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Privacy policy

Last Update Date: 30th September 2018
Effective Date: 24th October 2018
This privacy policy will inform you about the type, scope and purposes for collection and use of personal data on this website. It describes the information that we collect about you when you visit our website, www.winningsparrow.com (the “website”) and use the services available on the Website (“Services”), and how we disclose that information. The responsible organization is Strategic Consulting Group Pvt. Ltd., registered under Company’s Act 1956 in India as operator of an online platform at www.winningsparrow.com and its related services Strategic Consulting Group Pvt. Ltd. values your privacy , and if you have any questions or comments about the Privacy Policy, please contact us at support[at]winningsparrow.com. This policy is incorporated into and is subject to the WinningSparrow Terms of Use, which can be accessed at www.winningsparrow.com/terms.
In terms of the Information Technology (Intermediate Guidelines) Rules, 2011 and the information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. Any grievances or complaints may be intimated to, Santosh Punde - Grievance Officer, who may be reached at info[at]strategicconsulting-group.com, info[at]winningsparrow.com or by telephone at +91-124-4049831 (during regular business hours, Monday to Friday, 9 am to 5 pm) or by email at info[at]winningsparrow.com. The complaint shall be readdressed within a period of 1 month .

What is Personal Data?

Personal Data is the information through which a persona may be identified i.e. that can be traced to a specific person. It includes information that whether on its own or in combination with other information with other information may be used to readily identify or contact you such as: name, address, email address, phone numbers etc. It may also include data on one’s preferences, hobbies, membership or viewed websites.
We only collect, use or transfer personal data provided to us if permitted by law or if users consent to the data collection.

What Personal information/data is colleted when using WinningSparrow services?

We collect personal information from Service Professionals offering their products and services. The information is partially or completely accessible to all visitors using WinningSparrow’s website (services) or mobile application, either directly or by submitting a request. Service Professionals and clients are required to create an account to be able to access certain portions of our website or mobile application. The type of personal information we collect depends upon your particular interactions with our website or mobile application, and varies accordingly.
We also collect data on every visit to our website, called server log files (“access data”) (name of the webpage visited, time and date of visit, the amount of data transmitted, your operating system etc.) and when using mobile devices additionally we also collect your country code, language, device name, operating system name and version.
The access data will be used by us for statistical evaluations for the operations, safety and optimization of WinningSparrow offers. However, we reserve the right to subsequently review access data if usage gives a specific indication of unlawful use.
Consumers/Clients: During the account registration process and during the usage of the WinningSparrow website or mobile application, we will collect information such as your name, postal code, telephone number etc. You may also provide us with your mailing address, demographic information, and other information relevant to you. We also collect personal information that you post in your Offer, Profile, Feedbacks etc or other correspondence sites on the website www.winningsparrow.com or mobile application, or any comments you provide during dispute resolution with other clients or service professionals of the website or mobile application.
Service Professionals: We require you (service professionals) to register for an account on our website, if you want to post any information about useful. During the account registration process we will collect your business name, telephone number, address, zip code, travel preferences, a description of your services, a headline to your profile, name, email address and other details. You may also be required to provide other content or information about your business, including photographs, office address, previous projects etc.
Background Verification: The service professional acknowledges that as part of our on-boarding process, the Company or a Verifier (entity appointed or nominated by the Company) may undertake a background verification checks of the service. Thus, with respect to the above, the Service Professional provides consent to and acknowledges the following:
  1. The service professional will not have any objection to WinningSparrow sharing their personal information and documents, including but not limited to name, gender, date of birth, mobile number, education, email, ADHAAR number and other government issued identifications such as Voters ID, PAN card etc with the Verifier for the purpose of background checks and verification.
  2. The service professional authorizes the verifier to securely store the Service Professional’s proprietary information and understands that the verifier shall endeavor to ensure confidentiality of the same. WinningSparrow and its authorized users/partners/affiliates/contractors shall be entitled to access such digital record.
  3. WinningSparrow reserves its rights to take appropriate actions against a fraudulent background check and verification.
WinningSparrow reserves its rights to record the conversation between service provider and consumers/clients facilitated by WinningSparrow through the messaging and chat options available on the platform. All the chat/message recordings may be used to monitor and prohibit abuse and fraud, safeguard the rights of the users of WinningSparrow, and resolve disputes.
If we deem it necessary, in our sole discretion, we may also collect information from third parties, such as information regarding your credit scores (to the extent permitted by law), or information to verify any identification details you provide during registration.
Services provided by us after successful registration are not offered to persons under 18 years of age. Therefore, no personal information on visitors younger than 18 years of age is intentionally collected during registration.
Service Provider Payment Data: After registration, before the first project of the service provider (and inclusive subsequent projects) , for the purpose of payment processing we will collect the following “payment data”: Bank account No., Account Holders name and other banking details. This payment data will only be collected, saved and used by us for billing and payment transactions of fees to which service provider users are entitled in accordance with the regulations of the contract between WinningSparrow and the service provider. The user is allowed to review, change or delete this data on his user profile at any time.

What Personal information/data is collected from social networking sites?

You may register and also log on to our website through your Facebook/Linkedin/Xing/Twitter account. If you do so, you must enter the email address and password that you use to log in to your account. We will ask you to grant us permission to access and collect your basic information in accordance to usage terms and the privacy policy (ex. Your name, professional experience, education etc.). We can also access other information which you have chosen to disclose but isn’t public.
We store the information that we receive from Facebook/LinkedIn/Xing/Twitter with other information that we collect from you or receive about you. This information will be used by us to provide our offers and services.
Links to Social Media: WinningSparrow is connected to various Social networking Sites like Facebook, Twitter, Linkedin, and Xing, through links. Activating such buttons will forward you to the WinningSparrow page on the respective social network where data will only be processed by the servers of the respective social network.

What Automatic information/data is colleted when using WinningSparrow’s services and how we use cookies and other tracking services?

We and our third party service provider, which include advertisement networks, use cookies, web beacons, and other tracking technologies to collect information about your use of our website and services, such as your ISP, operating system, domain name, access time, your IP address, and type of device you use.
We also track how frequently you visit our website, we use this information for website analytics., to assist us in determining relevant advertising(both on and off our website), to evaluate the success of our advertising campaigns, and as otherwise described in the policy. We may also obtain your device ID, which is sent to our servers and used for fraud prevention efforts.
We and our third party service providers collect information from you by using cookies. A cookie is a small file stored on the user’s computer hard drive containing certain user information. Cookies allow web application to tend to you as an individual, tailoring its operations to your needs. When you visit the website we may send one or more cookies to your computer that identifies your browser. Some of these may be connected to third party service providers and websites. The terms of use of such cookies are governed by this Policy and the privacy policy of the relevant third party companies or websites. For example, Google Ads, Google Analytics etc.
Disabling Cookies: You can choose to accept or decline cookies (by default, most web browsers automatically accepts cookies), if you disable cookies you may be prevented from gaining full advantage/usability of the website because it may not function properly if cookies are disabled. We and our third party service providers also use clear GIF’s in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Third-party websites: By clicking on a link to another website or location, you will be transferred to another website; in this case, your personal information or anonymous data may be collected by another service provider. We do not monitor or review these external websites or their contents and thus shall not be liable for their contents or their data collection.

How Personal information/data collected, is used by WinningSparrow?

Generally the data provided, is used by WinningSparrow generally to perform our services, provide a better experience and answer other questions. We collect and aggregate information about the use of our website and services to understand you better and provide a better overall website experience. We use data and information (among other things) provided by users, for the following purposes:
  • Easy registration and security of your account
  • Website improvement and provide better service
  • Internal research and development, and record keeping purposes
  • Preventing blocked users from re-registering
  • Client specific design to meet your preferences
  • Answering user requests and questions
  • Sending your profile to a client after receiving your permission
  • Occasional telephonic conversations with you for secondary fraud protection or to obtain feedback from you.
  • Sending administrative, security, support or maintenance email notifications.
  • Performance of requested services.
  • Answering user questions and requests.
  • Sending emails to registered users with contents related to our services insofar as the user doesn’t object.
  • Process billings and payments, including sharing with registered third party payment gateways.
  • For troubleshooting purposes, where applicable.
  • We may use demographic information (i.e. age, postal code, location, income group, education etc) to more effectively facilitate the promotion of goods and services to appropriate target audiences and for other research and analytical purposes.
  • To resolve disputes, to protects ourselves and users of the Website and Services, and to enforce our Terms of Use.
  • We may also compare personal information received from you, to verify its accuracy and authenticity with personal information collected from third parties.
From time to time WinningSparrow may use personal information for new and unanticipated uses not previously disclosed in our privacy policy. If our information policy changes, WinningSparrow shall make reasonable efforts to provide notice and obtain consent of any such uses as may be required by Law.

Electronic Newsletters, Invitations, Polls and Surveys

WinningSparrow may offer any of the following free web-services, which you may select to use or receive. Certain of the following services may require you to provide additional personal information as detailed below:
Electronic Newsletters: WinningSparrow offers free electronic newsletters to users. We will gather email addresses of users for the newsletter mailing list. Users may remove themselves from the mailing list by opting out of receiving newsletters during the registration processes, or by following the link provided in each newsletter or by changing their preferences in their profile settings page.
Send to a friend: WinningSparrow users can voluntarily choose to electronically forward a link, page or document to someone else by clicking “send to a friend”. To do so, the user needs to provide its as well as the recipients email addresses. This information is not used for any other purposes otherwise stated.
Polling: WinningSparrow may offer interactive polls to users so they can share their opinions with other users and see what our audience thinks about important issues, services, and/or the website. Opinions or other responses to polls are aggregated and are not identifiable to any particular user. We might use a system to “tag” users, so they are limited to vote only once per poll.
Surveys: WinningSparrow may conduct user surveys from time to time to better target content on the website. We don’t share individual responses to third parties, but share aggregate data with them. We also may share aggregate data on our website, which can be viewed and downloaded by other users of WinningSparrow.
Security: WinningSparrow is very concerned about the security of your personal data. We (and our external service partners) use a number of industry standard security technologies and procedures to protect your personal information from unauthorized access, use or disclosure. WinningSparrow may use encryption, passwords and physical security measures to help protect your information. No security measure is however 100% complete. Therefore, we do not guarantee, and thus, one cannot expect that their data and personal information will not be collected by others. You should take steps to protect against unauthorized access to your password that nobody can easily guess and nobody knows, keeping your login passwords private and other security measures should also be taken. WinningSparrow will not be responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords or for any activity on your account via unauthorized password breach.
Disclosure: We may share the information that we collect about you, including your personal information, as follows:

Information disclosed to protect us and others

WinningSparrow may disclose your information (including personal information) if;
  • Disclosure is necessary in order to comply with legal processes (ex. Court order, search warrants etc.) or other legal requirements of any governmental authority.
  • Necessary by reasonable doubt to enforce this privacy policy, terms of use etc.
  • Disclosure is necessary to prevent unauthorized transactions or other illegal activities.
  • Necessary required to protect our rights, or the rights of any person or entity.
  • Disclosure would potentially mitigate our liability in an actual or potential lawsuit.

Information disclosed to third party service providers and business partners

WinningSparrow has contracts with various third party organizations for the operations and maintenance of the website. WinningSparrow and third party business operations may need to share your personal information and data generated by cookies and aggregate information with the vendors and service agencies. If you complete a survey, we may also need to share your information with the survey coordinators.

Disclosure to non-affiliated third parties with after your request

Your request for services may be shared with third party websites with whom we have contractual relationship in order to provide your request with maximum exposure. Personal Information including details of your request, location, and other contact details.

Disclosure to other users of our website

Other users and service providers, will be able to see the information that you post(other than your payment information), Comments that users post on the website will be available for other visitors to our website. In addition we will posts results (in aggregated form) of surveys or polls on our website.

Disclosure to government officials and law enforcement officials

If required by any law enforcement or other government authority, WinningSparrow will disclose your information, including, and without limiting to, your name, city, telephone number, email address and other data permitted by law.

Disclosure in case of change of control or bankruptcy

In the event that WinningSparrow undergoes a change in control, it reserves a right to transfer the information collected from users of the website/ mobile app to the third party entity (the successor). This includes, without limiting, to merger or sale of all or substantially all of WinningSparrow’s assets.
In addition, in case of bankruptcy, receivership, reorganization, or application of laws and equitable principles affecting the creditors, WinningSparrow may not be able to control how your information is transferred/utilized.

Information Disclosed at your request

WinningSparrow may share your personal information (to the extent permitted by you), with other registered users(including but not limited to service providers) to whom you explicitly ask us to send your information. For example, If you contact another service provider on our website, we send that registered user a notice that includes your basic details that you’ve chosen to allow.

Links to External Websites

The website may contain links to external/other websites to which WinningSparrow has no control over. Such links don’t have an endorsement by WinningSparrow on those websites. WinningSparrow is not responsible for protection and privacy of any information shared with these websites and such sites are not governed by our policy. WinningSparrow has no control over the kind of information collected, and the intended utilization of the provided information/data. Your use of any external websites is subjected to the terms of use and privacy policy located on the visited external websites.

Your Personal Information

One may choose to restrict the collection of their personal information in the following ways:
  • You can review, correct and delete your personal information by logging onto the website and navigating to profile settings.
  • One must promptly update their personal information if it becomes outdated or inaccurate.
  • Upon request, WinningSparrow will close your account and remove all the personal information from view as soon as possible based on the account activity and applicable law.
  • WinningSparrow does retain information from closed accounts, however, accounts that have been closed are unavailable on the website and/or mobile application.
  • WinningSparrow will not be responsible for any personal information that was not included, and remains on the website.

Correction and Reviewing of Data

You have the right to demand the correction of inaccurate personal data saved on you. In processing considerations, you have the right to demand the completion of incomplete personal data. For further information please contact us at info[at]winningsparrow.com

Deletion (Right to be Forgotten)

You have the right to delete any personal data saved by us. For further information please contact us at info[at]winningsparrow.com

Right to data portability

You have the right to receive your data provided to us in a machine-readable and commonly used format. For further information please contact us at info[at]winningsparrow.com
Furthermore, you have the right to transmit the data to another controller without hindrance from the controller to whom the personal data was provided. When exercising your right to data portability, you have the right to have your personal data transmitted directly provided it is technically feasible.

Right to object

You have the right to submit a complaint to a competent supervisory authority, if you have any objection regarding our data policies and terms of use. Also, you can contact us at info[at]winningsparrow.com for further information and regarding any queries. You can also write to us at support[at]winningsparrow.com.

Storage duration of personal data

WinningSparrow will generally only save your personal information for as long as required for performance of the contract or respective purposes and limit the data stored to an absolute minimum.
In case of longer contractual relationships, storage periods may vary, but are generally limited to the duration or to the legally required storage periods. Storage duration depends upon whether the data is up to date, whether there is a contractual relationship with WinningSparrow etc.

Safeguarding Your Personal Information and Password

WinningSparrow is concerned about the security and protection of the personal data provided to us. We (and our external service providers) use a number of standard industry security technologies and procedures to protect your personal information from unauthorized access, use or disclosure. Data of our WinningSparrow services is exclusively stored in Digital Ocean servers unless otherwise stated.
Your password is the key to your account, DO NOT disclose it to anyone. If you do share your password or your personal information with others, you are solely responsible for all actions taken via your account. If you lose your password, or control of your account you may be subjected to legal binding actions taken on your behalf from your account. Please notify WinningSparrow in such cases on info[at]winningsparrow.com or support[at]winningsparrow.com immediately to change your password.

User Generated Content

We invite you to post comments, pictures and other feedbacks and information that you would like to be available on our website. If you post content on our website, all of the information that you post will be available to all visitors to our website. Your posts may become public, and WinningSparrow cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

Safeguarding Your Personal Information and Password

THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH ABOVE. WINNINGSPARROW MAY, IN ITS SOLE DIRECTION CHANGE THIS POLICY FROM TIME TO TIME. WINNINGSPARROW WILL POST THE UPDATED VERSIONS OF THIS DOCUMENT ON ITS WEBPAGE. WINNINGSPARROW ENCOURAGES YOU TO REVIEW THIS POLICY REGULARLY FOR ANY CHANGES.
OUR PRIVACY POLICY MAY BE VIEWED ON AND PRINTED FROM OUR WEBSITE AT ANY TIME AT http://www.winningsparrow.com/privacy-policy