1. SCOPE OF THIS PRIVACY POLICY

1.1 This Privacy Policy outlines the information we will collect and how we will use that information. This Privacy Policy will also instruct you on what to do if you do not want your personal information collected or shared when you visit the Website.

1.2 This Privacy Policy applies only to our online activities and is valid for visitors to our Website with regards to the information that they shared and/or collected. This Privacy Policy is not applicable to any information collected offline or via channels other than this Website.

1.3 If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

2. WHAT INFORMATION WE COLLECT

We collect information in multiple ways including when you provide information directly to us, when you permit third parties to provide information to us, and when we passively collect information from you, such as information collected from your browser or device. The list mentioned below is illustrative, not exhaustive. We collect and process two main types of personal information and data; Personally identifiable Information and Data (“Personal Data”) and Non- Personally Identifiable Information and Data.

2.1 Collection of Personally Identifiable Information

We collect information you give us or permit us to access. Information may include, but is not limited to, your name, image, birth date, email and physical address, telephone number, gender, contact lists, social media information and profile, activity and performance information, and when necessary, credit card information.

2.2 Information we get when you use the Website

When you access or use our Website, we may automatically collect certain information about you and how you use the Website. This may include:

a. Website: The information gathered on the Website generally includes company names, locations, times and dates of access, and the web pages viewed while visiting. Additionally, information is collected on the search engines and search phrases used to find our Website. We may also collect the name of internet service providers and the operating system of your computer. User registration may be required to access some of the features on our Website, for which you may be required to provide your name, title, company, e-mail address, and phone number.

b. Please note that one cannot identify a specific individual by using Device Information or Log Information alone. However, these types of non-personal information, combined with other information, may be used to identify a specific individual, such non-personal information will be treated as personally identifiable data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such non-personal information.

2.3 Information we get from third parties

We may also get information about you from other third parties wherever permitted by applicable law. For example, we receive information from:

a. third-parties who help us to supplement the information you have provided and to ensure the accuracy of your information. For example, we use third party service providers to validate your identity or address.

b. third parties who provide us with information about you or your interaction with our Website. For example, we may obtain service and support information or technical issues you may have raised with these third parties.

c. We may also combine that information with data that is publicly available and data from third parties.

We collect this information from individuals/organizations/business enterprises who willingly submit such information to us. Those Users who do not wish to supply their personally identifiable Information, may be prevented from engaging in certain Website-related activities. If you do not want your personally identifiable information collected, please do not submit it to us. If you have already submitted this information and would like for us to remove it from our records, please contact us at the email address or phone number listed at the bottom of this Privacy Policy. We will use reasonable efforts to delete your information from our existing files.

2.4 Sources of Collection of Non-Personally identifiable Information

We may also collect data from non-personally identifiable information sources such as web browsers, operating systems, bookmarks, page views. This may include browser name, specific device or computer, technical information such as connection to our Website such as the operating system and the Internet service providers and such other information. When you access or use our Website, we may automatically collect certain information about you and how you use the Website. This may include:

a. Device information: We may collect device information such as the MAC address of your devices, Internet Protocol (“IP”) addresses, log information, error messages, device type, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information and unique device identifiers. For example, we may collect IP addresses from you when you log into the Website as part of our log-in and security features.

b. Usage Information: We may collect usage information such as the pages you viewed, the features you use, your browser type, visits, clicks, downloads, messages sent/received, and any links you click on to leave or interact with our Website.

c. Log Information: When you use our Website, the system and exception log may be uploaded.

d. Content: We may also collect content that you provide through the Website or content that is automatically collected in the background.

e. Information from Cookie and other Technologies: GHC and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects, and similar technologies (collectively, “Cookies”) to provide the product/services you requested, recognize your visit, track your interactions with our Website, and improve your and other clients’ experience. Data collected through Cookies will help us in understanding consumer behaviour and analysing website traffic. If Cookies are disabled, certain areas of our products and features on our Website may not work properly. You have control over some of the data we collect from Cookies and how we use it, you may manually accept, decline or ignore the pop-up displayed.

f. Tracking Devices. We may use other industry standard technologies like pixel tags and web beacons to track your use of our Website pages and promotions, or we may allow our third party service providers to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our Website, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, pixel tags and web beacons generate a non-personally identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behaviour on our Website, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our affiliates and/or marketing partners for the same purposes.

g. Google Analytics. We currently use Google Analytics to collect data and information. This helps us analyse data about Your visit to our Website as well as understand how our products are being used.

h. Local Storage. We may collect and store information (including personal information) locally on your device.

2.5 Required Information

Some of the functionalities in our Website may require you to provide information in order for you to use the Website. If you do not wish to provide the required information, you may not be able to use certain features or the Website. We will try to let you know what information is required and what information is optional. We may also combine information that you provided us with information about you that we get from other sources, in accordance with applicable law.

3. HOW DO WE USE YOUR INFORMATION

We use your information in various ways, including to:

3.1 Enable your use

a. Enhance, customize and personalize your experiences and communications;

b. Operate, provide, improve and maintain GHC’s Website, including analyzing user behavior and trends; and

c. Send you administrative messages and other information about GHC. Communicate with you about your purchase, account information or customer service, if any.

3.2 Provide and conduct marketing and promotions

a. Communicate with you about our products and events, and for other promotional purposes;

b. Administer contests, promotions, events, surveys or other features; and

c. Display relevant marketing to you.

3.3 Sharing information

We may provide your information to our affiliates, some of which may be outside India.

3.4 Management of information technology systems

We may use your data for management and operation of our communications, information technology and security systems; and audits (including security audits) and monitoring of such systems

3.5 By law or to protect rights

a. We may disclose information upon governmental request, in response to a court order, when required by law, to enforce our policies, or to protect our or others' rights, property or safety.

b. We may share information to prevent illegal uses of GHC’s products or violations of the Privacy Policy, or to defend ourselves against third-party claims.

c. We may also share information with companies assisting in fraud protection or investigation.

d. For compliance with our legal and regulatory obligations under applicable law.

e. Establishing, exercising and defending legal rights.

3.6 Fraud prevention and detection

a. We may process data in detecting, preventing and investigating fraud.

b. We may use data in detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

3.7 Improvements

For improvement of our Website, identifying issues with our Website; planning improvements to Website; and creating a new Website.

3.8 Business Transfers

Your information may be transferred to a third party as a part of our business assets (in a sale of a part or all of GHC). If this should happen, notice will be provided by posting to the Website or other form of communication.

4. HOW DO WE SHARE YOUR DATA

4.1 Public Sharing

a. Default sharing When you join or use the Website, you agree to publicly share a basic amount of information, which may include your name, city location, and contact details.

b. Sharing you choose You may choose to share certain information. In order to participate in certain features, you may have to adjust your privacy settings and share more information. You may also choose to share your activity on other platforms, such as Facebook and Twitter. Please read the privacy policies of those platforms, because your GHC activity published on those platforms will no longer be governed by this Privacy Policy.

c. GHC sharing Information that is publicly shared may be used by GHC for promotional purposes.

4.2 Disclosure of Personal Data to third parties

We disclose Personal Data to legal and regulatory authorities; our external advisors; our processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Website.

We disclose Personal Data to other entities within the GHC group (for legitimate business purposes and the operation of our Website, to you), in accordance with applicable law. In addition, we disclose Personal Data to:

a. you and, where appropriate, your appointed representatives;

b. legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

c. accountants, auditors, lawyers and other outside professional advisors to GHC, subject to binding contractual obligations of confidentiality;

d. third party processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below;

e. any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;

f. any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

g. any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

h. any relevant third-party provider, where our Website uses third party advertising, plugins or content.

If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content. If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

5. LINKS TO THIRD PARTY WEBSITES

This Website may contain links to third party sites. Access to any other Internet site linked to this Website is at the User’s own risk and GHC is not responsible for the accuracy or reliability of any information, data, opinions, advice or statements made on these sites. GHC provides these links merely as a convenience and the inclusion of such links does not imply an endorsement.

6. INTERNATIONAL TRANSFER OF DATA

Because of the international nature of our business, we may transfer Personal Data within the GHC group, and to third parties, in connection with the purposes set out in this Privacy Policy. For this reason, we transfer Personal Data to other countries that may have different external privacy laws and data protection compliance requirements to those that apply in the country in which you are located. We will nevertheless process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Privacy Policy.

7. TRANSMISSION/SHARING OF INFORMATION

7.1. We do not sell, trade, or rent Users’ personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

7.2. We may use third party service providers to help us operate our business and the Website or administer activities on our behalf. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

8. RETENTION OF PERSONAL DATA

We take every reasonable step to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Privacy Policy. We will retain Personal Data in a form that permits identification only for as long as:

8.1 we maintain an ongoing relationship with you (e.g., where you are a user of our Website, or you are lawfully included in our mailing list and have not unsubscribed); or

8.2 your Personal Data are necessary in connection with the lawful purposes set out in this Privacy Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in processing those data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data)

8.3 If we no longer need your information for the above purposes, we will generally delete or de-identify and anonymize it in accordance with our standard data retention practices. However, there may be occasions where we are unable to fully delete or de-identify your information due to technical or other operational reasons, for example, where your information has been archived onto back-up systems. Where this is the case, we will take reasonable measures to securely isolate your information from any further processing until such time as we are able to delete or de-identify it. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it.

9. SECURITY OF YOUR INFORMATION

We understand that the security of your information is important to you. We take reasonable care and precaution and provide appropriate technical and organizational security controls to protect your information. At GHC, we implement security controls to prevent breaches of unauthorised access to User data, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Website. But, even with our best efforts, we cannot ensure or warrant the security of your information. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. GHC is not responsible for the unauthorized use of your information nor for any lost, stolen, compromised passwords, or for any activity on your account via unauthorized password activity.

10. WHAT YOU CAN DO TO MANAGE YOUR PRIVACY

10.1. Update your Privacy Setting You may update your privacy settings directly through the Website by visiting your account settings.

10.2. Manage Marketing Communications from us We honour your choices when it comes to receiving marketing communications from us. To update your preferences (including to opt-in or opt-out of marketing communications) you can unsubscribe using an unsubscribe link on marketing emails.

10.3. Cookies and Other Tracking Technologies You can find information on changing your browser settings to opt-out of optional Cookies in your browser settings. If you disable some or all of the Cookies, some parts of the Website may not work.

11. DISCLAIMER OF LIABILITY

YOU MAY PROVIDE INFORMATION AND CONTENT ON OUR WEBSITE. THIS INFORMATION THAT YOU INPUT MAY PERTAIN TO, BELONG TO OR OWNED BY YOU OR ANY OTHER THIRD PARTY. YOU HEREBY AGREE AND ACKNOWLEDGE THAT WITH RESPECT TO ANY INFORMATION THAT YOU INPUT INTO OUR WEBSITE, WHETHER BELONGING TO YOU OR ANY THIRD PARTY, YOU PROVIDE THE REQUISITE CONSENT TO US FOR ITS COLLECTION, USE AND STORAGE IN ACCORDANCE WITH THIS PRIVACY POLICY AND THAT YOU HAVE THE REQUISITE AUTHORIZATION FROM SUCH THIRD PARTY TO PROVIDE SUCH INFORMATION. GHC SHALL NOT BE LIABLE OR RESPONSIBLE FOR ANY LIABILITIES ARISING OUT OF THE SHARING OF ANY SUCH DATA OR INFORMATION BY YOU ON OUR WEBSITE AND GHC EXPRESSLY EXCLUDES AND DISCLAIMS ANY SUCH LIABILITY. YOU, THE PROVIDER OF INFORMATION AND DATA SHALL BE SOLELY LIABLE FOR PROVIDING SUCH INFORMATION AND ANY LIABILITIES ARISING OUT OF ANY CLAIMS MADE BY SUCH THIRD PARTIES.

12. MERGER/ACQUISITION

As is with any other businesses, we could merge with, or be acquired by another company. If this occurs, the successor company would acquire the information we maintain, including personally identifiable information. However, such personally identifiable information would remain subject to this Privacy Policy.

13. SECURITY PRECAUTIONS

We maintain reasonable physical, electronic and procedural safeguards to protect your information. Whenever you access your account information, we offer the use of a secure server. Once your information is in our possession, we adhere to our security guidelines to protect it against unauthorized access. However, by using the Website, the User accepts the inherent security implications of data transmission over the internet and the world wide web which cannot always be guaranteed as completely secure, and therefore, there would always remain certain inherent risks regarding use of the Website. The User understands these inherent risks and agrees that GHC shall not be responsible for any unauthorised access, breach of security and/or the unauthorised usage of Users’ data.

14. HOW TO CONTACT US

If you have questions about this Privacy Policy or our Website, please contact us at Email: info@ghcpl.uk

15. CHANGE TO OUR PRIVACY POLICY

We may change and update this Privacy Policy from time to time and for any significant changes affecting your personally identifiable information, we will update the Website accordingly and provide written notice to you, which, for these purposes, shall include an email sent to the email address you have on file with us. If you disagree with any change, you must stop using the Website. The continued use of the Website will be considered as acceptance of the change.

16. GOVERNING LAW AND DISPUTE RESOLUTION

You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of India and all disputes arising out of or in connection with this Agreement shall be finally settled by arbitration in accordance with Indian Arbitration and conciliation act, 1996 as amended from time to time. The seat of Arbitration shall be at New Delhi. The arbitral tribunal (AT) shall be of Sole Member. The award of (AT) shall be final and binding on parties. The language of arbitration shall be English.

16. GOVERNING LAW AND DISPUTE RESOLUTION

You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of India and all disputes arising out of or in connection with this Agreement shall be finally settled by arbitration in accordance with Indian Arbitration and conciliation act, 1996 as amended from time to time. The seat of Arbitration shall be at New Delhi. The arbitral tribunal (AT) shall be of Sole Member. The award of (AT) shall be final and binding on parties. The language of arbitration shall be English.

The courts of New Delhi shall have jurisdiction over the dispute related to this Privacy policy.

17. GRIEVANCE OFFICER

In accordance with Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Grievance Officer are provided below: