Care To Play (C2P) Privacy Policy

Updated as of 03 January 2024.

In this policy (“Privacy Policy”), we the Care to Play group set out how your personal information is collected, received, used, stored, possessed, dealt or handled. We value the trust placed in us by you and therefore, we take significant efforts to protect your personal information (“PI”) including sensitive personal information (“SPI”).

The term “PI” and “SPI” are hereinafter for the sake of brevity and convenience collectively referred as the “Information”.

References to “we”, “our” or “us” shall mean the Care to Play group and its activities. Any references to “you”, “your” or “user” shall mean any person providing information to our representative.

The Care to Play group is comprised of Indus Action Initiatives, Trickle Up Program Inc., Everdeen Learning Pvt. Ltd. (“Rocket Learning”), and IDinsight India Private Limited (“Care to Play Entities”). Trickle Up Program Inc., Everdeen Learning Pvt. Ltd., and IDinsight India Private Limited have appointed Indus Action Initiatives as the data processor on their behalf and Indus Action Initiatives will collect, process and share Information from you on behalf of itself and the Care to Play Entities to carry out the Activities (as defined below).

By providing your Information, you agree to the terms and conditions of this Privacy Policy.

Alternatively, if you have any questions or clarifications, please reach out to us at the details provided in para 9 below.

1. THE INFORMATION WE COLLECT AND HOW WE USE IT

Information collectedPurposes for which we collect/process Information

At the time of registration, we collect the following information from you:

  • Name
  • Contact details (mobile number and email address)
  • Date of birth
  • Identification documents

Usage data

We and certain third parties on our behalf may also collect the following information about you and, our Activities in relation to you, and your interactions with us:

  • Location data
  • IP address
  • interactions on emails, communications, messages and other channels information that you provide to our representatives including through your survey responses

The information we collect from you will be used for the following purposes (“Activities”):

  • to assess eligibility for various government programmes
  • to communicate with you
  • to generate research and insights
  • for marketing and promotional purposes
  • to provide benefits under Care to Play programmes

2. DISCLOSURE

At times, we may share your Information with certain trusted partners, some of whom are set out below.

  • Others working for and with any of the Care to Play Entities. Each of the Care to Play Entities uses certain trusted third parties, vendors or sub-processors (for example, providers of support and IT services) to help us carry out and improve the Activities.
  • Partnerships with research and development institutions. We may share your information with entities engaged in research and development.
  • Relevant governmental authorities. We may be required to disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; or (b) provide any benefits under government programmes; or (c) perform a task carried out in the public interest.
  • Successors or assigns of the Care to Play Entities. If another person acquires any of the Care to Play Entities, that person will possess your information including personal information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy. If any of the Care to Play Entities is involved in a [merger, acquisition, bankruptcy, reorganization or sale of assets] such that your information would be transferred or become subject to a different privacy policy, we will notify you of such actions in advance.
  • Legal or contractual obligations of the Care to Play entities. We may share your information from time to time if required to enforce or apply our respective terms of use and/or any other agreements.

3. SECURITY

We and our data processors have in place appropriate technical and security measures in line with industry standards and applicable laws to secure the information collected by us. We are continuously implementing and updating administrative, technical, and physical security measures to help protect your personal information including sensitive personal information against unauthorized access, loss, destruction, or alteration.

We and our data processors use commercially reasonable security practices and procedures, industry practices and procedures designed to help keep your personal information safe and secure. Some of the safeguards we use to protect your information include anonymisation of your personal data and aggregation of data prior to sharing with third parties where required. Unfortunately, the transmission of information over the Internet is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of your data while it is being transmitted; any transmission is at your own risk.

As you are aware, we may share your information with third parties, such as our vendors and suppliers, who may share such information further (for permitted purposes). We will ensure, on a commercially reasonable efforts basis and through contractual protections, that such information is shared in accordance with applicable laws.

4. WHERE YOUR INFORMATION IS STORED

Your information may be transferred to or may be maintained on computers, computer systems and computer resources located outside India where the privacy laws may be different (but no less stringent than the restrictions imposed by Indian law) as those where you live. We shall ensure the same level of data protection is adhered where your information is transferred or maintained.

5. CHANGES TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully modifies your rights, we will notify you.

6. YOUR CONTROL AND ACCESS OF YOUR INFORMATION

You have control over your personal data and how it’s collected, used, stored, processed and shared. You may correct, amend, add or delete your Information.

If you reach out to the Grievance Redressal Officer (details provided in para 9) you will be provided on request, and as feasible,

  1. access to the following:
    1. a summary of Information being processed by us, and the processing activities in relation to such Information,
    2. identities of any third parties with whom we have shared your Information.
  2. correction of inaccurate or misleading Information about you
  3. completion of any incomplete Information or updating any Information about you

However, we may be required to retain your Information for audit, review or compliance with applicable laws. Further deletion of information may result in us suspending the services being provided to you. In case you do not agree with the terms and conditions after giving your consent, you may withdraw your consent at any time.

7. DATA RETENTION

We do not retain your Sensitive Personal Information for longer than is required for the purposes for which the information may be lawfully used. “Sensitive Personal Information” shall mean passwords, financial information, physical, physiological, and mental health condition, and any other information that is classified as Sensitive Personal Data or Information under Section 3 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011.

8. COMMUNICATIONS FROM US

The Care to Play Entities may from time to time send you announcements and updates when they consider it necessary to do so for each of their relevant projects (such as for updates or key events such as maintenance, or security, privacy, or administrative-related communications). We send these to you via SMS, messaging platforms, emails among other means.

You may opt out from unwanted messages or e-mail communications from us by following the instructions provided in such a message.

9. GRIEVANCE REDRESSAL

If you have any /questions about this Privacy Policy, the Activities, your dealings with us, or any grievances with respect to the processing of your Information or the exercise of your rights under this Privacy Policy you can contact the Grievance Officer at grievance@indusaction.org or you can write and send a letter to us at the below address:

Indus Action Initiatives, G-7, 2nd Floor, Lajpat Nagar III, New Delhi – 110024
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