Effective Date:01 June 2020

Last Updated on:01 June 2020

This privacy notice (“Notice” / “Privacy Notice”) explains how VR Enterprise, a company incorporated in India and having its registered office at 201 Montana Apts, Plot 104, Telang Cross Road 2, Matunga E, Mumbai  400019 (“We” or “Us” or “Our” or “ToggleArt”) processes Personal Data which We collect from you in Our capacity as a controller, where We determine the purposes and means of processing of your Personal Data.

We process information relating to an identified or identifiable natural person (“Personal Data”)in accordance with this Privacy Notice and in compliance with the relevant data protection regulation and laws. This Notice provides the necessary information regarding right and obligations for concerned parties, and explains how, why and when we process Personal Data.

LEGAL BASIS FOR PROCESSING OF PERSONAL DATA

SHARING OF PERSONAL DATA

• You acknowledge that We will share your Personal Data with Our group companies and third-party service providers so that they may offer you Our Service(s) and/or to send information or updates to the Service(s) if you have subscribed to Our Service(s) by agreeing to the Terms (“Subscriber”). We conduct a due diligence on such third-party service providers prior to sharing your Personal Data with them. When We process your order where you are a Subscriber, We may send your Personal Data to and also use the resulting information from credit reference agencies to prevent fraudulent purchases.
• We share Personal Data with Our third-party service providers that host, maintain or provide Our websites, applications, backup, storage, analytics and other services. These third-party service providers may have access to or process your Personal Data for the purpose of providing these services for us.
• We share your Personal Data with such third-party service providers only on a contract basis where such service providers assure that they are and shall be in compliance with the applicable data protection laws.
• We may be required to disclose your Personal Data in response to: a) lawful requests by public authorities, including to meet national security or law enforcement requirements and/or b) subpoenas, court orders, or legal process, or to establish or exercise Our legal rights or defend against legal claims.
• We may also share Personal Data to assist investigation and prevention of illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Our Terms, or as otherwise required by law.

COLLECTION AND USE OF PERSONAL DATA

We collect and process the following Personal Data about you.

1. Information you provide Us:

• Subscription Information:When you subscribe to any of Our Service(s) by agreeing to the Terms of Services, We may collect your (i) contact information such as name, e-mail address, mailing address, IP address, geographic location, or phone number of the account admin; (ii) name and e-mail address when account admin/user(s) provide feedback from within the Service(s); and (iii) unique identifiers, such as username, account number or password. Subject to this Notice, we will use such data to (i) provide you the Service(s); (ii) send you communication from the Service(s); (iii) assess needs of your business to determine or suggest suitable Service(s); (iv) send you requested information about the Service(s); (v) respond to customer service requests, questions and concerns; (vi) administer your account; (vii) send you promotional and marketing communications (where you have requested us to do so); and (viii) facilitate your transactions with other users when you use Our Service(s).
• Job Application(s):When you apply for an open position by populating the application form on our website(s), We may collect your (i) contact information, such as name, email address, mailing address, phone number, links to your social networking profiles; and (ii) any other information contained in the resume that you submit to us. Subject to this Notice, We will use such data to evaluate you for the open position that you have applied for or any position that we consider you suitable for at the time you submit your resume or at any later date. Unless you notify us otherwise by an e-mail to privacy@toggleart.com,We will retain such data for a period of 6 (six) months for archival purposes. If you wish to update the data you provided to us, you may do so by contacting us at privacy@toggleart.com.
• Websites:When you register for any of Our events or programs, including seminars or webinars through a registration form on Our website, visit Our publicly accessible community forums and blogs or submit any forms on Our website(s), We may collect information such as name, e-mail address, company name and website URL, company details, location and contact information. Subject to this Notice, We will use such data to (i) facilitate your use of the program or event for which you have registered; (ii) send you requested information about Our Service(s); (iii) respond to your requests, questions and concerns; (iv) assess needs of your business to determine or suggest suitable Service(s); (vi) send you requested information about the Service(s); and (vii) send you promotional and marketing communications (where you have requested us to do so).
• Cookies and similar technologies:We and Our third party advertising partners use cookies, gifs, log files, web beacons and similar technologies that collect Personal Data and help Us to analyze trends, administering the website, tracking users’ movements around the site, and gathering demographic information about Our user base as a whole. Please see Our Cookies Policy for further information about Our use of Cookies and similar technologies.

2. Information that We collect from other sources:

We may also receive your Personal Data from other sources which include sources such as Our business partners, social media services, marketing service providers, email add-ons in the following manner: (a) from third party sources like databases and social media but only where We have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to Us; (b) We may also obtain Personal Data if you authorize Us to connect with a third-party service including single sign- on services such as Google and Facebook Connect. We will access and store your name, email address(es), current city, profile picture URL, and other Personal Data that the third- party service makes available to Us and use and disclose it in accordance with this Notice; (c) other information such as location information, device information, browser information, information regarding the date and time of your access to Our Service(s), navigational information such as the websites you visit and/ or access.

TRANSFER OF PERSONAL DATA

We process Personal Data in India.

YOUR RIGHTS

• Right to rectification:If you believe that We hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and We will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
• Right to erasure:You also have the right to request erasure of your Personal Data or to restrict processing in accordance with the data protection laws; as well as to object to any direct marketing from us.
• Right to data portability:Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making We may use.
• Right to object:You have the right to object / restrict the processing of your Personal Data in certain circumstances, including where such Personal Data is no longer required in light of the purpose of processing, or in connection with direct marketing, and/ or by utilizing the opt-out mechanisms that We provide to you.

If We receive a request from you to exercise any of the above rights, We may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. Requests to access, change, or remove your information will be handled within thirty (30) days.

SECURITY

We use appropriate technical and organizational measures to protect the Personal Data that we collect and process. The measures ToggleArt uses are designed to provide a level of security appropriate to the risk of processing Your Personal Data as specified in Our security policy. If you have questions about the security of your Personal Data, please contact us immediately as described in this Policy.

MINORS AND CHILDREN’S PRIVACY

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 16, and We do not knowingly collect Personal Data from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Service at any time or in any manner without Parental Approvals. If We learn that Personal Data has been collected on the Service from persons under 16 years of age and without verifiable parental consent, then We will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has obtained an Account on the Service, then you may alert us at privacy@toggleart.com and request that We delete that child’s Personal Data from our systems.

DATA RETENTION

We retain the Personal Data collected where an ongoing legitimate business requires retention of such Personal Data. In the absence of a need to retain Personal Data as specified herein, We will either delete or aggregate it or, if this is not possible then We will securely store your Personal Data and isolate it from any further processing until deletion is possible.

HOW TO CONTACT US

We only process your Personal Data in compliance with this Privacy Notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your Personal Data or are unsatisfied with how We have handled your information, you have the right to lodge a complaint with our Data Protection Officer at privacy@toggleart.com.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to update or modify this Privacy Notice at any time and from time to time without prior notice. If We make any material changes to the way We use or disclose your Personal Data, We will notify you by email, at the email address you have provided to us. If you object to any changes you must cease using our Service(s). Please review this Privacy Notice periodically by visiting this webpage from time to time as changes to this Privacy Notice are effective when they are posted on this page.

NOTICE TO END-USER AND OTHER EXCLUSIONS

Our Service(s) are intended for use by enterprises/retailers. Where the Services are made available to you through a Subscriber, that enterprise/retailer is the Controller of your Personal Data. Your data privacy questions and request should be submitted to the Subscriber in its capacity as your Controller. If you are an individual who interacts with a Subscriber using our Services, then you will be directed to contact our Subscriber for assistance with any requests or questions relating to your Personal Data. We are not responsible for Subscribers’ privacy or security practices which may be different from this Notice. Subscribers to our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by End Users. We collect information under the direction of our Subscribers, and have no direct relationship with individuals whose personal information We process in connection with our Subscriber’s use of our Service(s)

With the exception of Personal Data collected when you register for an account to access or utilize Our Service(s) and other information We collect in connection with your registration or authentication into Our Service(s), this Notice does not apply in connection with access and use of Our Service(s). The security and privacy practices, including how We protect, collect, and use electronic data, text, messages, communications or other materials submitted to and stored within the Service(s) by you (“Customer Data”), are detailed in and governed by Our Terms or such other applicable agreement between you and Us relating to your access to and your use of such Services.

Our website contains links to other websites. Our Notice applies only to Our website(s), so if you click on a link to another website, you should read their privacy policy. We encourage you to review the privacy statements of any such other websites to understand their Personal Data practices.

Cookie Policy

VR Enterprise (“ToggleArt” “We” or “Us” or “Our”) uses cookies and other similar technologies on our Websites available at (the “Websites”) to collect information from users that visit, use or access Our Websites. In this Cookie Policy (the “Cookie Policy”) We explain the purpose and use of cookies and similar technology that We collect when individuals and other persons including companies, organizations, other legal entities and their employees, representatives and agents (“You” or “User” or “Subscriber”) access and visit our Websites.

What is a Cookie?

A ‘cookie’ is a small piece of data sent from a website and stored on the User’s computer by the User’s web browser while the User is browsing. When You visit a site that uses cookies for the first time, a cookie is downloaded onto Your computer / mobile device so that the next time You visit that site, Your device will remember useful information such as visited pages or user preferences. Cookies are widely used in order to make websites work, or to work more efficiently, and Our Websites relies on cookies to optimize user experience and for features and Services to function properly.

Types of Cookies We use

Essential Cookies

ToggleArt uses essentials cookies which enable core functionality such as security, network management and accessibility. You may not opt-out of these essential cookies, however, You may disable these by changing Your browser settings, but this may affect how the Websites functions.

Analytics and Customization Cookies

ToggleArt uses Google Analytics cookies to help improve the Websites by collecting and reporting information on how You use the Websites, however the cookies collect the information in such a manner that the information does not directly identify anyone. ToggleArt also uses cookies to collect information on how its Websites are being used and identify the effectiveness of its marketing campaigns in order to customize the Websites for You.

Advertising Cookies

Technologies similar to cookies

Log files:

Log file information is automatically reported by Your browser each time You access a web page. When You use the Service, Our servers automatically record certain information that Your web browser sends whenever You visit any website. These server logs may include information such as Your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.

Clear gifs information:

When You use the Service, We may employ clear gifs (also known as web beacons) which are used to track the online usage patterns of Our Users anonymously. No personally identifiable information from Your ToggleArt account is collected using these clear gifs. In addition, We may also use clear gifs in HTML-based emails sent to Our Users to track which emails are opened by recipients. The information is used to enable more accurate reporting and make ToggleArt better for Our Users.

How and Why do We use Cookies?

We use automatically collected information and other information collected through Our Websites through cookies and similar technologies to: (i) personalize Our Service, such as remembering Your information so that You will not have to re-enter it during a visit or on subsequent visits; (ii) monitor and analyze the effectiveness of Service (iii) monitor aggregate site usage metrics such as total number of visitors and pages viewed;

These cookies do not collect personal information about You. A persistent cookie remains on Your hard drive after you close your browser so that it can be used by Your browser on subsequent visits to the Service. Persistent cookies can be removed by following Your web browser’s directions. A session cookie is temporary and disappears after You close Your browser.’

How can You control Cookies?

You may choose to accept or reject cookies used on the Websites. Most websites allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of Our Websites or Services. You can reset Your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Resources You may want to reference

Please reach out to the below links which may help You if You want to learn about advertiser’s use of cookies:

• Internet Advertising Bureau (US)
• Internet Advertising Bureau (EU)

Below is a reference to some popular browser manufacturers and their help pages relating to cookie management in their respective products.

• Google Chrome
• Internet Explorer
• Android Browser
• Safari (Desktop)
• Mozilla Firefox
• Safari (Mobile)

Updates to Our Cookie Policy 

We may update Our Cookie Policy to reflect changes to the cookies We use on Our Website or for other operational, legal and / or regulatory reasons as and when required. Please therefore visit this Cookie Policy from time to time to stay informed about Our use of cookies and related technologies.