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    Privacy Policy

    Steve Medius Private Limited (SMPL) – Privacy Policy
    This Privacy Policy explains how we process the personal information that we collect from our customers/users and prospective customers/users when they use our services, attend our events or premises, subscribe to our newsletters, or use our websites, apps, platforms and services governed by this Privacy Policy (our "Services").

    SMPL is the data controller of your personal information, that is, the entity that determines the ‘purposes and means’ of the processing of the personal information processed about you, or, in other words, the uses for which we process your personal information and the manner in which it is done

    1. When this Privacy Policy applies
    The following Services are subject to this Privacy Policy:
    1. 1.Completing a form on one of our apps or websites.
    2. 2.Contacting us using call back or online chat features
    3. 3.Buying or enquiring about our products and/or services, whether on- or off-line.
    4. 4.Taking part in research, for example a survey.
    5. 5.Using one of our service portals and/or apps.
    6. 6.Attending one of our events, seminars, and contests or attending one of our kiosks at any place.
    7. 7.Taking a query from you, for example about upgrade or repair of a service or product we offer, and fulfilling our obligations to you.
    8. 8.Our marketing of contents, goods and services we think may be of interest to you and your business

    2. Information we collect and what we use it for
    We collect personal information in the following circumstances:

    1. 1.When you have expressed interest in a product or service we or our affiliates or third parties at our platforms offer: We will collect your business contact details, for example, if you approach us online, attend our stall at an event or at any other place where we have our presence, and/or call us about a potential service or product, we will make a note of your details so that we may follow up on your query as well as offering other products and services that may be of interest to you.
    2. 2.Upon registering or availing for a Service we offer: You will be asked for several personal and/or business details that are necessary to create an account and offer you our Services. Some of these fields are marked as compulsory. If you do not provide us with information which is marked as compulsory we may be unable to provide all or part of the Services to you.
    3. 3.When you use our Services: We may collect and process information regarding your use of such Services to improve your overall experience and to fulfil our obligations to you.
    4. 4.When we research our market and find potential buyers: To make sure we are reaching the appropriate business audiences, we may from time to time purchase marketing lists and other databases providing contact details. These may contain your name, business email address and business phone number. However, we do not buy marketing lists which contain your private, outside-of-work contact details.
    5. 5.To improve your user experience and the overall quality of our Services: Knowing your basic personal details lets us personalise any communications we send to you. For example, we collect your role information to ensure we provide marketing which is relevant to your role in your business.
    We go into more detail on how we use the information we collect, below.

    2.1. To Provide Online Accounts
    This is personal information you give us when setting up an online account (for example, our apps) which personally identifies you rather than your business, such as your name, email address or telephone number. There are a number of reasons we need this information to verify your identity and assist with the identification of users; for example, your email address may act as your username to sign into your online account and access our Services.

    2.2. Responding to customer queries
    Your personal details will be processed to respond to queries and assist with the identification of users. For example, your contact information will be collected when you submit a call back form or use our customer chat features and may then be used as an identifier in future. Whenever you fill in a form on our website or app, we may store relevant identity data so that we can trace the history of your query and deal with it more efficiently.

    2.3. Events management
    We collect your information to register you for an event, webinar or seminar which you have expressed interest in, process your payment for the event (where applicable) and provide you with the relevant materials for that event:

    For example, and depending on the kind of event involved, we collect your name, telephone number, emergency contact details (where absolutely necessary), dietary requirements and any other information necessary to enable you to get the most out of your experience

    2.4. To learn about your activities
    2.4.1. Browsing Behaviour, Device Information and Interaction

    We sometimes record details of your actions (for example, repeated site visits, interactions, keywords, online content production) when you access and use our Services so that we can build a customer ‘picture’ over time. It also includes information about the devices and methods you use to interact with our Services and Content, including via a service portal.

    We may combine behavioural information (such as your browsing activity) with your personal details, but we will not store any personal details related to fields left blank by you during your sign-up process. When the use of information which personally identifies you is not necessary to achieve the purposes set out in this section, we will only process behavioural information on an aggregate basis.

    We capture information about your Operating System and Internet Browser when you visit our websites, apps or use our Services, including information that is automatically logged when you use our Services or apps (for example, requested information, timestamp, IP address, and, where applicable and necessary, various network infrastructure and server identifiers).

    We will process your behavioural, device and interactions information for the following purposes:

    1.To provide, maintain, protect and improve products and Services, and to develop new ones:

    1. 1.For example, information about how you browse our websites or search for products can be used for data analysis and research, to deliver better user journeys, provide more relevant search results or structure the way the information is shown in our Services.
    2. 2.When you install our mobile apps, a unique application number along with information about your device is sent to us, making it easier for us to maintain our apps and Services and offer automatic updates.

    2.To improve your user experience and the overall quality of our Services:

    1. 1.Your activity such as the pages you visit or the items you view teaches us what you find important and most interesting to you on our Services so that we can tailor your experience around what matters to you most and display personalised content
    2. 2.Device and platform identifiers let us know which device you are using to access our Services in order to customise and optimise them to your device and improve your overall user experience (for example, providing more relevant content and advertising on the device or browser you are using)..
    3. Storing data locally on your device allows us to improve things like website performance and loading of content even when you are offline.

    3.Subject to the requirements of applicable law, to provide you with marketing communications, for example, more relevant content and offers, and latest news about products and events which we think will be of interest to you and your business:

    1. 1.For example, following a link to a tutorial from a marketing email, or following us on Facebook or Twitter.
    2. 2.Understanding how and where you interact with us means we can provide you with more personalised and helpful information through your preferred communication channels.

    4.To protect our other users and SMPL:

    1. 1.We can monitor unusual or suspicious activities on our services, such as automated abuse, so that we can address it quickly and inform you about potentially fraudulent activities affecting your account.
    2. 2.We might also use your personal information for internal auditing, in order to comply with applicable legal requirements.

    2.4.2. Contents Users’ Details, Apps Usage and Service & Support History
    This is information about our Contents and services or solutions (such as service/s provided, software applications, mobile apps), of how our services or solutions are set up and used (e.g. user set-up and preferences, installation and integration or other settings) and our Services. Sometimes, this information is linked to your business, but at other times it must necessarily be linked to you personally. Some of the information under this category does not qualify as personal information, but we will apply any necessary safeguards to ensure as well the privacy of this information. We will process this data for the following purposes:

    (a) To provide you with more useful information, more relevant content and offers, and latest news about our contents, solutions, services and events: For example, personalised and helpful information, such as expert hints and tips, learning resources, software updates, installation or user guides, or details about relevant training courses.

    (b)To provide, maintain, protect and improve apps, contents and services, and to develop new ones: Understanding how our customers/users use our platforms help us identify features that we need to improve or add to future contents and/or services.

    (c) To help solve any issues you might have with our Contents and Services:

    (d) We require your information so that we can troubleshoot your queries more effectively, providing you with information which is specific to your interests.

    (e)Understanding your Operating System (OS) allows us to troubleshoot your query more effectively, for example, by providing you with information about relevant downloads.

    2.5. To find new customers/users
    To offer our products, contents and services to others who may be interested in them, we sometimes obtain your contact details from our partners in the industry, as well as professional bodies who provide this information to businesses. When we obtain contact details this way we ensure that your contact details are not part of any national opt-out service.

    2.6. To send out surveys and use the results to improve our products, contents and services
    SMPL and its partners occasionally send our customers/users surveys and feedback forms. Where you provide your name and contact details, we may use these to respond to any feedback, provide you with information we think you’ll be interested to hear given your responses and add you to our marketing database (you can opt out of this during the survey, if you’re not interested).
    Our partners may, where permitted, decide on how to use your information for their surveys. Where this is the case, SMPL is not in control of the use of your personal information and you are no longer subject to this privacy Policy. Please read the privacy policies of these partners for more information on their privacy practices or for information on how to unsubscribe.

    2.7. Payment Information
    We do not process or store your bank or credit/debit card details used when purchasing goods and services through our Apps or Services. Payments for purchases are completed through third-party payment platforms which do not share your banking details with SMPL.

    2.8. Cookies and other technologies
    Cookies and similar technologies (e.g. web beacons) are small pieces of information used to store technical and/or personal details, identify users of a service and enable certain functionalities. To learn more about the cookies used by our Services and how to reject them, please visit the Cookie Policy applicable to each of the Services, which can be accessed through the homepage of our websites or the relevant section of our apps.

    Further information about cookies
    If you'd like to learn more about cookies in general and how to manage them, visit, please note that we can't be responsible for the content of external websites.

    2.9. Legal and regulatory requirements and other business purposes
    We sometimes need to process your personal information to comply with applicable laws and regulations, for example where we have an obligation to report suspected fraud.

    There may also be other business-related purposes for processing your information, including negotiating, concluding and performing contracts, managing accounts and records, supporting corporate social responsibility activities, legal, regulatory and internal investigations.

    3. Legal Basis for using your personal information
    We will only process your personal information where we have a legal basis to do so. The legal basis will depend on which of the above purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:
    1. 1.The legitimate business interests of SMPL: where it is necessary for us to understand our customers/users, promote our contents, products and Services and operate effectively IT service provider, managers of various apps and provider of contents, solutions and Services.
    2. 2.Performance of a contract with your business: where you have ordered or requested products or Services from us and we need to use your contact details in order to process your order and deliver the products or Services.
    3. 3.Compliance with law: where SMPL is subject to a legal obligation and needs to use your personal information in order to comply with that obligation.
    4. 4.Consent: for example, where you have provided information to us voluntarily in order to enter a competition. You can withdraw your consent at any time.

    3.1 Our Legitimate Interests
    Our legitimate interests include where it is necessary for us to understand our customers/users in sufficient detail so we can create and publicise new products and Services, and offer our customers/users a better experience. For example:

    1. 1.We perform analytics on this legal basis as they are necessary to provide you with a tailored experience and so that we can improve, maintain and manage our contents and Services in a way which meets your expectations as a customer/user;
    2. 2.We need to use your information so that we can better support and maintain the contents and services which you use;
    3. 3.We use lead and campaign management technology to help us analyse how our customers/users interact with us and ultimately provide more relevant and interesting content to you;
    4. 4.We engage in product development to better our apps, products and services and will use your feedback, from surveys and elsewhere, as part of this process;
    5. 5.Where permissible we market new products and services which we think you may be interested in these, always offering you the option to unsubscribe.

    4. How we share your information
    4.1. Within SMPL
    We restrict access to personal data to people within our group of companies who have a “need to know” such information. For example, we may pass personal data we collect about you to our local sales businesses or local service centres in order to provide our Services where you are located.

    4.2. Outside SMPL, to our partners and third parties
    Your personal information may be shared by SMPL with its Affiliates for their own use related to selling or improving our contents, goods and services. Your information may also be shared with our Affiliates for marketing our goods and services to You, if you have granted Your consent for receiving direct marketing communications from us. Your personal information collected by us when you use our Services, may be shared with or disclosed to our partner companies other than SMPL and its Affiliates, for the purpose of marketing and selling our contents, goods and services to You. We may disclose your personal information to the following third parties, amongst others, for the purposes described here

    1. 1.Vendors or other subcontractors with whom we have a business relationship and who provide products and services to us so that we can provide our Services to you (such as warehousing and delivery, maintenance and servicing partners, software development, website hosting and management);
    2. 2.Third-party service providers which carry out marketing campaigns, lead generation or run customer surveys on our behalf;
    3. 3.Payment processing companies, credit reference agencies and anti-fraud screening service providers in order to process payments and (where necessary) to carry out fraud-screening;
    4. 4.With our professional and legal advisers for the purposes of obtaining commercial, financial or legal advice;
    5. 5.In the event that we sell any business assets, personal information may be disclosed to a potential buyer. In these circumstances, we will make reasonable attempts to ensure the buyer will be bound by the terms of this Privacy Policy;
    6. 6.In exceptional circumstances, personal information may be shared with third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers/users, staff and assets;
    7. 7.We may also disclose your personal information if it is necessary to comply with a legal obligation in any jurisdiction, including where that obligation arises as a result of a voluntary act or decision by us (e.g. our decision to operate to a country or a related decision).

    5. How we protect your information
    Your personal information is held on secure servers and is not processed for any purposes other than those set out in this Privacy Policy. The servers we use to store this information are accessible to authorised staff only and we ensure that adequate security measures are in place.
    Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at the contact details below.

    6. Marketing communications
    SMPL and/or other group companies may use your personal information for marketing purposes and to inform you about other products and services, which we think might be of interest for you. You can specify whether you wish to receive such information by ticking the appropriate box in our forms, or by telling us your preference where we interact in person.
    You will be able to opt out from receiving such information at any time from the relevant preference centre or by unsubscribing using a link/mechanism provided in all applicable communications. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time (for example, to confirm an order you have made or to confirm delivery details).

    7. How to exercise your rights
    We will delete your personal information once it is no longer necessary for the purposes for which it was originally collected.
    You also have the right to object to your personal information being used for certain purposes, including to send you marketing, for more details of how to opt-out of marketing.
    We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal information, or if you have any questions or concerns regarding your personal information, you should contact us using the details below.

    8. Retention of your information
    SMPL will keep your personal information for as long as we need it for the purposes set out in this Privacy Policy and in accordance with any retention periods required by applicable laws and during the relevant statutes of limitations. This term should typically not exceed 8 years in most jurisdictions. Please note that where you unsubscribe from our marketing communications, we will keep a record of your communication information to ensure we do not market to you in future.
    SMPL will not delete your personal information where it refers to an active relationship or a product or service explicitly requested by you.

    9. Your commitments
    You guarantee the quality of the information provided in our Services. All personal information you send to us must be real, accurate and kept up to date. You take full responsibility that your information is accurate, updated and that it complies with this principle.

    10. Changes to this Privacy Policy
    We will update our Privacy Policy from time to time to ensure you are promptly informed of our data processing activities. We will not engage in any processing operations that might put at risk your personal information, and will gather your explicit consent where necessary to safeguard your right to privacy. We will keep you updated on any changes to this Privacy Policy through the Services on our website from time to time. If you continue using our Services after the updated Privacy Policy on our website, you agree to be bound by the updated terms.

    11. Contacting SMPL

    Please contact us with any questions or comments about this Privacy Policy at our Office mentioned below;

    Compliance Office
    Steve Medius Private Limited
    1108 Kailash Building 26, Kasturba Gandhi Marg New Delhi 110001