Privacy Policy

PRIVACY POLICY- TRUE COUNSEL

 

OVERVIEW

True Counsel Private Limited (“True Counsel”, “we”, “us”, “our”) values Your privacy and is committed to ensuring that Your privacy is protected. The purpose of this privacy policy (“Privacy Policy”) is to describe what information we collect about You while You use our Services (“Services”) through our Website and applications (collectively, along with any replacement Website or application, “Platform”), why we collect the information, how we use Your information, how we protect and share Your information, the choices we offer You, including Your ability to access, update and remove information about Yourself (“User” or “Your” or “You”). 

This Privacy Policy must be read in conjunction with the “Terms of Use” (…) and all the terms and conditions therein. Please read and understand this Privacy Policy carefully, and its applicability to the Services that we provide You. If You do not agree with this Privacy Policy, do not access or use the Services.

DEFINITIONS

For the purposes of this Privacy Policy:

  • “Cookies” are small files that are placed on Your computer, mobile Device or any other Device by a Website, containing the details of Your browsing history on that Website among its many uses.
  • “Device” means any Device that can access the Service such as a computer, a cell phone or a digital tablet.
  • “Service” refers to the Website.
  • “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform Services related to the Service or to assist the Company in analysing how the Service is used.
  • “Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • “Website” refers to TRUE COUNSEL, accessible from (url)
  • “You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

INFORMATION WE COLLECT

We are committed to protecting Your privacy in order to give You a secure experience. You may visit most of our site without providing any personal information to us. But sometimes we need information in order to provide You Services that You request, and this policy explains our data collection in relation to the following (collectively referred to in this Privacy Policy as our "Services"):

We automatically track certain information based upon Your activity on our Websites using Cookies, internal functions and other Devices. We use this information for internal research on our users' demographics, interests, activities and used to better understand and serve You and our community. This information may include and not limited to the URL that You just came from (whether this URL is on our site or not) which URL You next go to (whether this URL is on our site or not), what browser You are using, and Your IP address. 

This Privacy Policy governs the collection, storage and use of personal information by us via our Websites, apps and Services. It provides You with details about the personal information we collect from You, how we use Your personal information, and Your rights regarding the personal information we hold about You. Please read this Privacy Policy carefully.

We collect the following broad categories of information from You (collectively referred to as “Information”)

Personally Identifiable Information: If You choose to create Your profile or answer or ask a question or use any Services provided by our Website, You must register and create an Account. When You

  • register with us on the Site to become a user
  • choose to add information to Your profile webpage or
  • create a profile, we will ask You for personally identifiable information.

This refers to information about You that can be used to contact or identify You ("Personal Information"). Personal Information includes, but is not limited to, Your name, company name (if applicable), phone number, email address and home and office postal addresses, as applicable. We use Your Personal Information mainly to provide the Services and administer Your inquiries. You may register to use the Services directly via the Website or by logging into Your account with certain third-party social media or social networking Services ("Social Networking Site") (including, but not limited to, Facebook) via the Website, as described herein. If You decide to register through a Social Networking Site, we will extract some of the Personal Information which You have provided to the Social Networking Site (such as Your name, email address and other information You make publicly available via the Social Networking Site) from the account You have with the applicable Social Networking Site and use that information to create Your Account. The specific information that we extract may depend on the privacy settings You have with the Social Networking Site. You hereby consent to our access to and collection of such personal information about You. We also collect the other information that You provide as part of registration and the administration and personalization of Your profile webpage (e.g., without limitation, zip code (on its own) and individual preferences) ("Non-Identifying Information"). We use Your Personal Information (in some cases, in conjunction with Your Non-Identifying Information) mainly to provide the Services, complete Your transactions, and administer Your inquiries. Certain Non-Identifying Information would be considered a part of Your Personal Information if it were combined with other identifiers (for example, combining Your zip code with Your street address) in a way that enables You to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, Your viewing preferences). We may combine Your Personal Information with Non-Identifying Information and aggregate it with information collected from other True Counsel users (defined below) to attempt to provide You with a better experience, to improve the quality and value of the Services and to analyse and understand how our Website and Services are used. We may also use the combined information without aggregating it to serve You specifically, for instance, to deliver a product to You according to Your preferences or restrictions. We also use Your Personal Information to contact You with True Counsel newsletters, marketing or promotional materials and other information that may be of interest to You. If You decide at any time that You no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. 

Geo-location Information: When You use certain features of the Platform, we may collect information about Your location such as Your IP address, which in turn would enable us to infer Your city, region/state, country, continent, Internet Service Provider (ISP), longitude/latitude coordinates of location, type of connection (residential, business, etc.), and name of the organisation that owns the connection (i.e., if it is a business connection or not).

Usage Information: We collect Information about Your interactions with the Platform such as the pages viewed on the Platform and the User Account dashboard, content created or uploaded through use of the Platform and Services.

Log File and Device Information: When You use the Platform, we automatically collect and store certain information in server logs. This includes details of how You used the Platform, such as access to Your User Account, certain information that Your web browser sends whenever You visit any Website, internet protocol address, information inferred from Your internet protocol address like location, ISP details, Device information such as hardware configuration and operating system, browser types, referring / exit pages and URL’s, number of clicks, domain names, landing pages, pages viewed and other such information. We do not link this automatically collected data to Personally Identifiable Information.

Cookies and Tracking Technologies: We collect Device specific information (such as Your hardware model, operating system version, unique Device identifiers). The Company may associate Your Device identifiers with Your User Account. You may decline these Cookies by changing Your browser settings, if permitted. However, do note that this may impact certain features of the Platform or Your experience in using the Platform.

All the Information provided to the Company by You, including Personally Identifiable Information or any Sensitive Personal Information, is voluntary. You understand that the Company may use certain information of Yours as provided in Section 3 below.

This Privacy Policy does not apply to, nor do we take any responsibility for any information that is collected by any third party either using the Services or through any third-party links made available to You during Your use of the Services or through any of the advertisements or through BOTS. Please note that You will be bound by the terms of use and privacy policy(ies) published by third-parties in respect of any information that You may provide to them, and the Company expressly disclaims any liability arising from the content available on such third-party Websites or applications. 

 

DATA YOU GIVE US (OR OUR THIRD-PARTY SERVICE PROVIDERS) DIRECTLY

  • if You sign up for our newsletter, or specific mailing lists, we will collect Your email address;
  • if You enter into any competitions, contests, or giveaways, or complete any surveys on our apps or Websites, or when using any of our Services, we will collect and store the data You submit to us, including Your name, email address, wallet address, and social media handles;
  • If You create an account (to enable You to use some of our Services), we may collect Your company’s name, username, email address, telephone, address Your first and last name, and other registration-related information;
  • If You book a demo with us (to understand the Services provided), we may collect Your as well as Your company’s name and contact details.
  • if You contact us via our Website or through email, raise a complaint, ask for technical support or report a problem with any of our Services, we will also collect information You provide to us (including Your name, email address and phone number).

DATA WE COLLECT WHEN YOU USE OUR SERVICES

  • the IP address used to connect Your computer to the internet;
  • data about Your location, Device type and model, operating system and version and platform, and any apps You are using in conjunction with our Services;
  • data relating to Your use of our Services; and
  • the number of times You visit or use any of our Services and the amount of time You spend using the Services.

We will sometimes use third party advertising companies to help us collect this personal information. Further information is provided below in

 HOW WE USE THE INFORMATION WE COLLECT 

We will use the Information collected from You for the following purposes:

  • To allow You to collaborate and communicate with other Users.  
  • Ensuring the Services and/or the content on the Website is presented in an effective manner for Your use. 
  • To perform our obligations as per Your requests and for providing You the Services. This includes sharing Your Information in strict confidence with the Consultants, as Consultants will need to access Your Information to provide the Services, subject to the terms of this Privacy Policy.
  • To provide You with information pertaining to Services. 
  • To notify You about any changes and improvements to Services and/or Website; or analytical purposes, including but not limited to assessing Usage Data, usage patterns, and other similar activities.
  • When You create a User Account, we keep a record of Your communication to help solve any issues You might be facing. 
  • We use information collected from Cookies and other tracking technologies to improve Your user experience.
  • To conduct analysis to ensure that the Services are provided in an efficient manner.
  • In any other way that we may describe to You at the time You provide the information.

 

You hereby acknowledge and agree to the Company using Your Information for the foregoing purposes. Except as otherwise provided herein, we will not disclose, publish, sell, rent, market or share with any third party Your personal information without Your express consent.

Please do not include or provide any personal information unless specifically requested as part of the registration or other applicable processes. If any information You have provided or uploaded violates the terms of this Privacy Policy, True Counsel may be required to delete such information upon informing You of the same and revoke Your access if required without incurring any liability to You.

 

OUR DISCLOSURE OF YOUR INFORMATION

We cannot ensure that all of Your private communications and other personally identifiable information stored with True Counsel will never be disclosed in ways not otherwise described in this Privacy Policy. We may be forced to disclose information to the government and law enforcement agencies. Under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or members may abuse or misuse Your information that they collect from our Websites. Therefore, although we use industry standard practices to protect Your privacy, we do not promise, and You should not expect, that Your personally identifiable information or private communications will always remain private. 

As a matter of policy, we do not sell or rent any personally identifiable information about You to any third party. However, the following describes some of the ways that Your personally identifiable information may be disclosed. 

  • Advertiser:We aggregate (gather data across all our user's accounts) personally identifiable information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for other marketing and promotional purposes. However, in these situations, we do not disclose to these entities any information that could be used to identify You personally. Certain information, such as Your name, email address, password, credit card details and bank account number, are never disclosed to marketing advertisers. We may use third-party advertising companies to serve ads on our behalf. These companies may employ Cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via Cookies and action tags is completely anonymous. 
  • External Service Providers:There may be a number of Services offered by external Service Providers that help You use our Websites. If You choose to use these optional Services, and in the course of doing so, disclose information to the external Service Providers, and/or grant them permission to collect information about You, then their use of Your information is governed by their privacy policy. 
  • Other Corporate Entities:We share much of our data, including personally identifiable information about You, with our parent and/or subsidiaries that are committed to serving Your online needs and related Services, throughout the world. To the extent that these entities have access to Your information, they will treat it at least as protectively as they treat information they obtain from their other members. Our parent and/or subsidiaries will follow privacy practices no less protective of all members than our practices described in this document, to the extent allowed by applicable law. It is possible that we and/or its subsidiaries, or any combination of such, could merge with or be acquired by another business entity. Should such a combination occur, You should expect that we would share some or all of Your information in order to continue to provide the Service. You will receive notice of such event (to the extent it occurs). 
  • Users and members:If You ask a question, True Counsel’s Users will see the content of Your question and Your contact information. You can choose what Personal Information You provide as part of Your question. We recommend that You guard Your sensitive information. 
  • Legal opinion:If You make opinion request with an expert via the Services, we will share Your Personal Information, including, but not limited to, Your name and email address, as well as other information about Your request, with the expert so that such expert can coordinate the work with You. 
  • True Counsel's Partners: We may also provide Personal Information to our business partners or other trusted entities for the purpose of providing You with information on goods or Services we believe will be of interest to You. You can, at any time, opt out of receiving such communications. 
  • Social Networking Services:users may link their Accounts with certain Social Networking Site. In these instances, with Your permission and on Your behalf, we will share information about Your activities on the Site and Services, which may include Your Personal Information, including, but not limited to, information contained in any questions, with the applicable Social Networking Service. Through the use of such Services/APIs, as stated above, we also receive certain information (which may include Your Personal Information) in accordance with the privacy settings You have set in Your Social Networking Site account if any. Other than what we may share with the Social Networking Site in connection with Your linking of accounts, the personal information and Social Networking Site has about You is obtained by the Social Networking Site independent of our Service. Other Services follow different rules regarding the use or disclosure of the personal information You submit to them. We encourage You to read the privacy policies or statements of the other Services You use. 
  • Law and Order:We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as intellectual property rights, fraud and other rights. We can (and You authorize us to) disclose any information about You to law enforcement and other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or You to legal liability.

WHAT PERSONAL INFORMATION IS SHARED WITH OR ACCESSED BY THIRD PARTIES?

True Counsel will share Your personal information with various third parties (including our affiliate companies in other countries) as follows:

  • We use third parties to help us manage Your information and the Services, such as our IT Service Providers, cloud Service Providers and customer Service software and support ticketing Providers. These are companies who are authorized to process data on our behalf only as necessary to provide the relevant Services to us and cannot use it for their own independent purposes;
  • We share Your data with our third-party payment Providers where You have asked us to complete any purchases using our Services. These third-party payment Providers may also ask us to share Your data with them to confirm the nature of any payment transaction and to verify Your identity and payment details;
  • We share Your personal information with companies that assist us with our marketing activities where You have opted-in for such communications; and
  • We or our third-party partners may disclose Your personal information where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party. We may also share Your data with third parties to prevent fraud, abusive or unlawful behaviour or to demonstrate our compliance with other terms or laws.

Any third parties with whom we share Your personal information are limited (by law and by contract) in their ability to use Your personal information for any purpose other than to provide Services for us. We will always take reasonable steps to ensure that any third parties with whom we share Your personal information are subject to privacy and security obligations consistent with this Privacy Policy and applicable laws.

We will also disclose Your personal information to third parties:

  • where it is in our legitimate interests to do so to run, grow and develop our business, such as:
  • if we sell or buy any business or assets, we may disclose Your personal information to the prospective seller or buyer of such business or assets;
  • if substantially all of our or any of our affiliates' assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
  • if we are under a duty to disclose or share Your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
  • in order to enforce or apply our Terms of Service or any other agreement or terms of use, to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
  • to protect the rights, property or safety of True Counsel, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.

We may also disclose and use anonymised, aggregated reporting and statistics about users of our Website or our goods and Services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

Save as expressly detailed above, we will never share, sell or rent any of Your personal information to any third party without notifying You and, where necessary, obtaining Your consent. If You have given Your consent for us to use Your personal information in a particular way, but later change Your mind, You should contact us and we will stop doing so.

HOW WE STORE AND PROTECT YOUR INFORMATION

The Information that You provide, subject to disclosure in accordance with this Privacy Policy, shall be maintained in a safe and secure manner. True Counsel databases and information are stored on secure servers with appropriate firewalls.

True Counsel uses industry standard physical, technical and administrative security measures in accordance with all security standards required under applicable law to safeguard and keep secure Your Information. We conduct periodic reviews of our security measures pertaining to our information collection, storage, to guard against unauthorized access to systems. 

Given the nature of internet transactions, True Counsel does not take any responsibility for the transmission of information including User Information shared by You. Any transmission of User Information on the internet is done at Your risk and True Counsel shall not be responsible for the circumvention of the privacy settings or security measures either by You or any third party.

When You enter User information (such as log in credentials) in respect of Your User Account (“User Information”) or when You upload any Information through the use of the Platform, we take reasonable efforts to ensure that Your User Information and all other information submitted by You is safe and secure; however, the Company makes no representation, warranties or other assurances that the security measures are adequate, safe, fool proof or impenetrable.

As a User of the Services, You have the responsibility to ensure data security. You should use the Services responsibly and not share Your User Information including Your username or password or account information with any person. Do remember that You are solely responsible for all acts done under the account registered to You.

YOUR RIGHTS with respect to Data Retention and Data Deletion

  • Requestfor Deletion

If You no longer want to use our Services and want Your User Account/ personal information to be deleted, You may contact us at …… to request that Your User Account be deleted.  Your User Account and, subject to our data retention obligations, all Your personal information will be deleted within a period sixty (60) days from the date on which You request deletion thereof. 

  • Deletion on Accountof Non-Use

In the event You do not use/ access the Services or Your User Account for a period of twelve (12) months, we will delete Your User Account and all Your personal information. 

If You wish to avail the Services once Your User Account is deleted pursuant to non-use or pursuant to Your request, You will have to sign-up as a new User.

  • Rectification of Inaccurate or Incomplete Information

You can change, alter, modify Your account Information (including User Information) at any time by e-mailing us at ……. . However, please note that in the event You alter, or update or delete Your account information, we cannot ensure the continuity or quality of the Services being provided to You. 

True Counsel may permit or deny modification of any Information, to the extent such information is required by it order to be compliant with and observe applicable laws. You have the right to ask us to correct inaccurate or incomplete personal information concerning You (which You cannot update Yourself using Your User Account).

  • Data Portability

Data portability is the ability to obtain some of Your information in a format You can move from one Service Provider to another. Depending on the context, You may also be entitled to request copies of personal information that You have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another Service Provider (where technically feasible). 

  • Withdrawing Consent and Restriction of Collecting Data.

Where You have provided Your consent to the collecting of Your personal information by True Counsel, You may withdraw Your consent at any time by sending a communication to True Counsel at…. specifying which consent You are withdrawing. Please note that the withdrawal of Your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. However, please note that in the event You withdraw Your consent, we cannot ensure the continuity or quality of the Services being provided to You.

  • Complaints

If You wish to place a complaint with regard to privacy requirements or laws, access any of Your Information or would like to update or correct any errors in Your User Information, please contact our Data Protection Officer/Grievance Redressal Officer: ….. at …. so that we can consider and respond to Your request.

If You have any questions about this Privacy Policy or True Counsel handling practices, You may send email to us at ……

RESTRICTIONS

The Services are only intended for Users who are of 18 (Eighteen) years of age or older (or the age of majority in their country of use) and otherwise competent to contract. If You are not of the requisite age, You are not to provide any User Information or other information. True Consel shall have the right to revoke the provision of Services and delete accounts of Users not compliant with the aforesaid requirement without notice.

AMENDMENTS

This Privacy Policy is subject to change from time to time. If we make changes to this Privacy Policy, we will update the “Last Updated” date at the top of this Privacy Policy. If You disagree with the revised Privacy Policy, You may delete Your User Account.  

TERMS OF USE

This Privacy Policy shall form a part and shall be read in conjunction with the Terms of Use of True Counsel. All capitalized terms used in this Privacy Policy, unless otherwise defined, shall have the meaning set forth in the Terms of Use.

 

 

COOKIE POLICY- TRUE COUNSEL

 

WHAT ARE COOKIES AND WHY DO WE USE THEM?

When You use our Services (as defined in our Terms of Service), we use Cookies, pixels, and similar technologies to gather data about Your use of our Sites.

Cookies are small files that we may send to Your browser when You first use the Sites, which are then stored on Your Device in order to remember information about You (such as login details). Those Cookies are set by us and called first-party Cookies. We also use third-party Cookies – which are Cookies from a domain different than the domain of the Sites You are visiting – for our advertising and marketing efforts. 

We use Cookies in a few different ways under the following categories:

  • Necessary Cookies- These are Cookies that are required for the operation of our Sites or to comply with legal requirements. These cannot be switched off in our systems. They are usually only set in response to actions made by You which amount to a request for Services. 

They include, for example, Cookies that enable You to log into secure areas of our Sites or help to ensure the content of pages loads quickly. You can set Your browser to block or alert You about these Cookies, but some parts of our Sites will not then work. 

  • Functionality Cookies- These are required for our Sites to function correctly and to give You access to the Sites that we offer. For example, these Cookies allow the Sites to remember any settings You make and provide enhanced and more personal features. If You do not allow these Cookies then some or all of our Services may not function properly.
  • Analytical or Performance Cookies– These allow us to recognise and count the number of visitors and to see how visitors move around our Sites when they are using them. This helps us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily. If You do not allow these Cookies, we will not know when You have visited our Sites.
  • Targeting Cookies – These Cookies record Your visit to our Sites, the pages You have visited and the links You have followed. We will use this information to make our Sites more relevant to Your interests. These Cookies may also be set through our Sites by our advertising partners. They may be used by those companies to build a profile of Your interests and show You relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying Your browser and internet Device. If You do not allow these Cookies, You will experience less targeted advertising.

We also use pixels (also referred to as web beacons, clear gifs, pixel tags, and single-pixel gifs). A pixel contains a tiny image that may be embedded within web pages and emails, requiring a call (which provides Device and visit information) to our servers in order for the pixel to be rendered in those web pages and emails. We use pixels to learn more about Your interactions with email content or web content, such as whether You interacted with ads or posts. 

Cookies and pixels collect data about You but are typically constructed with privacy by design. Only the server that sets the cookie can retrieve the data it collects, and the data is often collected on an anonymized basis.

Some content or applications on the Sites are served by third-parties. These third parties may use Cookies alone or in conjunction with web beacons or other tracking technologies to collect information about You when You use our Sites.  The information collected by these Cookies is directly obtained by such third parties, in some cases are not disclosed to us, are used and managed in accordance with the privacy and Cookies policies of those third parties and are not under our control. We do not control these third parties’ tracking technologies or how they may be used. For more information about such Cookies, You should contact the responsible Provider directly. 

HOW CAN YOU MANAGE COOKIES USED ON THE SITES?

You decide if You want to consent to our use of Cookies or not. When You first visit our Sites, You are presented with a cookie banner that allows You to either opt in or opt out from our use of Cookies. If You consent to our use of Cookies, such Cookies will be sent to and stored on Your Device. 

If You opt out and do not consent, we have a special script in place which ensures that no Cookies that collect Your data are being used. You can also choose not to allow some types of Cookies. However, blocking some types of Cookies may impact Your experience of the Sites and the Services we are able to offer.

All browser technologies enable You to manage the Cookies in the cookie folder of Your web browser. This means that You can either delete Cookies from Your cookie folder once You have finished Your visit to our Sites or You can set Your preferences with regard to the use of Cookies before You begin browsing our Sites. Please note, as stated above, that deleting or rejecting Cookies may adversely affect Your user experience of our Sites.

You can find out further information at:

- Google

Firefox

Windows

Safari

 

CHANGES TO THIS COOKIES POLICY

From time to time, we may make changes to this Cookies Policy. If we decide to do so, we will post the changes on our Sites, so that You are always aware of what Cookies we use and how we use them. 

CONTACT DETAILS

If You have any questions, comments or requests relating to our use of Cookies, or if You would like to exercise any of Your rights under this policy, then please contact us at ….

Have a question about our Cookies Policy? ……