Privacy Policy

Viacom18 Media Private Limited (“We”, “Us”, “Our”, “Viacom18”) is strongly committed to the data subject’s (“You”, “Your”, “User”) right to privacy and to keeping Your in formation secure. To earn Your trust and confidence in Our commitment, We are fully disclosing Our privacy practices. We encourage You to read Our privacy statement to understand what types of information We collect and how We use this information. This statement applies solely to the information collected on www.desiplaytv.com (“Website”).

This Privacy Policy describes the usage of information provided or collected on the sites and applications where this Privacy Policy is posted. We follow this Privacy Policy in accordance with applicable law in the regions where We operate. In some cases, We may provide additional data privacy policies specific to certain services or regions. Those terms are to be read in combination with this policy.

Please keep in mind that when You provide information to Us on a third-party site or platform (for example, via Website through social media login) the information We collect is through those third-party sites linked with Our Website and is covered by this Privacy Policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices You have made on the third-party site or platform will not apply to Our use of the information We have collected directly through Our Website. Please also keep in observance that Our Website may contain links to other sites not owned or controlled by Us and We are not responsible for the privacy practices of those sites. We encourage You to be aware when You leave Our Website and to read the privacy policies of other sites that may collect Your Personal Information.

All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Use.

This Privacy Policy should be read in conjunction and together with the Terms of Use applicable to the service (website, application or other service) You are using.

USER CONSENT

By using Viacom18’s service (for example, when You visit the Website, enter a contest or promotion, communicate with Us amongst others, on Our sites), You agree to Our collection, use and sharing of Your Personal Information as described in this Privacy Policy. In some cases, particularly if You reside in a country governed by a data protection regulation, We may ask You to provide explicit consent to access Our services before proceeding for further operations.

In case of any roaming user profile or if You are a traveller visiting various countries around the world and avail Viacom18’s services, then We will consider the country of Registration (where You provide Us with Your details for the first time) as Your primary country and the consents obtained at the time of Registration will be valid for Your processing of personal information. The Privacy Policy shall be applicable as per the law of that country at the time of Registration will apply to You.

ACCESSING WEBSITE THROUGH VPN/ PROXY

You should not access or use the Website by means of any mechanism or technology which conceals Your actual geo-location or provides incorrect details of Your location (for example, use a virtual private network (VPN/Proxy) to access the Website).

We will not be responsible or liable for any collection, storage or processing of Your Personal Information or data if You use any mechanism or technology to access or use Website which conceals Your actual geo-location.

COLLECTION OF PERSONAL INFORMATION AND ITS USE

‘Personal Information’ is defined as any information that identifies (whether directly or indirectly), relates to, describes, or is reasonably capable of being associated with a particular individual or natural person, such as the individual’s name, postal address, email address, and mobile number.

When anonymous information is directly or indirectly associated with Personal Information, the resulting information can also be treated as Personal Information.

We may use the Personal information collected to provide, analyse, administer, enhance and personalize Our service and marketing efforts, to process Your Registration, and to communicate with You related to the cases mentioned below.

For example, We may use Your Personal information to:

• verify Your identity; to help provide Our services and to administer those services.
• communicate with You concerning Our services (for example by email, push notifications, text messaging, and online messaging channels), so that We communicate news regarding the Website to You.
• determine Your requirements and provide personalized suggestions, tips and promotional content for various topics all of which We think will be of interest to You;
• prevent, detect and investigate potentially prohibited or illegal activities, including fraud;
• analyze and understand Our audience, improve Our service (including Our user interface experiences);
• notify You about changes in terms of service.

We provide personalisation by using data You submit to Us in terms of cookies, and other technologies in relation to the devices You use.

You can also raise a request to alter Your consent choices at connectwithus@viacom18.com.

INFORMATION YOU PROVIDE TO US

We may ask for and collect the following Personal Information about You when You use the Website and without this information We may not be able to provide You with all the requested services;

To use certain features on the Website and for the services (such as event registrations and Website campaigns, surveys, quizzes, polls), You may provide basic contact Information through forms available on the Website (“Registration”), including but not limited to:

o First Name
o Last Name
o Gender
o Age
o Email Address
o Phone number
o Country of residence
o City

INFORMATION YOU PROVIDE TO US VOLUNTARILY
If You send Us personal correspondence, such as emails or letters; We may collect and store such information.

We may collect additional information at other times, when You provide feedback(s), modify Your email preferences, respond to surveys, or communicate with Us. This information may include Your name, e-mail id, mobile number, city, etc.

INFORMATION WE COLLECT AUTOMATICALLY
We collect information about You and Your use of Our service, Your interactions with Us and Our service partners, as well as information regarding Your computer or other devices used to access Our service and Website (such as mobile devices, tablets and other viewing devices). This information may include, but is not limited to:

o Activities on the Website such as type of pages viewed, time spent on pages, search queries etc.
o Information collected via the use of cookies and other technologies* ;

*Note: To improve the responsiveness of the Website for Our users, We may use “cookies“, or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (“User ID“) to understand the user’s individual interests using the identified computer.
Unless You voluntarily identify yourself (through Registration, for example), We would not know who You are, even if We assign a cookie to Your computer. The only personal information which a cookie can hold is the information You supply. A cookie cannot read data from Your hard drive. Our advertisers may also assign their own cookies to Your browser(s) (if You click on their ads), a process that We do not control. For more details You can refer to Our Cookie Policy.

INFERRED INFORMATION THROUGH USAGE AND LOG DATA

We may track certain information about You based upon Your behaviour on the Website. We use this information for conducting internal research on Our users’ devices, interests, usage statistics, and behaviour to better understand, protect and serve Our users. This information is compiled and analysed on an aggregated basis.

We may also collect Your information to track user behaviour and preferences for internal analytics and research. We may also use Your information:

• To evaluate Your interests for the articles published on the Website
• To perform analytics and conduct customer research, to determine Your interest, for identifying and analysing traffic patterns.

LAWFULNESS OF PROCESSING PERSONAL INFORMATION

The Website will only collect and process Personal Information about You where We have lawful basis. Lawful basis on which We would process Your Personal Information includes obtaining explicit consent from You for processing Your Personal Information or processing for “legitimate interests” where processing is necessary by Us to provide You with Our services.

In case You choose to decline to submit the Personal Information We may not be able to provide certain services to You. In any case, We will not be liable and or responsible for the denial of certain services to You for lack of You providing the necessary Personal Information. When You register on the Website, We contact You from time to time about updating Your Personal Information to provide the users such features that We believe may benefit / interest You.

DISCLOSURE TO THIRD PARTIES

a. General Disclosure

At times the Website may make certain Personal Information available to strategic partners that work with the Website to provide service, or that help the Website market to users and potential users. The Personal information will only be shared by the Website to provide or improve Our service and marketing aspects; under no circumstances do We sell Personal Information nor do We share Personal Information with third parties for their marketing purposes.

We may disclose Your Personal Information to:

• Affiliates/subsidiaries or Our group companies;
• Our Analytics partners
• Our professional advisers, including Our accountants, auditors and lawyers;
• Other telecommunication and information Services providers;
• by disclosing individual records as may be required by law; or
• Government and regulatory authorities and other organisations, as required or authorised by law.
• In the event Viacom18 is merged with or acquired by another company or in case of re-organization or re-structuring of business, We and Our affiliates may share Your personal information, wholly or in part, with another business entity.

We will take necessary measures to ensure that these entities only use such information to perform the above functions, and that they have adequate procedures in place to deal with Your data securely.

b. Service Providers

We may disclose Your information if We use third party processors to administer and process Your Personal Information for the purposes notified in the Privacy Policy, e.g. for hosting activities related to the use of Our Website or services. The Website may include links to various third-party websites that may collect Your Personal Information. Use of Your information collected by such third-party platform will be governed by the privacy policy in such third-party platform. Such websites or applications are governed by their respective privacy policies, which are beyond Our control. Once You leave Our servers (You can tell where You are by checking the URL in the location bar on Your browser), use of any information You provide is governed by the privacy policy of the operator of the application/site that You are visiting. That policy may differ from ours. If You can’t find the privacy policy of any of these application/sites via a link from its homepage, You should contact the application/site owners directly for more information.

We may share anonymous or deidentified or aggregate consumer information publicly and with Our service partners. For example, We share information publicly to show trends about the general use of Our services. We also allow specific partners to collect information from Your browser or device for marketing/promotions and measurement purposes using their own cookies or similar technologies.

c. Legal

The Website may disclose Personal Information, if required to do so by law or in the good-faith belief that such action is necessary to:

• find that Your actions on Our Websites violate the Terms of Use or any of Our usage guidelines for specific products or services;
• conform to the edicts of the law or comply with legal process served on the Website or its owners;
• protect and defend the rights or property of the Website-owners, the Website or the users of the Website;
• Act under exigent circumstances to protect the personal safety of users of the Website, its owners, or the public.
• We may need to share details with third parties (such as auditors or legal advisors) to obtain advice. Any such processing will be governed by an agreement in the form required by law, preserving any statutory data protection rights.

YOUR CONTROLS AND CHOICES

Managing Your Information

When You use the services from Viacom18 (Websites or any of its sub sites), We make good efforts to provide You, as and when requested by You, with access to Your Personal Information and shall further ensure that any Personal Information or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such Personal Information or information to be retained by law or for legitimate business purposes.

We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where We provide information access and correction, We perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way We maintain certain services, after You delete Your information, residual copies may take a period of time before they are deleted from Our active servers and may remain in Our backup systems.

To exercise rights applicable to You as a data subject, you may email Us at connectwithus@viacom18.com and raise a request for the specified right. Kindly ensure You use appropriate subjects to mention the right (e.g. Data Access Request, Data Portability Request, Data Correction Request, Data Deletion Request) while raising all such requests, this would help Us process Your requests in a faster and more efficient manner.

We may take 30 days from the date of receipt of request to complete Your requests. However, if the nature of the requests are excessive in nature or would require significant effort then We may ask for an extension of 60 days by giving a prior notice to You with the reason for the extension.

We provide You the ability to exercise certain controls and choices regarding Our collection, use and sharing of Your Personal Information. In accordance with applicable law, Your controls and choices may include:

a. Data Access and Data Portability
You are entitled, as the data subject, to request copies of Your Personal Information held by Us. 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)

b. Rectification of Inaccurate or Incomplete Information
You can ask Us to correct inaccurate or incomplete Personal Information concerning You (this is the information which You cannot update yourself within Your Viacom18 account) by sending Us an e-mail to connectwithus@viacom18.com .

You can access and update some of Your Personal Information through Your account settings. You are responsible for keeping Your Personal Information up-to-date. The Website may send You periodic reminders via e-mail to maintain the accuracy of Your Personal Information.

c. Data Retention and Erasure
We retain Your Personal Information as long as necessary for the legitimate interests specified in this Privacy Policy and for Us to comply with Our legal obligations. If You no longer want Us to use Your information, then You can request that We erase Your Personal Information and close Your Registration and We shall delete the Personal Information available to Us from Our records and direct any service providers with whom the same was shared to delete the same.

Please note that if You request for the erasure of Your Personal Information:

• We may retain some of Your Personal Information as necessary for Our legitimate business interests, such as fraud detection and prevention, and enhancing safety.
• We may retain and use Your Personal Information to the extent necessary to comply with Our legal obligations and reasons of public interests in the area of public health. For example, We may keep some of Your information for tax, legal reporting and auditing obligations.
• Information You have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Website, even after Your account is closed/cancelled. However, attribution of such information to You will be removed. Additionally, some copies of Your information (e.g., log records) may remain in Our database, but are disassociated from personal identifiers.
• Because We maintain copies of Personal Information to protect from accidental or malicious loss and destruction, residual copies of Your Personal Information may not be removed from Our backup systems for a limited period of time.
• For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

d. Withdrawing Consent and Restriction of Processing
For withdrawing Your consent at any time during the tenure of Our services to You, You may choose to do so by sending Us an e-mail connectwithus@viacom18.com. We shall review Your request and may ask You to verify Your identity. Post verification, We will withdraw the consent for which request was made by You and stop any further processing of Your Personal Information.

e. Objection to Processing
Where Your Personal Information is processed for direct marketing purposes, You may, at any time ask Us to cease processing Your data for these direct marketing purposes by sending an e-mail to Us at connectwithus@viacom18.com.

Children’s Privacy
The Website is not intentionally designed for or directed at persons less than 18 (eighteen) years of age. Viacom18 does not knowingly permit any person who is under 18 (eighteen) years of age to register with the services or to provide any other personally identifying information. If Viacom18 becomes aware that any Personal Information of persons less than 18 (eighteen) years of age has been collected on the Website without verified parental consent, then Viacom18 will take the appropriate steps to delete any such information and notify the parent.

However, We consider it the responsibility of parents to monitor their children’s use of Our services. Nevertheless, it is Our policy is not to collect and process any Personal Information from children below 18 (eighteen) years of age or offer to send any promotional materials to persons in that category. Viacom18 does not seek or intend to seek or receive any Personal Information from children. Should a parent or guardian have reasons to believe that a minor has provided Viacom18 with Personal Information without their prior consent, please contact Our customer support team (connectwithus@viacom18.com) to ensure that the Personal information is removed from the Website.

Data transfer, storage & processing globally
We operate globally and may transfer Your Personal Information to individual companies of Viacom18 affiliated companies or third parties in locations around the world for the purposes described in this Privacy Policy. Wherever Your Personal Information is transferred, stored or processed by Us, We will take reasonable steps to safeguard the privacy of Your Personal Information. Additionally, when using or disclosing Personal Information, We adopt required means under applicable laws for ensuring adequate safeguards. You agree that You will not use, sell, transfer, or transmit the materials of the Website to any person or upload such materials of the Website on any other website, webpage or software, which may violate/cause damages or injuries to any rights of Viacom18 or its affiliates or any third party including privacy rights, publicity rights, and intellectual property rights.

Security and compliance with laws
We are continuously implementing and updating administrative, technical, and physical security measures to help protect Your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards We may use to protect Your information are firewalls and data encryption, and information access controls. If You know or have reason to believe that Your account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of Your account, please contact Us by contacting Our customer support team at: connectwithus@viacom18.com.

Change in Policy
This Privacy Policy is subject to change from time to time. We reserve the right, at Our sole discretion, to modify the terms of this Privacy Policy from time to time in order to ensure compliance with applicable laws (“Updated Terms”). The Updated Terms shall be effective immediately and shall supersede the terms of this Privacy Policy. We will notify You of any changes to this Privacy Policy if the changes made to the Privacy Policy significantly affect Your rights or as may be required by law. You shall be solely responsible for reviewing the Privacy Policy from time to time for any modifications. By continuing to use the Website after the updated Terms have been published, You affirm Your agreement to the Updated Terms.

CONTACT INFORMATION

a. Support
If You require any information or clarification regarding the use of Your Personal Information or this Privacy Policy or grievances with respect to use of Your personal information, please email Us at connectwithus@viacom18.com.

b. Data Controller
The data controller for the Website is Viacom18 with the business address of:

Viacom18 Media Pvt Ltd.
Zion Bizworld, Subhash Road – ‘A’,
Next to Garware Institute, Vile Parle (East),
Mumbai, Maharashtra – 400057,
India.

The data protection officer (“DPO”) appointed by Viacom18 can be contacted at dpo@viacom18.com.

c. Complaints
You can write to Our the DPO in case of any grievance or compliant. You have the right to complaint about the data processing activities carried out by the Website before the competent data protection authorities.

If You have any queries, complaints regarding the collecting, processing, transfer of personal data/information or regarding this policy please do contact Our DPO at dpo@viacom18.com.

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