Privacy Policy

Welcome, and thank you for taking our services.

This Privacy Policy describes the kind of information we gather on or through the Thinking Grey services, and how we use and disclose such information, and the steps taken by us to protect such information. By visiting the site, you accept the terms and conditions of this Policy.

This Policy is incorporated into, and is subject to, our Terms of the website. Capitalized terms used but not defined in this Policy have the meaning given to them in our Terms of the website.

1. Collection of Information
We collect some information from or through the website. The legal bases for our processing of Personal Information are primarily that the processing is necessary for providing the content in our website and that the processing is carried out in our legitimate interests, which are further explained in the “Use of Information” section. We may also process Personal Information upon your consent, asking for it as is appropriate.

a) User-Provided Information
When you use the website, you may provide and we may collect certain information that personally identifies you or could be used to personally identify you (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information: first name, last name, email address, username, password, student ID and other educational record data. Personal Information also includes other information, such as preferences and usually the kind of information that will help in identifying any individual. You may provide us with Personal Information in various ways on the Website. If you choose to withhold any Personal Information requested by us, it may not be possible for you to gain access to certain parts of the website.
When you use the Website, we may collect information about your location. With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.
Our website might send push notifications to your device. Our website may also request access to your device’s calendar website, camera and gallery. If you have previously allowed access to your device’s calendar camera and/or gallery, or don’t want push notifications and no longer wish to allow access, you may edit the website settings at the device level .

b) Information from Other Sources
We obtain information, including Personal Information, from third parties and sources apart from the Website, like our partners Google and Facebook. If we combine or associate information from other sources with Personal Information that we collect through the Website, we will treat the combined information as Personal Information in accordance with this Policy.

2. Use of Information

• We may use the personal identification information you provide to ensure the security of or our website
• Thinking Grey will be not disclose your personal identification information
• Your personal identification information may be used to allow access to the website and provide you any service that you may request from us.
• We may use the personal identification information to provide technical support as and when required.
• We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
• No personal identification information will be posted in third part websites or Website forum
• When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Notice. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.

3. Communication of Information
In certain circumstances, in order to get optimum performance from the Website, we may disclose certain information that we collect from you as follows:

• Within our family of companies, including parents, corporate, affiliates, subsidiaries, business units and other companies that share common ownership.
• With law enforcement and governmental entities when required by law. For greater clarity, we may disclose Personal Information or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies; and
• When we disclose your Personal Information to third parties, we take reasonable measures to ensure that the rules set forth in this Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organizational measures.
• We may finally make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding your interests, habits, and usage patterns for certain programs, content, websites, and/or functionality available through the Website.

4. Security and Retention
We follow all kinds of accepted industry standards to protect the information given to us, for both during transmission and once we receive it. We maintain all appropriate physical, technical and administrative safety measures to protect Personal Information against any kind of accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. Although we cannot ensure 100 % security of transmission over internet and any information transmitted over internet is at your own risk. We do not guarantee that any such information cannot be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or administrative safeguards. If you believe your Personal Information has been compromised, kindly contact us as set forth in the “Contact” section below. If we find a security systems breach, we will inform you and the authorities responsible for such occurrence of the breach in accordance with applicable law.
We shall keep your Personal Information only for as long as necessary to fulfill any relevant purposes set out in this Policy and in order to comply with our legal and regulatory obligations. If you would like further information regarding the periods for which your Personal Information will be kept, please contact us as set forth in the “Contact” section below.

5. Data Transfer
Your Personal Information could be stored and used in any country where we have facilities or in which we engage third party website providers. By using the Website and agreeing to the policy , you will consent to the sharing of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of INDIA, it is subject to the laws of the country in which it is being used, and is subject to disclosure and use to/by the governments, courts or law enforcement or regulatory agencies of many other country, in accordance to the laws of those countries. Although, OUR practices for your Personal Information will at all times continue to be governed by this Policy and, if applicable, we will comply with the General Data Protection Regulation(“GDPR as adopted on 27th April 2016 by the European Union in replacement of the earlier Data Protection Regime in India.”) requirements providing adequate protection for the transfer of Personal Information from India to third country.

6. Third-Party Websites
The Website contains features or links to websites and websites provided by third parties. Any information provides by you for third-party sites or websites is given directly to the operators of the websites and is subject to their own operators’ policies, and if any, governing privacy policy and security norms, even though it is accessed through our Website. We will not be responsible for the content or privacy and security practices and policies of third-party sites or websites to which links or access are provided through the Website. We encourage you to learn and understand about third parties’ privacy and security policies before providing them with information.

7. Rights Regarding Personal Information
With a written request and subject to proof of your identity, you may gain access to the Personal Information that we hold, used or communicated and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, in case of any change in your personal information we expect you to send an email or mail to us and/or else we will make sure that the Personal Information we maintain about you is accurate and up to date.
Under the GDPR, you might be entitled to specific provisions, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your Personal Information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of Personal Information about you, under certain conditions; (v) the right to demand that we restrict processing of your Personal Information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your Personal Information is inaccurate; (vi) the right to data portability of Personal Information that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection at: http://ec.europa.eu/justice/data-protection/index_en.htm. Please note that the term Personal Information used in this Policy is equivalent to the term “personal data” under the GDPR.

8. Limitation of Liability
Thinking Grey , Thinking Grey and our affiliates, Officers, employees, stockholders, licensors, vendor, agents, developers will not be liable for any indirect, incidental, special, consequential, punitive, or multiple damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill or other intangible losses, resulting from: (a) your use of the Services or inability to use the Services; (b) your access to or inability to access the Services; (c) the conduct or content of other users or third parties on or through the Services; or (d) unauthorized access, use or alteration of your content.
Our Service is provided "as is," and we can't guarantee it will be safe and secure or will work perfectly all the time. TO THE EXTENT PERMITTED BY LAW, WE ALSO DISCLAIM ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT
We also don't control what people and others do or say, and we aren't responsible for their (or your) actions or conduct (whether online or offline) or content (including unlawful or objectionable content). We also aren't responsible for services and features offered by other people or companies, even if you access them through our Service.
Our responsibility for anything that happens on the Service (also called "liability") is limited as much as the law will allow. If there is an issue with our Service, we can't know what all the possible impacts might be. You agree that we won't be responsible ('liable") for any lost profits, revenues, information, or data, or consequential, special, indirect, exemplary, punitive, or incidental damages arising out of or related to these Terms, even if we know they are possible. This includes we delete your content, information, or account. Our aggregate liability arising out of or relating to these Terms will not exceed the lower of Rs.100 or the amount you have paid us in the past twelve months.

9. Data Controller / Data Processor
In accordance with the GDPR, Thinking Grey is acting both as a “Data Controller” and as a “Data Processor”. As Data Controller, Thinking Grey is responsible for safeguarding the data of our customers as they interact directly with our websites like . As Data Processor, Thinking Grey is responsible for safeguarding the data of our partners’ and customers’ users as it flows through our system.

10. Children’s Privacy
The Website is not directed to children under the age of 16, and we do not knowingly collect Personal Information 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 Website at any time or in any manner. If we learn that Personal Information has been collected on the Website 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 provided Personal Information, then you may alert us as set forth in the “Contact” section and request that we delete that child’s Personal Information from our systems.

11. Update
You are requested to revisit the page periodically to make sure you are aware of any changes for this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Website, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Website after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

12. Contact
Questions related to the Policy given by us or your Personal Information that has to do with accessing information, or change request, or exercising of rights or filing complaints or further information about the policy or reasonable question request about Thinking Grey or Thinking Grey Website or about service provided outside of India we can be reached by the following contact.
Thinking Grey
5067, 3rd Floor, Rustomjee Ease Zone,
Opposite Rustomjee Ozone,
Malad west, Mumbai,
Maharashtra
4000064
privacysupport@thinkinggrey.com
Phone Number : 022-40223100

Last Updated on 1st Feb 2021