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OUR PRIVACY POLICY
Effective date - 23rd November 2020
Introduction
This Privacy Policy describes our practices regarding use, maintenance, and disclosure of Personal Data that we collect through the Channels defined hereunder. You can be assured that any Personal Data that you disclose to us will be treated only in the manner described in this policy.
Whenever this Policy mentions "Cutshort" or "we" or "us" or "our", it refers to the AppyHappy Software Private Limited, which is responsible for your information under this Privacy Policy. Whenever the terms "you" and "your" are mentioned in the Policy, it refers to a User (which includes a "Candidate", "Recruiter", "Lead") accessing our Channels and/or Visitor of our Channels. If you are a corporate entity or an organisation, references to the terms "you" and "your" shall include your employees, representatives and agents. We conduct our business in compliance with applicable laws.
We urge you to read this Policy thoroughly. By accessing our website/mobile app and using our Channels, you will have represented your agreement to this policy and bound by its terms. Kindly note, this policy does not apply to third-party websites, products, or services even if they link to our Channels, and You should consider the privacy practices of those third-parties carefully.
By using the Site, you agree to the terms of this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not provide us with your personal information or interact with the Site/app.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of use
1. Scope of the Privacy Policy
  1. This Privacy Policy applies to information that we collect through the following (collectively referred to as 'Channels'). All of the below mentioned are collectively referred to as "Channels".
    1. Cutshort web platform, tools and services accessible via the same
    2. Websites – www.cutshort.io, www.cutshort.ai
    3. Cutshort mobile application
    4. Our services for configuration, setup and training
    5. Customer interface channels
    6. Social networking sites
    7. Electronic communications
  2. Our privacy and security practices in connection with the access and use of our Channels are governed by the TERMS OF USE, which are a binding contract between the User (respectively, collectively referred to as 'You') and us
  3. To administer and manage your relationship with us, we will necessarily need to collect, use, disclose and/ or process your Personal Data, to which you consent by agreeing to this Privacy Policy.
2. Information we collect
  1. The collection of your Personal Data shall be strictly restricted to what is necessary for the purpose of fulfilling the purposes identified herein below. We may collect and retain the following information (Personal Data) from and about you if you interact with us through the Site. When you register for an account to access or utilise one or more Channels offered by us. We collect data such as
    1. If you are a Recruiter your name, name of the organisation, name of the person posting the job vacancy on the Channels, address, phone number, email ID and password which you have entered in the Channels, social profile links or any other information provided by you during the use of our Channels which you may enter into our system voluntarily.
    2. If you are a Candidate and/or Lead, your name, address, phone number, your email id and password which you have entered in the Channels; your work experience information, your educational information, salary, resume and social profiles links; or any other information provided by you during the use of our Channels which you may enter into our system voluntarily.
    3. For your benefit, you may opt to import and sync your contacts, address books or networks from 3rd party services including but not limited to Google, Facebook, LinkedIn, Twitter, Dribbble, GitHub & StackExchange. In such cases, we may receive your contacts (including contact information, your service provider(s). If you sync your email or calendars with our Services, we will collect your 'email header' and calendar meeting information (e.g. times, places, attendees and contacts)
    4. your location, website browsing patterns (e.g., through cookies) and purchase history; user activity and use of the Service (e.g. among other things, page views, IP address, requested URLs, referring URLs, visit date and length, and file type requests)
    5. your payment details, billing and delivery addresses, a credit / debit card number and a credit / debit card expiration date and/ or other payment instrument details
    6. Other information you actively submit to us or we can determine about you based on your interactions with our Websites and Channels.
  2. We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a message from another user, we track whether you have acted on it and will send you reminders. We may also analyse these messages algorithmically to make better suggestions for you and other users
  3. We may also collect information that your browser sends whenever you visit our Website or use our Service which may include information such as browser type, browser version, your computer's Internet Protocol (IP) address, internet service provider, date/time stamp, URLs of referring/exit pages, operating system, the information you search for, local and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information, the time spent on those pages usage information, and other statistics
  4. We ask for and may collect personal data from various sources, which may include but are not limited to, information you voluntarily provide us at any events, seminars, conferences, talks, promotions, surveys organised by us, and/or information we collect when you submit web forms on our websites or if you use interactive features of the websites for e.g. our chatbot. We record any personal information or other content that you provide to us at the time of providing feedback or registering a complaint.
3. How you can choose how we should use your Personal Data
  1. We get access to above mentioned information when you
    1. Access the Channels
    2. Register, subscribe, or create an account with Cutshort
    3. Open or respond to our emails
    4. Contact customer service or use other customer support tools
    5. Visit any page online that displays our ads or content
    6. Connect or link to any Website via social networking sites
    7. Post comments to online communities
    8. Provide information to our vendors
  2. As a Cutshort user, you have the power to control how we use the Personal Data that we collect
    1. You can manage your email, SMS and notice preferences by adjusting the settings in your web browser
    2. You can also manage your subscriptions by following subscription management instructions contained in any commercial emails that we send you
  3. Please note that even if you decide not to subscribe to, or to unsubscribe, from promotional email messages, we may still need to contact you with important transactional information related to your account with Cutshort and your purchases/access of CUTSHORT Device
  4. You hereby consent to receive communications by SMS, email or calls from CUTSHORT with regard to the services provided by it
  5. You may manage how your web browser or mobile device handles cookies by adjusting its privacy and security settings. Please refer to Paragraph 10 of this Policy for information of Cookies for more information
  6. You may also manage the sharing of certain personal data with us when you connect with us through social networking platforms or applications. You may adjust our permissions and manage the interactivity between us and your social networking account or your mobile device
4. How we use your Personal Data
We may use the Personal Data you voluntarily provide to us or that we collect from you or through other sources for the fulfillment of our obligations under our contract with you and/or to comply with our statutory legal obligations. We process and use your Personal Data for the following purposes enumerated below. The list is not an exhaustive one. We use the information for many other purposes including the following
  1. To personalise your account with CutShort
  2. Facilitate and process orders – for example, for and other goods and services
  3. Determine your eligibility for certain types of offers, products or services that may be of interest to you, and analyse advertising effectiveness
  4. Answer your questions and respond to your requests
  5. Communicate and provide additional information that may be of interest to you about us, the sellers and our business partners
  6. Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of business partners
  7. Manage our everyday business needs, such as administration of Channels, analytics, fraud prevention, and enforcement of our corporate reporting obligations or to comply with the law
  8. Comply with our legal obligations, resolve disputes, and enforce our agreements
  9. Enhance other information we have about you to help us better understand you, determine your interests and provide you with more relevant and compelling services
  10. To maintain, operate and improve the site
  11. To authenticate your registration through OTP or otherwise
5. How we disclose your Personal Data
  1. We shall not sell, rent, share, disclose or transfer any of your Personal Data to any third party without your consent and without notifying you of the purpose for such transfer or sharing.
  2. We employ third parties to perform certain tasks to facilitate our Channels and to assist us in analyzing its usage. We may transfer certain Personal Data to these third parties, but this transfer will be subject to your explicit consent and the TERMS OF USE. You hereby give us your consent to disclose your Personal Data to such third parties. These third parties have access to your Personal Data albeit only to perform specific tasks on our behalf. These third parties are contractually and otherwise legally bound not to disclose or use your Personal Data for a purpose other than in connection with providing the service on our behalf and/or to us.
  3. We are not in the business of selling or renting Personal Data. We will not share your Personal Data with third parties, except in the following manner
    1. If you are a Candidate, then, with the Recruiters, so they can contact You
    2. If you are a recruiter, we may share your information with Candidates and /or Leads, who shall use such information to contact you and apply for the job posted by you.
    3. in case of a merger, acquisition or reorganization with a purchaser of our company or all or substantially all of our assets
    4. to comply with legal orders and government requests, or as needed to support auditing, compliance
    5. to combat fraud or criminal activity, and to protect our rights or those of our affiliates, business partners and users, or as part of legal proceedings affecting Cutshort
    6. in response to a legal process, including to law enforcement agencies, regulators, and courts
    7. With your consent or as otherwise required or permitted by law
  4. We may disclose non-personal information in the aggregate to third parties (e.g. Advertisers) relating to user activities, salaries, professional data and behaviour on the Channels
6. Security and Visibility of Personal Data
  1. We use strict security measures to ensure the security, integrity and privacy of Your Personal Data and to protect your Personal Data against unauthorized access or unauthorized alteration, disclosure or destruction
  2. We shall, however, not be responsible for any breach of security or for any actions of any third parties that receive your Personal Data
  3. Neither we nor our representatives will ask you for your password or other Personal Data, including financial information. Please treat requests for your password or other personal information as suspicious and promptly contact us
  4. When You use the Channels to find career opportunities, we show your information (called "talent card") to only the users registered as Recruiters and don't share it on social networks or search engines. We also offer you an option to hide your talent card from specific employers by specifying companies and will make reasonable efforts to do so, however, we provide no guarantees to such an effect
  5. When You use the Channels for any other purpose such as professional growth, content share and recruiting, your content such as job will be visible to all users, be shared on social networks and search engines
  6. We have put in place reasonable and necessary organisational and physical measures and are implementing and updating appropriate administrative, technical, organizational and physical security measures of commercially acceptable security standards to help protect your information against unauthorized access, loss, destruction, use, alteration or disclosure of any information we store. Some of the safeguards we use to protect your information are firewalls and information access controls
7. Data Transmission and Storage
  1. The information collected by us may be sent to servers located in the United States, Singapore and India. By interacting with and/or using the Channels you understand that your personal data will be transferred to such countries and you consent to such transfer.
  2. We do not transfer your Personal Data to third parties, unless it is necessary to fulfill our obligations to you and as permitted by law. We shall make appropriate arrangements to ensure that your data is processed in a secure manner and in compliance with applicable data protection laws, specific to your country.
  3. In addition, we may display advertisements on our service from third parties (e.g. partners, advertising companies, and ad networks). These third parties use tracking technologies, such as cookies, to measure the effectiveness of their advertisement. We do not provide any personal information to these third parties
8. User's Rights in relation to Personal Data
  1. By keeping your personal data updated you can help us to ensure that we can respect your preferences and offer you the goods and services that are most relevant to you
  2. You have a right to have your Personal Data maintained by us removed from our systems. You can also at any time unsubscribe from our services, newsletters, e-mailers. Provided that, notwithstanding such request, this data may be retained if required to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain your Personal Data and maintain a record of your transactions for financial reporting or other compliance purposes
9. Retention of your Personal Data
We will retain your Personal Data for as long as required to perform the purpose specified under this privacy policy. In case you opt to delete your account, we shall retain your Personal Data for upto six months after which, we shall delete all your Data along with any Personal Data. When we have no ongoing legitimate business, operational, legal or other statutory need to process your Personal Data, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
10. Public Posts
The Channels may contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products etc., and otherwise submit your own original content. Prior to posting in these areas, please read our TERMS OF USE carefully. All the information you post may be accessible to anyone with Internet access, and any information you include in your posting may be read, collected, and used by others
11. Messages and Notifications
  1. We use your email address to provide services in connection with the Service, such as updates, notifications, and reminders, and to contact you on behalf of other users of the Service who send you communication, among other things
  2. At times, we will notify you by email about updates, changes, and other service related information. We will never ask you for your password or other personal information in those notifications and communication, or in any other communication from us
12. Privacy Policies of Third Parties
This Privacy Policy only addresses the collection, processing and use (including disclosure) of information by us through your interaction with the Channels. Other websites that may be accessible through links from the Site may have their own privacy policies and personal information collection, processing, use, and disclosure practices. Our business partners may also have their own privacy policies. We encourage you to familiarize yourself with the privacy policies provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion
13. Cookies
  1. Cookies are unique identifiers, usually made up of small bits of text or code. Cookies are usually stored on your device or in your web browser and they send certain information back to the party who served the cookie. When we say cookies we are actually referring to a broader range of technologies than just cookies, including web beacons, clear gifs, pixels and other similar technologies. When we say first-party cookies we mean cookies that are served by Cutshort .com. When we say third party cookies we mean cookies that are served by non-Cutshort .com parties
  2. We use cookies to ensure that you have the best possible experience while using our Service. Cookies are used in order to better understand how applications and websites work and to optimize online and mobile experiences. Cookies do this by allowing the party serving the cookie to analyse a website’s or mobile app’s performance, to identify certain users anonymously and remember their preferences, to better understand whether a computer or device (and probably its user) has visited a website previously and to serve personalised advertisements
  3. Consent: By using our Website or Channels, using any services provided through the Site, or receiving our emails, you consent to the use of cookies in accordance with this clause as 'Cookies Policy'
  4. Intent: This Privacy Policy sets out how we, and third parties we authorize, use cookies when you interact with our Site or the services offered via the Site. Our Privacy Policy explains what we do (and don't do) with the information, including any personal data we may collect about you. Please read them both
  5. Cookies in E-mails: Our emails contain cookies that track whether you open our emails and whether you click any links within them. The cookies used in our emails to monitor these behaviours are unique to each email and are not stored on your computer or mobile device
  6. Cookies and Browser settings: You may be able to avoid certain cookies by configuring your browser settings or opting-out directly with the party that operates and controls the cookie. Please check your browser settings for more information. Kindly note that in case you opt to decline cookies and flush out the cookies from your computer, it will reduce the functionality of our Service
14. Account Deactivation, Reactivation and Deletion
  1. At any point, you may deactivate your account from your account settings page. Once deactivated, your personal data will stop being visible to others on our Services and you will be unsubscribed from all messages, emails, notifications from us. Some information such as messages/communications you have sent or content you have already shared with other CutShort users using any of our Services will remain visible to others
  2. We retain your Personal Data even after you have deactivate your account to prevent fraud and abuse and enforce our Terms of Use
  3. You may reactivate your account yourself in the future by successfully verifying your account by proving ownership of your registered email address or mobile number
  4. You may, at any point request us to delete your account, by contacting our support team, which shall take upto 15 business days. Once deleted, neither You nor other users shall be able to view Your Data including account information, communications etc. however, the same shall remain in our systems for upto 6 months (for legal and other compliances) after which, it shall be deleted. You shall not be allowed to reactivate your account once you exercise the option of deletion of the account. Upon deletion, some information such as messages/communications/resumes/documents you have sent or content you have shared on the Channels will remain visible to others
  5. Upon deactivation or deletion of your account, we attempt to take all necessary measures to ensure that Your Personal Data is not visible to other users, however, we disclaim all liability if such data has been previously downloaded by any user prior to such deactivation or deletion of the account
15. Personal Data of Children
  1. We do not knowingly collect Personal Data from children under 18. If you are a child under the age of 18, do not submit any Personal Data to us. If you are a parent or guardian, we encourage you to instruct your children not to disclose any Personal Data without your consent
  2. If you believe that we may have unknowingly collected Personal Data from minors without parental consent, kindly Contact us at the contact details provided herein below, so that we may adopt appropriate measures to address the issue promptly and remove the information.
16. Additional Terms and Conditions for Certain Regions
  1. California, United States
    If you are a resident of California, we shall handle your Personal Data in consonance with the California Consumer Privacy Act (CCPA). As a resident of California you have certain additional rights in relation to your Personal Data.
    1. Personal Data means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household but does not include publicly available information.
    2. We will not, without your consent, disclose your Personal Data. You hereby give us consent to disclose your Personal Data for business purposes.
    3. You consent to and agree to direct us to and/or use the Channels to intentionally disclose Personal Data or to intentionally interact with a third party.
    4. You consent and agree that we may disclose the following categories of such Personal Data of consumers (as defined under the CCPA) in the 12 months immediately preceding the last update of this Privacy Policy.
      1. Identifiers such as a consumer's name, postal address, email address etc.
      2. Demographic information such as a consumer's work experience, educational information, resume etc.
      3. Geolocation data such as the location of a consumer's device or computer etc.
      4. Internet or other electronic network information
      5. Professional or employment- related information
      6. Inferences drawn from any of the above information
    5. We will not, without your consent, sell and/or disclose your Personal Data for valuable consideration. If you have given us your Personal Data, we have not sold and/or disclosed it for valuable consideration in the 12 months immediately preceding the last update of this Privacy Policy.
    6. Your rights under the CCPA
      1. Right to access - You have a right to and are allowed access to your data that we collect and process.
      2. Right to deletion - You have a right to request deletion of your Personal Data. This right is a subjective right, we may not comply with a data deletion request if we are permitted and/or required under law.
      3. Right to disclosure - You have a right to request us to disclose the categories of Personal Data collected, sources from which Personal Data is collected, purpose of collecting Personal Data, categories of third parties with whom Personal Data is shared.
      4. You have a right not to be discriminated against for exercising certain rights under California law
    7. You may exercise your rights by contacting us at the contact details provided herein under.
  2. European Union (EU)
    This is applicable only to persons in the European Union.
    We ensure that all your data that we collect, store, use and process is done in compliance with the General Data Protection Regulation (GDPR). Elucidated hereunder are additional terms applicable to citizens of the European Union.
    1. The term Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
    2. We do not collect any sensitive Personal Data such as racial/ ethicalorigin, political opinions, religious or philosophical beliefs, trade union affiliation, genetic, biometric data, health data or data concerning sexual orientation from you.
    3. Legal basis for processing your Personal Data: If you are an EU citizen, we process Personal Data only for purposes for which we collect it. We shall process data only if we have your consent or if processing is necessary for complying with our legal obligations or where the processing is in our legitimate interest. If you need further clarification concerning the legal basis on which we collect and use your Personal Data, you may contact us at the Contact information provided hereunder.
    4. Residents of the European Union have certain additional rights in relation to their Personal Data under the General Data Protection Regulation (GDPR)
      1. Right to access - You have a right to and are allowed access to your Personal Data that is processed.
      2. Right to erasure - You may request erasure of your Personal Data only under certain circumstances which include but are not limited to unlawful processing of your data, if your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, if you withdraw your consent etc. Please note, however, that we may need to retain certain information to comply with our legal obligations.
      3. Right to rectification - You may at any time request for rectification of your Personal Data that we process. You may also complete Personal Data if it is incomplete.
      4. Right to restriction of processing - You have a right to restrict the processing of Personal Data if you contest the accuracy of the data, lawfulness of processing and or if you have objected to processing of data or if the data is no longer needed for the purpose of processing. We will inform you when such restriction is lifted.
      5. Right to data portability - You have a right to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable format. You are also entitled to the right to transmit your Personal Data to another controller to another where it is technically feasible.
      6. Right to object - You have a right to object the processing of your Personal Data. You have a right to object where your Personal Data is processed for marketing purposes.
      You may exercise any of the rights listed above by contacting us at the contact details provided herein under
    5. Personal Data of Children - We do not knowingly collect and/or process Personal Data from children i.e. persons under the age of 16 years. If you are a child below the age of 16 years, do not submit any Personal Data to us. We may collect and process the Personal Data of a child on obtaining consent for the same from the child’s parents or guardians, who have the legal competence and parental responsibility to give such consent on behalf of the child.
    6. Transfer of Personal Data: Kindly note that you are signifying agreement to the transfer of your Personal Data to outside the EU. Such transfer to which you hereby expressly consent is primarily for processing and we ensure an adequate level of protection through a series of agreements with our service providers.
  3. Indonesia
    These additional rights are applicable to citizens of Indonesia.
    Personal Data means and covers every individual data which is identifiable or can be identified, alone or combined with any other information directly or indirectly, through an electronic system or non-electronic system. In Indonesia Personal Data will be collected, stored, used and/or processed in compliance with our obligations under Regulation No. 11 of 2008 (Electronic Information and Transactions) amended by Regulation No. 19 of 2016 and Regulation No. 71 of 2019 (Electronic System and Transaction Operation)
    1. Except as otherwise required by law, we shall acquire, use and utilise your Personal Data only upon your explicit consent.
    2. We shall ensure and maintain the confidentiality, integrity, authenticity, accessibility, availability and traceability of your data.
    3. We shall train our employees incharge or enshrined with the task of processing your data and shall have a management policy, operations work procedures and periodical audit mechanisms for our Channels.
    4. Right to be informed in case of breach: We shall notify you in writing of any instances of breach of your Personal Data
    5. Right to be forgotten: You may make an application, requesting us to delete any irrelevant electronic information or documents under our control.
    6. Right to delisting: you may request us to delist irrelevant electronic information and electronic documents from an internet search engine through a court order.
    To access your rights, or in case of any concerns and/or complaints kindly contact our concerned authority at the contact details provided herein under.
  4. Laos
    These additional terms are applicable to domestic and international individuals, legal entities or organizations that are located or activated within the territory of the Lao People’s Democratic Republic. We shall ensure that the collection, access, use and disclosure of your data is safe and correct and in consonance with the Law on Electronic Data Protection (2017), Lao People’s Democratic Republic.
    1. The term Personal Data means electronic data of individuals, legal entities or organisations. We shall not access, use or disclose your Personal Data without your permission and consent.
    2. We shall collect data from you only for the purposes expressly enumerated in this policy and the collection of which you have expressly approved
    3. You are under an obligation to provide accurate and complete details and must inform of changes to your Personal Data in order to update and edit the data correctly and completely.
    4. Except as otherwise permitted under law, we shall use and disclose your Personal Data that we collect, maintain or administer only upon your approval
    5. Right to Access: You have a right to access the Personal Data that you provide to us.
    6. Right to update or edit: You may request us to update or edit your Personal Data, we shall use our best efforts to resolve your request promptly. We shall inform you promptly if we cannot activate your request due to technical or other issues.
    7. Right to delete: We shall delete all your Personal Data that you provide to us upon your request for deletion. We have a legal right to delete your Personal Data if it is contrary to the law.
    8. Right to disclosure: We shall not disclose your Personal Data to a third person until we obtain your approval for the same.
    9. Transfer of Personal Data : We shall not transfer your Personal Data outside Lao People’s Democratic Republic without your permission. You also have a right to subsequently deny transfer of your Personal Data and we shall stop sending or transferring data upon such request to third person.
    10. We shall not retain your Personal Data for longer than the purpose for which it is required or we shall delete your Personal Data upon expiry of purpose for which it was collected.
    11. If you have reasons to believe that your Personal Data has been damaged or is at risk, you may inform us at the Contact Information provided herein under.
    To access your rights or in case of any queries relating to our privacy policies or practices kindly contact us at the Contact Information provided herein under.
  5. Philippines
    If you are a citizen of the Philippines, or a resident of the Philippines, these additional terms shall be applicable to you.
    We shall process your Personal Data in accordance with the Data Privacy Act of 2012. Personal Data refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual, Personal Data also includes sensitive Personal Data.
    1. We shall process your Personal Data lawfully only after receiving your consent for such processing and in consonance with this Privacy Policy.
    2. All information shall be up-to-date and any inaccurate or incomplete data shall be rectified, supplemented, destroyed or the processing of such inaccurate or incomplete information shall be restricted.
    3. Your Personal Data which includes Sensitive Personal Data shall be retained only for the fulfillment of the purposes mentioned in this Policy or if otherwise required by law.
    4. Right to access: You have a right to access your Personal Data that you provide us with.
    5. Right of Transmissibility: Your Lawful heirs and assigns may invoke your rights under the Act upon your death or if you are incapacited or incapable of exercising your rights.
    6. Right of Data Portability: You have the right, where Personal Data is processed by electronic means and in a structured and commonly used format, to obtain from us a copy of data undergoing processing in an electronic or structured format, which is commonly used and allows for further use by you.
    Incase of questions regarding this Privacy Policy or to inorder to enforce your rights contact us at the Contact details provided herein under.
  6. Thailand
    This is applicable to citizens of Thailand
    We ensure that all your data that we collect, store, use and process is done in compliance with the Personal Data Protection Act, 2019. Elucidated hereunder are additional terms applicable to citizens of Thailand.
    1. The term Personal Data means any information relating to a Person, which enables the identification of such Person, whether directly or indirectly, but not including the information of the deceased Persons in particular.
    2. Legal basis for processing your Personal Data: If you are a citizen of Thailand, we collect, use, process or disclose Personal Data only for the purposes described in this Policy. We shall process your data only if we have your explicit written consent or consent via an electronic system or if processing is necessary for complying with our legal obligations or where the processing is in our legitimate interest. If you need further clarification concerning the legal basis on which we collect and use your Personal Data, you may contact us at the Contact information provided hereunder.
    3. Residents of the Kingdom of Thailand have certain additional rights in relation to their Personal Data under the PDPA, 2019.
      1. Right to withdraw consent: Except unless restricted by law, you may withdraw your consent at any time, however withdrawal of consent shall not affect the collection, use or disclosure of Personal Data, that you have already legally consented to. You may withdraw your consent by contacting us at the Contact information provided herein under. We shall at the time of withdrawal of your consent inform you of the consequences of such withdrawal.
      2. Right to access: Except if otherwise prohibited under law, you have a right to and are allowed access to and obtain copies of your Personal Data that is processed.
      3. Right to erasure or destruction: You may request erasure or destruction or anonymization of your Personal Data only under certain circumstances which include but are not limited to unlawful processing of your data, if your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, if you withdraw your consent etc. Please note, however, that we may need to retain certain information to comply with our legal obligations.
      4. Right to restriction of processing: You have a right to restrict the processing of Personal Data if the data is the Personal Data for which a request is made for its erasure or destruction, or if the data is no longer needed for the purpose of processing etc.
      5. Right to data portability: You may request to obtain or send and transfer Personal Data to other Data Controllers in the format which is readable or commonly used by ways of automatic tools or equipment, unless it is impossible to do so due to technical reasons.
      6. Right to object: You have unless prohibited by law, a right to object to the collection, use or disclosure of your Personal Data.
      You may exercise any of the rights listed above by contacting us at the Contact details provided hereunder. We shall make best efforts to respond to and resolve all your requests within a period of 30 days from the receipt of the request.
    4. Personal Data of minors: We do not consciously collect Personal Data from minors (i.e individuals under 20 years of age). We may collect, use and disclose Personal Data of minors on obtaining consent for the same from a person holding parental responsibility over the minor. If you believe that we may have unknowingly collected Personal Data from minors without parental consent, kindly Contact us at the contact details provided herein below.
    5. Transfer of Personal Data: Kindly note that you are signifying agreement to the transfer of your Personal Data outside the Kingdom of Thailand. Such transfer to which you hereby expressly consent is primarily for processing and we ensure an adequate level of protection through a series of agreements with our Service providers and in compliance with the Law.
  7. Vietnam
    We shall collect, edit, use, store, supply, share and disperse your Personal Data only in accordance with Law on Network Information Security (2015) and other relevant laws and regulations.
    1. Personal Data means information associated with the identity of a specific person. We shall collect and process your Personal Data only upon your prior consent for such collection and processing.
    2. We shall not share, disperse the collected, accessed or controlled Personal Data to any third party unless you consent to the same or if otherwise required under the law. We shall maintain the integrity of your Personal Data.
    3. Right to obtain and access Personal Data: You have a right to request access and obtain Personal Data that is collected and stored by us.
    4. Right to correction: You may request to check the accuracy of your Personal Data and may request correction of your Personal Data.
    5. Right to delete: You have a right to update, change and delete your Personal Data we collect.
    6. Right to restrict transfer: You may request us to stop disclosing or transferring your Personal Data to a Third Party.
  8. Singapore
    We collect, use and process your data in accordance with the Personal Data Protection Act (PDPA), 2012. Details of our obligations, and your rights and other essential provisions are set out herein below.
    1. Accuracy of your Personal Data - We will make all reasonable efforts to ensure that the Personal Data collected by us is accurate, complete and up-to-date. We shall adopt methods to verify and authenticate information provided by you. We shall make sure that any and/or all changes made or requested are updated in our records. We rely on the information you provide to us for performing our obligations/ Channels to you, you are required to provide us with accurate and complete information and to promptly update us in the event there are any changes to your Personal Data.
    2. Your Rights as a User or Visitor
      1. You shall, to the extent that the applicable law allows, have the right to request access to your Personal Data held by us.
      2. You have a right to request correction/ rectification of your Personal Data entrusted to us or update your Personal Data held by us.
      3. You have a right to request us at any time to limit the processing and use of your Personal Data.
      4. You may by giving notice, withdraw any consent given to us for the collection, use or disclosure of your Personal Data. We shall upon receipt of such notice inform you of the repercussions of withdrawing your consent. We may not allow withdrawal of consent in circumstances where it is required or authorised under this Act or any other written law. It is essential to note that your withdrawal of consent could result in legal consequences arising from such withdrawal.
    If you wish to exercise any of the above stated rights, you are required to contact us at the contact details provided hereunder. Transfer of Personal Data outside Singapore: In fulfilling our obligations to you it may become necessary to transfer data that we collect from you to jurisdictions outside Singapore for processing and storing. By providing information to us, you are consenting to the transfer, storing and processing of that information outside Singapore in accordance with the terms of this privacy policy.
17. Timeframe for processing User Requests
On receipt of a request for the exercise of any of the rights stated under this Privacy Policy, we shall make best efforts to respond to and resolve the same without undue delay within a period of 30 days of its receipt. If the requests received are complex or numerous we may, by giving you notice, extend this said period of 30 days. We reserve the right to charge you an administrative fee to process your request, we shall notify you of such fee before proceeding with your request.
18. Contact Us
If you have questions regarding this Privacy Policy or about our privacy practices, please contact us by email at hello@cutshort.io or at the contact details provided below. We will make all efforts to ensure that any requests, concerns, questions and grievances you may have are resolved quickly and promptly.
19. Modifications in Privacy Policy
We will routinely update this Privacy Policy to improve our practices and to reflect new or different privacy practices, such as when we add new services, functionality or features. You can determine when this version of the Privacy Policy was adopted by referring to the "Effective Date" above.
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