Privacy Policy

Introduction

We are ankaEK Pvt. Ltd., operator of the a-OK Platform ("a-OK Platform", "we" or "us"). This is our Privacy Policy, which explains how we process (i.e., collect, store, use, disclose, and protect) the personal data that you provide to us via the a-OK Platform, mobile application, website, application programming interfaces (APIs), QR workflows, and related services and features (collectively, the "Services"). For the purposes of this Privacy Policy, "personal data" means any information that can identify an individual directly or through other reasonably available means, including name, images or videos, contact information, usage data, employment, and payment information. Such data may be collected through your access and use of our Services.

The choice to provide us with personal data is always yours. Upon your request, we will explain your options to refuse or withdraw consent to processing your data, and we will record and comply with your choices. Your decision to withhold particular details may limit the Services we are able to offer to you. For example, if you do not allow us to collect your payment information, we may not be able to process your payments.

If you give us personal data about someone else (such as family members or friends) or when you designate them as gift recipients, you must do so only with that person's express consent. You must inform them how we process personal data related to them according to this Privacy Policy before you provide us with such personal data.

By accessing and using our Services (e.g., visiting our website, accessing the features and creating an account), you acknowledge that you have read and understood this Privacy Policy and that you consent to processing of your personal data as described in this Policy. Please take the time to read this Policy in full, and if you do not agree with its terms, please do not access or otherwise use our Services.

Our Services are meant only for users 18 and older. We reserve the right to request proof of age, via a verified identification method, at any stage so that we can verify that minors are not using our Services without parental consent. If we become aware that a minor is using our Services, we will prohibit and block the user from accessing the Services until the user's parent or guardian consents to their use of the Services. If you are a parent or legal guardian, and you believe that your child has provided us with personal data without your consent, please contact us at [email protected].

Applicability

This Policy applies to all users and visitors of our Services, regardless of whether they have created an account with us. This Privacy Policy applies in conjunction with other applicable terms, notices or contractual clauses.

Types of Personal Data We Process

We will receive your personal data when you access and use our Services. For example, you may provide your personal data when logging in, when you provide us with feedback or when you contact us. If you access our Services through your social media accounts, we may access the personal data that you have provided to your social media provider and we will manage such data in accordance with this Privacy Policy. We process the personal data described below:

• Information about your identity such as your name, date of birth, gender, username and password, contact information including email address and telephone number, and data in any photographs or videos or audio recordings that you upload onto our Services. If you are a business, we will also collect company name, registered address, and other business-related information.
• Marketing and communications data which may include your interest and preferences for goods and services and survey responses.
• Gift recipient's contact details, including name, email address, contact information, and delivery address. You are responsible to inform and provide this Policy to the gift recipients you are sending gifts to.
• Payment transaction details (for example: your name, contact information, address, the amount paid, and the date of payment) from the payment service provider that processed your payment.
• Usage and technical data such as the Internet Protocol (IP) address, operating system, unique mobile identifier, browser software, access device and connection information such as browser type, version, and time zone, and browser plug-in types.

How We Process Your Personal Data

Below is a description of the purposes for which we process your personal data:

• Operate Services: To operate and maintain our Services, administer user account, send you Services-related updates, solicit your feedback, provide you with costumer service and to customize your experience.
• Processing Transactions: To set-up accounts and to process transactions.
• Customer Service: To respond to your requests and inquiries, to provide customer service, and to train our employees.
• Feedback: To solicit your feedback and improve our Services.
• Marketing: To send you recommendations and to help us improve and personalize our marketing activities and to conduct market research.
• Advisors: To provide information to representatives and advisors, including lawyers and accountants to meet our legal, accounting needs.
• Protecting our Legitimate Interests: To protect and enforce the rights and interests of our employees, users, suppliers, affiliates, business partners, and our own rights and interests, and to take any action in any case of dispute or legal proceeding.
• Information Security and Fraud Prevention: To prevent and remediate fraud, misappropriation, infringements, violations, identity theft, cyber-attacks and other security incidents, illegal activities and misuse or abuse of the Service.
• Compliance: To comply with court orders and warrants, and assist law enforcement agencies to prevent fraud, infringements, identity thefts and any other misuse of the Services.

With Whom Do We Share Personal Data

We do not sell personal data to others. However, we engage trusted third-party service providers to help us maintain and operate our Services, and we share personal data related to you with such providers which process personal data related to you on our behalf. For example:

• Marketing and Business Development: To deliver our marketing and business development campaigns, we may share information with digital marketing providers, social media and advertising companies, market research partners, potential customers, event organizers and registration providers.
• Sales, Finance, Business Operations and Delivering Service: We may use third-party sales tools to track pipeline activity and order information, finance and invoicing tools to assist in managing orders, customer billing and fulfillment, legal and compliance tools to assist in our contracting and compliance activities, consultants, contractors, and other specialists to provide professional services, and other vendors which support our operations.
• Vendors and Service Providers: Such vendors and service providers are contractually bound to keep personal data related to you confidential and appropriately secure. If you are a gift recipient, we will also share personal data that you provide us with the gift sender for billing purposes, shipping, gift monitoring, customer service, and fraud detection.
• Government Authorities: We may share your personal data with government authorities in the relevant jurisdiction to comply with legal process and to respond to requests from public and government authorities.

How Long Will We Retain Personal Data?

We retain different types of personal data for different periods depending on its purpose, our legitimate business purposes, and applicable legal requirements. We will maintain your contact details to help us stay in contact with you.

At any time, you can contact us to delete your contact information. We will retain personal data after you have terminated your use of the Services if retention is reasonably necessary to prevent fraud and abuse and misuse of data. Generally, we will keep your data as long as you use the Services unless applicable law requires us to delete it or if we decide to remove it according to this Privacy Policy and our terms and conditions.

Opting Out of the Services

You can choose not to receive our promotional or marketing emails by clicking on the unsubscribe link in the emails that you receive from us or by submitting your request to us at [email protected].

We can also still use and share such personal data with third parties for non-marketing purposes (for example to fulfill your requests and orders, communicate with you and respond to your inquiries, etc.). In such cases, the third-party service providers with whom we share your personal data are authorized to use your personal data only as necessary to provide these non-marketing services.

What Are My Privacy Rights and How Do I Exercise Them?

You have control over how we process your personal data. Your personal data will be deleted if you have not used our Services for thirty-six (36) consecutive months or until such time as you notify us in writing that you no longer wish to use the Services. Thereafter, we will stop processing personal data related to you.

You can contact us to request to exercise any of the following rights:

• Right to Know: The right to know what personal data has been processed about you. You can request a copy of the personal data related to you that we store about you by contacting us.
• Rectification: The right to correct inaccurate or incomplete personal data maintained about you.
• Deletion: The right to request deletion of personal data processed about you and terminate your account.
• Opt-Out of Sharing: The right to opt-out of the sharing of personal data related to you, or otherwise the use of such data for targeted advertising or profiling. As stated above, we do not sell your personal data to others for monetary or other consideration. However, we engage service providers to help us maintain our Services. At any time, you can opt out of the collection of personal data by such service providers by contacting us.
• No Discrimination: The right not to be treated in a discriminatory manner for exercising privacy rights.

Data Controller and Data Processor Roles

Depending on how you interact with the a-OK Platform, we may act as either a data controller or a data processor:

• When We Act as a Data Controller

We act as a data controller when we determine the purposes and means of processing your personal data. This includes data collected directly from users of our Services, such as account registration details, usage data, and marketing preferences.

• When We Act as a Data Processor

We act as a data processor when we process personal data on behalf of our business clients. For example:

• when business clients upload recipient information,
• when gifts are sent to employees, clients, or partners, and
• when we facilitate order fulfillment and delivery.
• In these cases, thebusiness client is the data controller , and they are responsible for ensuring that personal data is collected and shared with us in compliance with applicable data protection laws
• Third-Party Roles

Vendors, delivery partners, and payment processors may also act as independent data controllers or processors, depending on their role in fulfilling services.

Do We Use Cookies?

We or our third-party service provider can store some information on your device or device hard drive as a cookie or similar type of tracking technologies (such as beacons, pixel tags, etc.) to collect data related to your use of the Services. You can set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. However, if you disable all cookies, some features of the Services may not function properly.

Aggregated and Analytical Data

We use anonymous, statistical, or aggregated data and will share it with service providers only for legitimate business purposes. It has no effect on your privacy because there is no reasonable way to extract data that we or others can associate specifically with you.

Information Security

We are committed to ensuring the security of your personal data. Accordingly, we and our hosting services implement systems, applications, and procedures to secure personal data related to you to minimize the risks of theft, damage, loss of data, or unauthorized access or use of data. For example, we restrict access to users' personal data only to limited personnel and we use industry-standard encryption technology to process your payments.

These measures provide sound industry standard security. However, no security system is completely impenetrable. Although we make utmost efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Third-Party Sites

The Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of third parties. We advise you to check their privacy policies to determine how they process the information they collect from you.

Changes to this Privacy Policy

From time to time, we may update this Privacy Policy, which shall be effective immediately. Your continued use of our Services following such updates or changes constitutes your acceptance of the changes. Therefore, please periodically review this Privacy Policy for any updates or change.

Acknowledgment, Consent, and Business Use

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. Where processing is based on consent, you agree to the collection and use of your personal data as described herein. Where processing is based on contractual necessity or legitimate interests, your continued use of the Services constitutes acknowledgment of such processing. If you are using the Services on behalf of a business or organization, you represent that you are authorized to do so and that you have obtained all necessary consents from individuals whose personal data is provided to the Platform.