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Privacy Policy

Last Updated: [●], 2024

This Privacy Policy (“Privacy Policy“) sets out how First Livingspaces Private Limited (formerly known as TCG Livingspaces Private Limited) (“Company“), having its registered office at Bengal Intelligent Park, Building.-Delta, 2nd Floor, Block EP&GP, Sector V, Salt Lake Electronics Complex, Kolkata - 700091 (“Company“, “we“, “us“ or “our“) collect, use, disclose, and safeguard personal and sensitive personal information in connection with your use of Sirrus.ai (hereinafter referred to as “Sirrus.ai“).

For the purposes of this Privacy Policy, “Permitted User“ refers to any legal person such as the officer, employee, partner, director or client of the Customer i.e., the legal entity availing the Services, who may access and use Services on the directions of the Customer, accessing or using Sirrus.ai and the Services thereunder, who is competent to enter into binding contracts, as per the provisions of the Indian Contract Act, 1872. For the purpose of this Privacy Policy, “you“, “your“ or “user“, as applicable, means the Permitted User.

As used herein, the term “Services“ means Sirrus.ai, an online software-as-a-service platform which is an AI-driven application, that seeks to automate operations. It equips the Permitted User with advanced tools for inventory management, intelligent content creation, AI driven sales funnel analysis and post-sales assistance. Sirrus.ai is managed and provided by First Livingspaces Private Limited (formerly known as TCG Livingspaces Private Limited), to the Permitted User in form of module(s)/features which collectively forms part of the Platform.

This document is published in accordance with the provisions of the Information Technology Act, 2000, and the Indian Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“Privacy Rules“) made thereunder and any other applicable law that require publishing the rules and regulations, Privacy Policy, and Terms of Use. We request the Permitted User to go through this Privacy Policy, General Terms and Conditions for the use of Sirrus.ai and Terms of Service carefully before deciding to access or use the Services.

We are committed to respecting and protecting the privacy of the Permitted User and the Personal Information we may obtain through Sirrus.ai or any other services. Accordingly, we have created this Privacy Policy to inform all Permitted Users about how we collect, use and share Permitted User's information and Personal Information of Customer's clients in general.

By clicking on [“I agree/I accept“] at the time of downloading/accessing/using Sirrus.ai, you agree to the terms and conditions of this Privacy Policy. If the terms outlined in this Privacy Policy do not align with your preferences, we recommend refraining from subscribing to our Services or disclosing any Personal Information.

  1. TYPE OF INFORMATION COLLECTED

We may collect and process information from you through your use of Services or which is provided to one of our marketing partners or through any engagement with Sirrus.ai through cookies or other similar tools. We may collect and process the following information, including but not limited to:

  1. We may collect a variety of information from you, including but not limited to your name, password, mailing address, phone number, email address, business category, GSTIN (if any), business ownership type, business address, with proof of Business Documents (Certificate of Incorporation, GST Registration License, PAN number, logo, brand name, Trademark Certificate and any other statutory registration number/ document and Personal Documents (Driving License, Passport, Voter's Id) (“Registration Documents“). We may collect such information which when combined with other pieces of information available with us could reasonably allow you to be identified (“Personal Information“).
  2. all data that is automatically captured such as your mobile phone operating system, which, when connected to the Internet, assigns a domain name and Internet Protocol (IP) address to facilitate data transmission. When accessing specific pages within Sirrus.ai, our servers inherently recognise your domain name and IP address. While this process involves the collection of your IP address, it does not entail the disclosure of any personally identifiable information. The technical information may include referring or exit pages, clickstream data, operating system. This data includes usage information and user statistics.
  3. Location information obtained through GPS or other means to know the geographical location of the user.
  4. Certain financial information like Bank Account details or credit card or other payment instrument details as may be required to facilitate the processing of payments made through Sirrus.ai. As making payment may require utilization of the services of the payment service providers, you will be subject to the terms of use and privacy policy of such payment service provider as well.
  5. We collect standard website access information (type of browser etc.) using cookies and other similar tracking technologies on Sirrus.ai. We do this to measure, improve and personalize our Services for you and we do not share this information with any third party organizations for commercial purposes.

We don't sell or trade user information in any form to anyone. The information is used solely for the purpose of enabling Services and making your experience better.

We remain committed to upholding your privacy rights and ensuring compliance with relevant data protection regulations.

If you choose not to permit us to collect such information, we may not be able to provide you with relevant Services and respond to your queries or resolve any problems which you encounter.

  1. USAGE OF INFORMATION COLLECTED

The primary objective of collecting, storing and processing your information by us is to facilitate the provision of our Services.

The personal and sensitive Personal Information provided by you is used for the following legitimate and lawful purposes:

  • To facilitate the provision of Services to you;
  • To monitor, improve and administer the quality of Services;
  • To provide you with beneficial schemes, new offers, and experience enhancement;
  • To analyse how Sirrus.ai is used, diagnose technical issues and improve user experience;
  • To store the information provided by you for efficient access;
  • To verify your identity and determine your eligibility to use Sirrus.ai and avail the Services;
  • To notify you about any relevant changes or updates;
  • To comply with legal and regulatory obligations;
  • To send administrative notices and service-related alerts and similar communications, as detailed under this Privacy Policy, to optimize efficiency;
  • To facilitate market research, troubleshoot issues, protection against error, project planning, prevent fraud and other criminal activity;
  • To enforce Terms of Service and General Terms and Conditions for the use of Sirrus.ai;
  • To send you information about our Services for marketing and promotions;
  • To establish communication with you including through email and text about transactions and related matters;
  • To establish, exercise, or defend legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings;
  • To facilitate assets sales, mergers, acquisitions or bankruptcy;
  • Account setup, administration, and verification;
  • Personalization of content, business information, or user information;
  • Periodic communication about new features, newsletters, contests, compliance requirements, and offerings;
  • Use of information by third-party advertisers for interest-based advertisements with user consent;
  • To provide accurate insights, analytics, trend identification, statistics to further enhance the effectiveness and efficiency of our Services and additional value-added services;
  • Using information to improve safety, reliability, and security across platforms by detecting, preventing, and responding to security risks, fraud, or technical issues that may harm users or the platform.

Information collected from you may be transferred to a third party as a result of a sale or acquisition, merger or bankruptcy involving the Company or in other cases by obtaining your prior explicit consent or as necessary, in accordance with this Privacy Policy and applicable laws.

  1. USE OF COOKIES

Cookies are small portions of information saved by your browser on your device. Cookies are used to record various aspects of your visit and assist us in providing you with uninterrupted service.

By clicking “Accept” on the cookie banner, you give us your consent to store and access cookies and other tracking technologies as described in the Cookie Policy accessible here[•]. Any information that is gathered by cookies or other tracking technologies, and the use of the same is subject to the disclosures and options provided in the Cookie Policy.

The Cookie Policy should be read together with our Privacy Policy, our General Terms and Conditions for the use of Sirrus.ai and Terms of Service.

  1. INFORMATION SHARING AND DISCLOSURES

We may share the Personal Information we collect or that you provide, as detailed in this privacy policy, through the following methods-

  1. Information may be shared with our Parent company, subsidiaries and affiliated entities under common ownership to facilitate the delivery of our Services or to comply with applicable laws.
  2. When Permitted Users contact Company's customer care for specific queries or issues, our customer care personnel may access your information to effectively resolve your concerns.
  3. Our Services may include third party services or links to external third-party websites. Please note that we do not control the content or privacy practices of these websites or services. We neither endorse nor make representations about third-party websites or services. Our Privacy Policy does not extend to information provided to or collected by these third parties, and users are advised to exercise caution when interacting with them.
  4. The Company collaborates with Third-Party Service Providers to extend variety of services on our behalf, including but not limited to Communication Services (SMS, push notifications, emails, WhatsApp services, etc.), banking partnerships, payment gateways, analytics platforms, cloud services, ANPR/hardware integrations, etc. These providers are contractually obligated to maintain the confidentiality of personal data and use it solely for the purposes disclosed.
  5. You acknowledge and consent to the potential sharing or transfer of your personal and sensitive information to third-party service providers. This sharing is strictly for the purpose of enabling these third-party service providers, which may include entities like Google and other social media platforms, to display advertisements and notifications on various websites across the Internet. These actions are based on the data collected by the Company through Sirrus.ai
  6. We cooperate with Government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose your information (including personal and sensitive Personal Information), including disclosure to third parties such as Government or law enforcement officials or private parties, as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of the Company, our Services, or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without giving notice to you.

Upon signing up for our Services and clicking on [“I agree/I accept“], you agree to share your information as necessary for the provision of these Services.

  1. INFORMATION SECURITY

We take data security and confidentiality seriously. We have adopted security measures that are in line with industry standards to protect the personal and sensitive Personal Information you provide, and to prevent unauthorized access, public disclosure, use, modification, damage or loss of the data. We take all reasonable and practical steps to protect your personal and sensitive Personal Information and have put in place appropriate methods and security practices to safeguard and secure all your personal and sensitive Personal Information and data. We only process personal and sensitive Personal Information and data in a way that is compatible with and relevant to the purpose for which it was collected or authorised by the user.

The Company allows users access to their personal and sensitive Personal Information and allows them to correct, amend or delete inaccurate information.

The Company uses commercially reasonable precautions to preserve the integrity and security of your information against loss, theft, unauthorised access, disclosure, reproduction, use or amendment. However, please be informed that, despite our best efforts, no security measures are perfect or impenetrable. So, if you have any concerns that your personal and sensitive Personal Information has been put at risk, please get in touch with us.

The information that is collected from you may be transferred to, stored and processed at any destination within and/or outside India, in accordance with the applicable laws. By submitting your information, you agree to this local and/or cross-border transfer, storing and/or processing. We will take such steps as it considers reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy.

By using our Services, you accept the inherent security implications of data transmission over the Internet. Therefore, the use of Services will be at your own risk and the Company assumes no liability for any disclosure of information due to errors in transmission, unauthorised third-party access or other acts of third parties, or acts or omissions beyond its reasonable control and you agree not to hold the Company responsible for any breach of security.

In the event, the Company becomes aware of any breach of the security of your information, it will promptly notify you and take appropriate action to the best of its ability to remedy such a breach.

  1. EXCLUSION

This Privacy Policy does not apply to any information or data about you other than those collected by the Company through use of Services, including such information collected in accordance with the above-mentioned clause 1 “ Type of Information Collected“. This Privacy Policy will not apply to any unsolicited information about you and provided by you through Sirrus.ai or through any other means. This includes, but is not limited to, information about you posted on any public domains. All such unsolicited information shall be deemed to be non-confidential and the Company will be free to use, disclose such unsolicited information without limitation.

Access to personal and sensitive Personal Information is limited to employees, agents, partners and third parties, who the Company reasonably believes will need that information to provide Services to you. However, they are not responsible for the confidentiality, security or distribution of your personal and sensitive Personal Information outside the scope of our agreement with such partners and third parties.

  1. RETENTION OF DATA

Sirrus.ai shall not retain your personal and sensitive Personal Information longer than is necessary to fulfil the purposes for which it was collected and as permitted by applicable law. At the expiry of such periods, your personal data will be deleted or anonymised to comply with legal retention obligations or in accordance with applicable statutory limitation periods.

If you wish to cancel your registration or request that the Company no longer uses your information, contact us through our grievance officer via email at grievanceofficer.fls@tcgre.com.

Even after your account is terminated, you consent to the Company retaining your personal and sensitive Personal Information only as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account, investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons relating to the Services availed by you.

  1. RIGHT TO WITHDRAW CONSENT

The consent that you provide for the collection, use and disclosure of your personal and sensitive Personal Information will remain valid until such time it is withdrawn by using the functionalities provided in Sirrus.ai. If you withdraw your consent, we will stop processing the relevant personal and sensitive Personal Information except to the extent that we have other grounds for processing such information under applicable laws. You may withdraw your consent at any time by using the functionalities provided in Sirrus.ai.

  1. CORRECTION/UPDATION/ERASURE OF DATA

You are responsible for maintaining the accuracy of the information you submit to us, such as (but not limited to) your contact information provided as part of account registration. The Company relies on the users to disclose all relevant and accurate information and to inform of any changes. If you wish to make a request to correct or update or erase any of your personal and sensitive personal data which we hold about you, you may submit your request through the functionalities provided in Sirrus.ai.

  1. RIGHT TO ACCESS

You have the right to obtain a summary of personal data you have provided to us, the processing activities conducted, and the third parties with whom such data has been shared, and any other information as may be required to be provided to you under applicable law.

  1. RIGHT TO NOMINATE

You have the right to nominate any individual who will exercise your rights in case of your death or incapacity.

  1. NOTIFICATION OF CHANGES

From time to time, we may update this Privacy Policy for keeping our privacy practices attuned with new technologies, industry practices, regulatory requirements or for other purposes. Any changes will be effective immediately upon the posting of the revised Privacy Policy. If the Company makes any material changes and law requires us to let you know, the Company will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Services prior to the change becoming effective. Should you choose to not “agree“ with the revised Privacy Policy, you may indicate the same by using the functionalities on Sirrus.ai. If you withdraw your consent, we will stop processing the relevant information except to the extent that we have other grounds for processing such information under applicable laws. We encourage you to periodically review this page for the latest information on our privacy practices.

  1. CHOICE TO OPT OUT

When you register, you may receive communications from Sirrus.ai, and you have the option to opt out of future communications at any time. This can be done through the functionalities provided in Sirrus.ai.

  1. GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000, and the rules made thereunder and other applicable laws, the name and contact details of the Grievance Officer are provided below. Any questions regarding this Privacy Policy or your rights, or any user grievance relating to the discrepancies or misuse of information so provided to Sirrus.ai may be addressed to the grievance officer, whose details are provided below.

Name: Punit Pande, Head of Operations

Email Id: grievanceofficer.fls@tcgre.com