Privacy Policy

Effective date: 14 January 2021

This privacy policy (“Policy”) explains our policy regarding the collection, use, disclosure and transfer of your information by MSFTS Private Limited or any of its affiliate(s) (“we” or “us” or “our”), which operates online workplace productivity tools and platform including the website https://trykardo.com ("Site" or “Website”), “Kardo App” (the “App”) available on Google Play Store, iOS and other similar platforms, other services via the site and application, any mobile or internet connected device or otherwise and other interactions (e.g. customer service enquiries, user conferences, etc.) (collectively the "Kardo App Service" or “Services”). This Policy forms part and parcel of the Terms of Use for the Kardo App. Capitalized terms which have been used here but are undefined shall have the same meaning as attributed to them in the Terms of Use. Users (as defined hereinafter) are requested to read this Policy in conjunction with the Terms of Use. Please note that “Kardo App Service” or “Services” would include any other future services we may provide or propose to provide.

In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organisation (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls its instance of the Services (its “Company”) and any associated Customer Data. If you have any questions about specific Company settings and privacy practices, please contact the Customer whose Company you use. If you have received an invitation to join a Company but have not yet created an account, you should request assistance from the Customer that sent the invitation.

As we update, improve and expand the Kardo App Service, this Policy may change, so please refer back to it periodically. By accessing the Site, App or otherwise using the Kardo App Services, you consent to the collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.

We respect the privacy of the users of the Kardo App Services (“Users” or “you”) and are committed to reasonably protect it in all respects. By using Kardo App Services, you agree to this Policy. If you do not agree with any term in this Policy, please do not use / avail of the Kardo App Services.

Information we collect and receive

Kardo may collect and receive Customer Data, information supplied by Users and other information and data (“Information”) in a variety of ways:

Customer Data. Customers or individuals granted access to a Company by a Customer (“Users”) routinely submit Customer Data to Kardo when using the Services.
User Data. While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to: a) their name, b) email address, c) phone number, d) business entity information, (e) account number of the Users, (f) KYC details and any other such information as required. In some cases / provision of certain service(s) or utility(ies), we may require your contact address as well. Further, upon downloading the App, Users are requested to share access to their contact list (as stored on their mobile device on which the App is downloaded), so as to enable the User to invite members to join their “Company”
Other Information. We also collect, generate and/or receives Other Information:
1. Company and account information. To create or update a Company account, you or your Customer (e.g. your employer) supply Kardo with an email address, phone number, password, domain and/or similar account details.
2. Usage information.
  - Services metadata: When an User interacts with the Services, metadata is generated that provides additional context about the way Users work. For example, We log the Companies, people, features, content and links you view or interact with, the types of files shared and what Third-Party Services are used (if any).
  - Log data: Our Servers automatically collect limited Information about your device's connection to the internet, including your IP address, when you visit our Site or use the App. We automatically receive and log Information from the App and/or your browser including but not limited to IP address, your device or computer's name, and your operating system, We may also collect log Information from your device, including but not limited to your location, IP address, your device's name, device's serial number or unique identification number (e.g. UDID on your iOS device, Android ID or ADID on your Android Device), your device operating system, browser type and version, CPU speed, and connection speed etc.
  - Device information: We collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
  - Location information: We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer or an IP address received from your browser or device to determine approximate location. Kardo may also collect location information from devices in accordance with the consent process provided by your device.
3. Cookie information. To improve the responsiveness of the Site and Services 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. By continuing to visit the App/Site, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this Policy. If you prefer not to receive cookies or web beacons, then you should stop using Services, or consult your browsing and third party cookie settings. We use cookies and other technologies for analysing and optimising our Website, App as well as for marketing purposes. Our partners may also assign their own cookies to your browser, a process that we do not control.
4. Contact information. In accordance with the consent process provided by your device, any contact information that an User chooses to import (such as an address book from a device) is collected when using the Services.
5. Third-party data. We may receive data about organisations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to postcodes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
6. Additional information provided to us. We also receive Other Information when submitted to our Website or App in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enrol in a certification programme or other educational programme hosted by us or a vendor, request support, interact with our social media accounts or otherwise communicate with us.
7. Demographic and Related Information. We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track the User behaviour on Site.

In case you choose to decline to submit Information on the Kardo App/Site, we may not be able to provide certain services on the App/Site to you. We will make reasonable efforts to notify you of the same at the appropriate time. In any case, we will not be liable and or responsible for the denial of certain services to you due to not receiving necessary Information from you.

How we use information

Customer Data will be used by us in accordance with the Customer’s instructions, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality, and as required by applicable law. Kardo is a Processor of Customer Data and the Customer is the Controller. The Customer may, for example, use the Services to grant and remove access to a Company, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

All Information is service dependent and we may use the Information to provide the Services, maintain, protect, and improve the Kardo App Services, and for developing new services. We use Information in furtherance of our legitimate interests in operating our Services, Website, App and business. More specifically, we use Information:

To provide, update, maintain and protect our Services, Websites, Apps and business. This includes use of Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at a User’s request.
As required by applicable law, legal process or regulation.
To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Information to respond.
To develop and provide search, learning and productivity tools and additional features. We try to make the Services as useful as possible for specific Companies and Users.
To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. We may also use your email address and phone number without further consent for marketing, non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, providing information about updates to Kardo App Services, billing, etc). If you have additional questions about a message you have received from us please get in touch through the contact mechanisms described below.
For billing, account management and other administrative matters. We may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data”. Any Information provided by you will not be considered as personal information if it is freely available and/or accessible in the public domain or is not deemed as a personal information under the applicable law. Further, any reviews, comments, messages, blogs posted/uploaded/conveyed/communicated by Users on the public sections of the Site or an application store (like the App Store or Play Store) becomes published content and is not considered as personal information which is subject to this Policy.

Data retention

We will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality, and as required by applicable law. Depending on the Services subscription, the Customer may be able to customise their retention settings and apply those customised settings at the Company level, or other level. The Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information. We may retain Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Information after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Information storage and backup

From time to time, we take backup of your data on Kardo App on our cloud database. This is done for the purpose of enabling Users to get their data back in case their phone's data becomes unusable, or phone gets lost, or the User moves to a new phone device. We also use this backup to provide useful insights and information related to your activity, work behaviour, etc., and to provide information related to User patterns and User data in the form of aggregated and anonymized statistics on data such as User spends by category, date, time, bank balances, etc.

We shall keep User’s Information in our records till the period of time where we can potentially offer the Kardo App Services to the Users. After such a period of time where Kardo App Services are no longer relevant to a User, we remove all the Information pertaining to a particular User from our records.

How we share and disclose information

This section describes how we may share and disclose Information. We do not control how Customers or Users or any other third parties choose to share or disclose Information. The Information (including Personal Data) collected may be shared with our affiliates, and group companies to the extent required for our internal business and/or administrative purposes and/or general corporate operations and to any third party service providers including marketing partners, and the User hereby consents to the same. We will take reasonable steps to ensure that these third-party service providers are obligated to protect your personal information and are also subject to appropriate confidentiality/non-disclosure obligations and they comply with the applicable provisions of the data protection laws. These entities, with whom we share the Information, may market to you as a result of such sharing unless you explicitly opt-out.

The User explicitly consents that we may have access to your SMS, contacts in your directory, location and device information and we may request you to provide your PAN and Know-Your-Customer (KYC) details to check your eligibility for certain products/services including but not limited to credit and payment products, etc., to enhance your experience and provide you access to the services being offered by us, our affiliates or other third party service providers (including lenders).

By using the Kardo App Services and providing information to us, Users agree and consent to the disclosure, transfer, storage, and processing of the personal information (including the sensitive personal information) by us in India and / or in other countries to its affiliates, group companies and third parties. While our primary motive is to protect the disclosure of personal information (except in accordance with the provisions of this Policy) of Users, Users may note that countries where their Information may be stored, may not have data protection laws similar to the countries where they are located.

The Customer’s instructions. We will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process.
Displaying the Services. When a User submits Information, it may be displayed to other Users in the same or connected Companies.
Collaborating with others. The Services may provide different ways for Users working in independent Companies to collaborate. Information, such as a User’s profile Information, may be shared, subject to the policies and practices of the other Company(Companies).
Customer access. Owners, administrators, Users and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. This may include, for example, your employer using Service features to export logs of Company activity, or accessing or modifying your profile details.
Third-Party service providers and partners. We may engage Third-Party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services or we may share business information to develop strategic partnerships with Third-Party Service providers to support our common customers.
Analytics. We may use third-party Service Providers to monitor and analyze the use of our Service including but not limited to Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Corporate affiliates. We may share Information with our corporate affiliates, parents and/or subsidiaries.
During a change to our business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or deidentified Data. We may disclose or use aggregated or deidentified Information for any purpose. For example, we may share aggregated or deidentified Information with prospects or partners for business or research purposes, such as telling a prospective Kardo customer the average amount of time spent within a typical Company.
To comply with laws. If we receive a request for information, we may disclose Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property or safety of Kardo or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With consent. We may share Information with third parties when we have consent to do so.

Security

We take security of data very seriously. We work hard to protect Information you provide from loss, misuse and unauthorised access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store and the current state of technology. Given the nature of communications and information processing technology, we cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

Age limitations

To the extent prohibited by applicable law, we do not allow use of our Services and Websites by anyone younger than 16 years old. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Accessing and updating personal information

When Users use the Site (or any of its sub sites) / App, we make good faith efforts to provide Users, as and when requested by Users, with access to their Information and shall further ensure that any personal information or sensitive personal data or other Information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal Information or sensitive personal data 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.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control. Your use of the Kardo App Services after such notice will be deemed acceptance of such changes. In any case, you are advised to review this Policy periodically on the Site to ensure that you are aware of the latest version.

Revocation of consent

A User can revoke his consent to the processing of his personal information at any time with effect for the future. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal information where such collection, use and disclose without consent is permitted or required under applicable laws.

Contacting Kardo

Please feel free to contact us if you have any questions about this Privacy Policy or Kardo’s practices or if you have any grievance relating to the processing of Information provided by you. We will respond within a reasonable timeframe. You can contact us at support@trykardo.com

Disclaimer

In case any personal information is shared by you with us, which is not requested by us during registration, (whether mandatorily or optionally), we will not be liable for any information security breach or disclosure in relation to such information. If you have any questions regarding this Policy or the protection of your personal information, please contact us at support@trykardo.com