
over internet / cellular / data networks and you agree that TI shall not be liable to
you for any modification, suspension or discontinuance of the Website or for any
breach of security or the disclosure of Personal Information unless TI has been
grossly and willfully negligent.
H. GENERAL
1. Data Retention
We generally retain Personal Information for so long as it may be relevant for the
purposes identified in this Privacy Policy, unless a longer period of time is
required by law. Your Personal Information will primarily be stored in an
electronic form. However, certain data can also be stored in physical form.
2. Lawful Basis for Processing Your Personal Information
This Privacy Policy is issued on behalf of TI as controller of your Personal
Information under applicable data protection laws.  A “controller” is the person or
organization who alone or jointly determines the purposes for which, and
the manner in which, any Personal Information is, or is likely to be, processed.
TI is based in Mumbai/Delhi, India and any information transmitted to us may be
stored, accessed, or processed in India. We follow the data protection laws of
India.
3. Automated Processing of Personal Information
We may use automated processing of your Personal Information in order to tailor
our communications with you and manage our relationships with our donors and
contacts. This automated processing may impact the type of communications
you receive from us.
If you would like to submit a data access, correction, restriction, or deletion
request, you can do so by contacting us at info@thriveindia.org and we will
process such request with respect to any Personal Information that we are able
to link to you individually based on the information that you can provide to us.
4. Force Majeure
Notwithstanding anything contained in this Privacy Policy or elsewhere, TI shall
not be held responsible for any loss, damage or misuse of your Personal
Information, if such loss, damage or misuse is attributable to a Force Majeure
Event. A “Force Majeure Event” shall mean any event that is beyond the
reasonable control of TI and shall include without limitation, sabotage, fire, flood,
explosion, acts of God, civil commotion, strikes or industrial action of any kind,
riots, insurrection, war, acts of government, computer hacking, unauthorized
access to computer data and storage device, computer crashes, breach of
security and encryption.
5. Right to Review and Modify
We will provide you with the right to review, access and modify the Personal
Information that we maintain about you depending on technical feasibility and
requirements of applicable laws. We may perform verification before providing
you access to this Personal Information. However, we are not responsible for the
authenticity of the Personal Information provided by you.
6. Withdrawal of Consent
You have the right to withdraw the consent provided to us in relation to your
Personal Information at any time in writing by sending an e-mail to us
at info@thriveindia.org, in accordance with the terms of this Privacy Policy.
However, please note that withdrawal of consent will not be retrospective in
nature and shall be applicable prospectively. In case you do not provide your
information or consent for usage of Personal Information or subsequently
withdraw your consent for usage of the Personal Information so collected, TI
reserves the right to discontinue the provisions for which the said Personal
Information was sought.
7. Deletion of Personal Information
You can request TI to delete the Personal Information provided by you to TI by
sending an e-mail to us at info@thriveindia.org. However, please note that
correction or deletion of certain information or data may lead to cancellation of
your registration with the Website or your access to certain features of the
Website. You also agree and acknowledge that certain data or information
cannot be corrected or deleted and/or is prohibited from being deleted under any
applicable law or in lieu of law enforcement requests or under any judicial
proceedings.
I. YOUR RIGHTS REGARDING YOUR INFORMATION
Any questions regarding this Privacy Policy or our use of your Personal
Information, you can reach us by email at info@thriveindia.org.
J. RIGHT TO CHANGE PRIVACY POLICY.
TI reserves the right at any time to modify, alter, or update this Privacy
Policy.  Your use of the Website following any changes means that you agree to
follow and be bound by the Privacy Policy as changed, subject to limitations
under applicable law.  Any change to this Privacy Policy shall be effective as to
any user who has visited the Website before the change was made.  Please
review this policy periodically, and especially before you provide any Personal
Information to us.
K. REFUND & CANCELLATION
Since all transactions online on the site are donations for which a tax exemption
certificate is issued no refund or cancellation is possible for the same except in
the case where the transaction is fraudulent or unauthorised in nature whereby
cardholder can initiate chargeback on the transaction with their respective bank.
L. CONTACTING US
For questions about this Website, please contact us at info@thriveindia.org
To contact us by mail:
Thrive India
Registered Office
Cabin No.4, 512A Deep Shikha,
8 Rajendra Place, New Delhi-110008, India
Phone: +91 9076033123
info@thriveindia.org