GALE Creative Agency Private Limited (hereinafter referred to as “GALE”/ “We”/ “Us”/ “Our”) having its registered office at No.3/1, Ground Floor, JP Techno Park, Miller Tank Bund Road, Vasanth Nagar, Bangalore 560 052, Karnataka, India, on behalf of itself and its affiliates/group companies under the brand ‘Markey’, operates the website ‘www.markey.ai’ (the “Site”) and its digital marketing technology subscription services (the “Services”) through ‘app.markey.ai’ and various other sub-domains (together referred to as “Platform”).

This Privacy Policy (hereinafter referred to as “Policy”), describes how we collect, use, and disclose information that we obtain about,

a. Visitors and Users (“User”/ “Visitor”/ “Client”/ “Subscriber”) of our Site and Services available through our subscription Platform and any related services offered by Us under the brand ‘Markey’,
AND
b. End Customers and Visitors (“Our Client’s End Customers”) of Our Clients/Subscribers, on their behalf, for the purposes of fulfillment of digital marketing services for which the Client/ Subscriber has subscribed to our Platform, 

collectively hereinafter referred to as “You”/ “Your”.

In this policy we describe the type of information collected; the purpose for which the information is collected; how the information is used; the intended recipients of such information; when it might be disclosed and how You can control the collection, correction and/or deletion of Your information and how the information is protected. We take the protection and proper use of Your information seriously and are committed to protecting such information in Our possession. Any capitalized terms used herein without definition shall have the meanings assigned to them in Our Terms of Use.

We advise You to read this Policy carefully prior to Your access of our Site, Platform, use of Services, or creation of an Account on the Platform, as the case may be. If You do not agree to this Policy, please do not access Our Platform, use Our Services, or create an Account in Our Platform. 

Our Site and Platform may contain links to other third-party websites or products. If You click on a third-party link, You should read their privacy policy before proceeding further. This Privacy Policy does not apply to any third-parties that are not owned by Us.

This Privacy Policy has some provisions that only apply to Our Visitors/ Users/ Clients/ Subscribers, and some that only apply to Our Client’s End Customers, respectively, and it also has provisions that apply to both. Please read the applicable Privacy Policy provisions carefully before proceeding.

1. FOR OUR CLIENT’S END CUSTOMERS

1.1 WHAT KIND OF INFORMATION DO WE COLLECT AND HOW

Our Clients provide us with the following types of information about their End Customers (Personal Information) either by embedding our tracking code into their websites or applications or digital advertisements run through our Platform, or through other data transfer means:

• Personally Identifiable Information (“PII”) such as an End Customers email address, name, and phone number. 
• We also obtain additional information about End Customer’s access or use of Our Client’s services and communications, such as actions taken, content viewed, messages clicked, offers accepted, search terms entered, advertisements clicked, applications opened, transactions done, and 
• End Customer’s device information, such as operating system, unique device identifiers, IP addresses, and access date, time, and location information.

1.2 HOW DO WE USE THE INFORMATION

We collect information about Our Client’s End Customers (You/Your) to provide Our Clients (They/Their) with behavioral and analytics data related to how their End Customers interact with their websites, products and services, and marketing promotions online, and use the information for providing digital marketing services through our Platform. We do not directly seek personal information from Our Client’s End Customers; we collect information using tracking technology that Our Clients install in their Websites or Applications or Digital Advertisements or share with us through other data transfer means, pursuant to their information collection and sharing practices, which are typically outlined in a privacy policy like this one and made available on their own website or service contract. We encourage all End Customers to read the privacy policies of Our Client they engage with.

For the purpose of this privacy policy and in accordance with the GDPR regulations for EU residents, Our Client is the Data Controller of its End Customer’s data (Data Subject) and We are only the Data Processors, when We collect and process their End Customer’s Personal Information for providing our Services.

We analyze and use the End Customer’s information solely to provide and improve our Platform Services for Our Clients. Markey collects information under the direction of Our Clients and has no direct relationship with their End Customers whose personal data it processes.

Please ensure you read, understand, and accept the privacy policies and any terms of use of Our Client before using their services or engaging with them. We assume no liabilities arising from your access or use of Our Client’s services and marketing communications, sharing your personal information with them, and their compliance with their own data security and privacy policies, and applicable laws & regulations.

1.3 RETENTION OF PERSONAL DATA/ INFORMATION

We will retain personal data we process on behalf of Our Clients for as long as needed to provide services to them. We will also retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

1.4 OPT-OUT

An End Customer of Our Client who seeks to opt out of any communications from Our Client, whether sent through Markey Platform or otherwise, must direct their query to Our Client directly with whom they have engaged and have a business relationship with. Our Client may request us to process the opt out request of the said End Customer, which we shall do so within 30 days of receipt of such request.

1.5 CHANGE, CORRECTION, DELETION OF PERSONAL DATA

An End Customer who seeks access, or who seeks to correct, amend, or delete their personal information should direct their query to Our Client directly. If requested by Our Client to remove or modify any or all of their End Customers data, we will comply within 30 days from the date of receipt of such request.

2. FOR OUR VISITORS/ USERS/ CLIENTS/ SUBSCRIBERS

2.1 WHAT KIND OF INFORMATION DO WE COLLECT AND HOW

When You (Our Visitor/ User/ Client/ Subscriber) access Our Site or Platform and/or create an Account with Us, and/or use the Services provided by Us, We shall collect certain information from You and about You, the details of which are provided below,

2.1.1 Personal Information

Any Information that relates to You as a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying You and any further information, including, without limitation, provided by You to Us when You (a) subscribe for any of Our Services/Platform by signing-up such as Your complete name and address, Your company/entity’s name (if any), Your designation in the company/entity (if any),Your contact number, Your email address and any other identifiers and any other sensitive/personal information as defined under the Applicable Laws as amended from time to time; b) use or view Our Platform which may result in personal information/data being collected via Your browser’s Cookies; c) request customer support, or otherwise communicate with Us; or d) when You use the Services, We automatically collects information on the type of device You use, your IP and related information, and the operating system version (“Personal Information”).

2.1.2 Usage Information

Any information that is not Personal Information, but information collected in relation to Your use of the Platform or information required for the proper functioning and development of the Platform, including, without limitation: (i) time, date and extent of Your usage of the Platform; (ii) Your usage and search history within the Platform, (iii) device keyboard settings; (iv) time zone, language, screen resolution, and other usage preferences You select when using the Platform; (v) the URL or advertisement that may have directed You to the Platform; (vii) other device and Platform access information viz., Your IP address, operating system, browser type, referring/exit pages, and other unique device identifiers, as well as Your push notification token.

2.1.3 Behavioral Information

We shall collect information which is connected with Your activity on the Platform across all Your devices using Your email or social media log-in details/credentials, as well as Services that You search, and opt-ins and communication preferences.

2.1.4 Location Data

Information about Your location when accessing and/or using the Platform if You chose to opt-in. With Your permission, We may collect Global Positioning System (GPS) data and mobile device location information. If You do not wish to share Your precise location with Us, You can switch off location services via the settings on Your mobile device.

2.1.5 Cookies

We and Our service providers and business partners use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages and advertisements You click on and how You use the Website, enhance Your experience using the Platform, improve the Platform, provide You with advertising on the Platform and elsewhere across Your devices, and measure the effectiveness of Platform. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from Your computer or device.

We, Our service providers and business partners shall set any Third Party Cookies to improve Our Platform by collecting and reporting information on how You use it. These cookies collect information in a way that does not directly identify anyone. We also set Third Party Cookies to collect information that is used either in aggregate form to help Us understand how Our Platform are being used or how effective their marketing campaigns are, to help customise the Platform for You or to make advertising messages more relevant to You.

For the purpose of clarification, “Third Party Cookies” means cookies provided by any third party service provider or vendor.

2.1.6 Transaction and Payment Information

We or Our authorised payment gateway solution providers or We through Our authorised payment gateway solution providers, as the case may be, collect information such as billing address, credit/debit card number, its expiration date or any other payment instrument details and transaction details or any other third-party payment information of You.

2.1.7 Device Information

We collect information about computers, phones, and other connected devices with a web connection and the presence of Our Platform and Services and integrate this information with the various devices You use. This information includes: device features such as information about operating system, hardware and software versions, battery status, signal availability, available storage space, browser type, app or file names and types, and plug-ins, device activities such as information about the activity and behavior of the device, for example in the background or in front of a window or with mouse movements (which help to distinguish humans from boats), unique identifiers, device ID, games, apps, or accounts You use, Bluetooth signals and information about nearby WiFi access points, beacons and cell towers, Personal Information that We are permitted to collect by turning on access in device configuration, as well as providing access to GPS location, camera or photo, information such as Your mobile operator’s name or ISP, language, time zone, mobile phone number, IP address, connection speed, and other devices near Your device or on the network so that We can help You with the streaming of the Services on Your device.

2.1.8 Third party Information

Information about You that We may receive from third parties services, such as advertising partners, data providers and analytics providers.

2.1.9 Social Networks Information

We may collect Your third-party social media networks information including Your contact lists for these Services and information relating to Your use of the Platform in relation to these Services, if You choose to link or sign up using a third-party social network or login service (such as Facebook, Twitter, Instagram, or Google). If You link Your Account in Our Platform to another service, We may receive information about Your use of that service.

2.2 HOW DO WE USE YOUR INFORMATION

2.2.1. As explained below, We use Your information to improve, support and administer the Platform and Our Services, to allow You to use its functionalities, and to fulfill and enforce Our Terms of Use. We may also use Your information to, among other things, show You suggestions, promote the Platform, and customize Your ad experience, in accordance with applicable laws.

2.2.2. We generally use the information We collect for the following purposes:

• to structure the Services provided to the Users through the Platform;
• to fulfill requests for Services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• to communicate with You, including to notify You about changes in Our Services;
• quality assurance purposes;
• to improve and develop Our Platform and conduct service development;
• to customize the Services, You see when You use the Platform, to enforce Our terms, conditions, and policies;
• to prove Your identity in order to use certain features;
• to combine all the information, We collect or receive about You for any of the foregoing purposes;
• to maintain security and help Us detect abuse, fraud, and illegal activity on the Platform;
• to understand how You use the Platform, including across Your devices;
• to support the social functions of the Platform;
• to make suggestions and provide a customized ad experience;
• to send promotional materials from Us or on behalf of Our affiliates and trusted third parties;
• to measure and understand the effectiveness of the advertising We serve to You and others and to deliver advertising;
• consistent with Your permissions, to provide You with location-based services, such as advertising and other personalized content;
• for any other purposes disclosed to You at the time We collect Your information or pursuant to Your consent.

2.2.3. However, If You have given Us Your information, We shall use all the data collected to: (i) Contact You for taking Services feedback and (ii) Processing payment instructions including those through independent third-party service providers such as payment gateways, banking and financial institutions, pre-paid instrument and wallet providers for processing of payment transaction or deferral of payment facilities.

2.2.4. We shall not sell or rent Your Personal Information to anyone, for any reason, at any time. However, We will be sharing Your Personal Information with Our affiliates and business partners.

2.2.5. If We need to process Your Personal Information for an incompatible purpose not discussed in this Policy, We will provide notice to You and, if required by law, seek Your consent. We may process Your Personal Information without Your knowledge or consent only where required by Applicable Laws.

2.2.6. The purposes listed in the above clauses may continue to apply even in situations where Your relationship with Us (for example, pursuant to a contract) has been terminated or altered in any way, for a period of 180 days from the date of such termination or alteration (including, where applicable, a period to enable us to enforce Our rights under any contract with You).

2.3 RETENTION OF PERSONAL DATA/ INFORMATION

We shall retain Your Personal Data/ Information or other information (“Your Data”) for as long as We need it to fulfil the purpose for which We have collected it and/or if applicable, as long as required by statutory retention requirements and/or according to the timeframes set forth under the Applicable Laws.
Thereafter, Your Data shall be permanently removed (except when required by law to retain). We make no representation or warranty with respect to any duty to permanently store any information You may provide or that We otherwise collect about You except as required under the Applicable Laws.

Please note that statutory storage obligations or the need for legal actions that may arise from misconduct within the Platform can lead to a longer retention of Your Personal Information. We may from time-to-time transfer or merge Your information collected off-line to Our online databases or store off-line information in an electronic format.

2.4 CHANGE, CORRECTION, DELETION OF PERSONAL INFORMATION

We generally rely on Personal Information provided by You to ensure it is current, complete and accurate. If Your Personal Information provided to Us when You had registered Yourself in Our Platform changes or was incorrectly captured, You must update it as soon as possible. You can review and update Your Personal Information through the “Edit” option in Our Platform where available, or contact us at the correspondence address given in “Contact Details” clause for any change or correction.

If You wish to cancel or delete Your account and/or request that We no longer use Your information and your End Customer’s information to provide You Services, You can request to delete your Account as per Our Terms of Use by emailing us from your registered email address at assist@markey.ai. We will comply with your request within 30 days of receipt of such a request after due verification. However, We may retain Your information in full or in part, in our archives, subject to Our Terms of Use and this Policy, for only as long as is required for fulfillment of our legal obligations, to maintain the integrity and auditability of our business financials, and such limited purposes only.

2.5 EMAIL NOTIFICATIONS AND OPT – OUT

We maintain a strict “no-spam” policy. Unless You requested otherwise in Your account settings at the time of Your initial registration or specifically opt out as provided herein, by accepting the Terms of Use and this Policy, You expressly agree that We may use Your information to contact You by email in order to deliver You information that is relevant to Your use of the Platform such as administrative notices, product/service enhancements or “newsletters”, or that, in some cases, is targeted to Your interests, such as information about Service/functionalities offerings that We believe You may be interested in learning more about. In the event of an intellectual property claim, we may transfer Your contact details with the claimant for contacting You to resolve the infringement claim directly with You. You may choose to stop receiving non-essential email communications from Us by following the “unsubscribe” instructions included in such communications. If a third-party vendor provides such newsletters, You may unsubscribe in accordance with the instructions provided by such third party. If You are having problems unsubscribing, please email to us at assist@markey.ai and we will unsubscribe you from any non-essential communications within seven (7) business days after due verification. Please note that We may not be able to process any unsubscribe requests submitted as direct replies to any promotional email or newsletter other than the email address mentioned above.

2.6 CONFIDENTIALITY OF YOUR LOGIN ID AND PASSWORD

You are responsible for maintaining the security of Your login ID and Password and must not provide these credentials to any third party. If You believe that they have been stolen or been made known to others, You must contact Us immediately at assist@markey.ai. We are not responsible if someone else accesses Your account through the login credential they have obtained from You or through a violation by You of this Policy or Our Terms of Use. If You have any security related concern, please contact Us at assist@markey.ai. We will work closely with You to ensure a rapid and personal response to Your concerns.

2.7 LINKS TO THIRD PARTY WEBSITES

The Platform may include links to other websites, mobile applications, or services (“Third Party Sites”), whose privacy practices may differ from those set forth herein. Such links are not an endorsement by Us of those third-party Sites and/or the products or services they offer. If You visit Third Party Sites or submit Information to any of those Third-Party Sites, Your visit and Information is governed by their privacy policy. We encourage You to carefully read the privacy policy of any Third-Party Site You visit, as it may differ substantially from that of this Policy. We make no representations or warranties with respect to, nor are We responsible for the privacy policies of, any Third-Party Sites. If You decide to click on any such links or access any Third- Party Sites appearing on the Platform, You do so at Your own risk.

3. FOR OUR VISITORS/ USERS/ CLIENTS/ SUBSCRIBERS AND OUR CLIENT’S END CUSTOMERS

3.1 WITH WHOM DO WE SHARE YOUR INFORMATION?

When We disclose the Personal Information for a business purpose, We enter into a contract that describes the purpose and requires the recipient to keep both confidential and Personal Information and not use it for any purpose except performing the contract.
We want You to understand when and with whom We may share the information We collect for business purposes. Your information is shared with others who have a legitimate purpose for processing or accessing it in the following ways:

3.1.1. Legal Reasons

We may disclose any of the information We collect to respond to summons, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, safety, and security of Us, the Platform, Our affiliates, Users, or the public. We may also share any of the information We collect to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable laws.

3.1.2. Sale, Merger, or Other Business Transfer

We may share all of the information We collect in connection with a substantial corporate transaction, such as the sale of a Platform, a merger, consolidation, asset sales, or in the unlikely event of bankruptcy.

3.1.3. Service Providers, Business Partners

We share the categories of Personal Information listed above with service providers and business partners (including those located outside Your country) to help Us perform business operations and for business purposes, including research, payment processing and transaction fulfillment, database maintenance, administering contests and special offers, technology services, deliveries, sending communications, advertising, analytics, measurement, data storage and hosting, disaster recovery, search engine optimization, marketing, and data processing. These service providers and business partners may include:

• Advertising, marketing, and analytics vendors, who may receive the information You choose to provide, the information We obtain from other sources, and the information We collect automatically but would not receive Your payment information or message data.
• Payment processors and transaction fulfillment providers, who may receive the information You choose to provide, the information We obtain from other sources, and the information We collect automatically but who do not receive Your message data.
• Cloud providers, who may receive the information You choose to provide, the information We obtain from other sources, and the information We collect automatically.
• Research providers, who may receive the information You choose to provide, the information We obtain from other sources, and the information We collect automatically but would not receive Your payment information or message data.
• Customer and technical support providers, who may receive the information You choose to provide, the information We obtain from other sources, and the information We collect automatically.

3.1.4. Third Parties

We may share aggregated usage information and may otherwise disclose non-Personal Information that We collect to third parties. However, absent Your prior consent, We will share Your Personal Information with third parties only in the ways that are described in this Policy, including as set forth below.

• We may use third parties to outsource one or more aspects of Our business and/or Platform operations (such as email or customer service functions, data processing, web analytics, maintenance, online advertising, and security execution and clearing services), in which case, We may provide Your Personal Information to such third parties in connection with the performance of such activities. Such third parties will only use Your Personal Information to the extent necessary to perform their functions and will be contractually bound to process Your Personal Information only on Our behalf and in compliance with Our requests.
• We will also share Your information with any member, subsidiary, parent or affiliate of Our corporate group, to assist in the improvement and optimization of the Platform, in order to prevent illegal uses, increase subscriber numbers, development, engineering and analysis of information or for Our internal business purposes.
• In the unlikely event of Our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, We may not be able to control how Your Personal Information is treated, transferred, or used.

3.2 WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

Our legal basis for collecting, using, and sharing the Personal Information described above will depend on the Personal Information concerned and the context in which We collect it. However, We will normally collect and/or process Your Personal Information pursuant to one or more of the following legal bases:

• The processing is in Our legitimate interests which do not override Your data protection interests or fundamental rights and freedoms.
• The processing is necessary to perform a contract with You.
• The processing is necessary to comply with Our legal or contractual obligations.
• We may also seek Your consent to process or retain Your Personal Information in certain, limited circumstances that We clearly identify to You.
• In some limited cases, We may need the Personal Information to protect Your vital interests or those of another person; for example, We may need to share Your Personal Information with third parties for security reasons (when We believe in good faith that disclosure is necessary to protect Our rights, protect Your or others’ safety, to investigate fraud, or respond to a related government request).

If We ask You to provide Personal Information to comply with a legal requirement or to perform a contract with You, We will make this clear at the relevant time and let You know whether the provision of Your Personal Information is mandatory or not (as well as the possible consequences if You do not provide it). Similarly, if We collect and use Your Personal Information in reliance on Our legitimate interests (or those of a third party) that are not listed above, We will make clear to You at the relevant time what those legitimate interests are. If You have questions about or need further information concerning the legal basis on which We collect and use Your Personal Information, please contact Us using the contact details provided in the “Contact Details” clause below.

3.3 EUROPEAN UNION – RESIDENT SPECIFIC RIGHTS UNDER GDPR

If You are a resident of EU, European data protection laws give you certain rights regarding your personal information.
You may ask us to take the following actions in relation to the personal information that we hold –

Access: To provide the personal information we hold for you
Rectify: To rectify the incorrect personal information we are holding for you
Delete: To erase the personal information.
Transfer: Send a machine-readable copy of your personal information to you or a third party of your choice
Restrict: To restrict the processing of your personal information
Opt-out: To stop receiving direct marketing communications. You may continue to receive Service-related and other non-marketing emails.

If you are Our Visitor/ User/ Client/ Subscriber: For Our Users/ Visitors/ Clients/ Subscribers we are the controller of your personal information for purposes of European data protection legislation. You can exercise any of the above-mentioned rights by submitting these requests to Us by email to assist@markey.ai . We may require some information to authenticate your request. We may reject your request as applicable under law in which case we will inform you of the legal basis for rejecting your request. We shall endeavor to respond to Your Request and inform You on the actions taken, within one (1) month from Your Request or within a reasonable timeframe in accordance with GDPR. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact our data privacy officer at the address given in the ‘Contact Details’ clause.

If you are Our Client’s End Customer: For Our Client’s End Customers, we process their personal data on behalf of Our Clients and act only as a Data Processor on behalf of Our Client who is the Data Controller. Any requests relating to European Users’ exercise of their rights of access, rectification, erasure, or restriction under the European General Data Protection Regulation (“GDPR”) must be provided to Us by Our Client. Our Client can notify Us of these requests by contacting us via the correspondence address given in ‘Contact Details’ clause or by any other request mechanism agreed mutually, and we shall comply within a reasonable timeframe in accordance with GDPR.

3.4 INDIA – RESIDENT SPECIFIC RIGHTS UNDER SPDI

3.4.1. In certain circumstances, You have the right to access the Personal Information that We hold about You and to correct, update, or request deletion of Your Personal Information. Prior to the fulfillment of Your request concerning Your Personal Information, We will ask You to verify Your identity before We can act upon Your request. You have the following rights:

• The right to request proper rectification, removal, or restriction of Your Personal Information;
• The right to require free of charge (1) confirmation of whether We process Your Personal Information and (2) access to a copy of the Personal Information retained;
• The right to take legal actions in relation to any breach of Your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.
• The right not to be subject to any automatic individual decisions which produces legal effects on You or similarly significantly affects You;
• Where the processing of Your Personal Information is based on Your consent, the right to withdraw Your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;
• Where processing of Your Personal Information is either based on Your consent or necessary for the performance of a contract with You and processing is carried out by automated means, the right to receive the Personal Information concerning You in a structured, commonly used, and machine-readable format or to have Your Personal Information transmitted directly to another company, where technically feasible (data portability);

3.4.2. As far as We process Your Personal Information on the basis of Our legitimate interests, You can object to processing at any time. You can find a detailed description of Our processing activities and the legal basis in the clauses above. If You object to such processing, We ask You to state the grounds of Your objection in order for Us to examine the processing of Your Personal Information and decide whether to adjust the processing accordingly.

3.5 TRANSFER AND INTERNATIONAL TRANSFER

We or Our appointed service providers shall collect, use, process, store and disclose Your Personal Information outside Your home countries, to provide Our Services. Such outside countries may have data protection and privacy laws that may be different from the laws of Your home country. We only transfer Personal Information to another country in accordance with the Applicable Laws, provided there are legally adequate protections in place for the Personal Information.
Further, transfer of Your Personal Information also include: a) In the event that We undergo reorganization are sold to, or merged with a third party, or sell all or substantially all of Our assets, any Personal Information We hold about You may be transferred to that re-organized entity or third party in compliance with applicable law; b) In the unlikely event of Our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, We may not be able to control how Your Personal Information is treated, transferred, or used.
In certain situations, We may be required to disclose Your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We strive to keep Our processing activities with respect to Your Personal Information as limited as possible.

For EU’s Data Subjects:
For Your Personal Information transferred from the EU, to Us in other countries, and for onward transfers of Your Personal Information to Our appointed services providers, We and Our appointed service providers will protect Your Personal Information when it is transferred from the EU, to other countries by:

• Processing Your Personal Information in a territory which the EU authorities (or other relevant governmental authority) has determined provides an adequate level of protection for Personal Information; or
• Implementing appropriate safeguards to protect Your Personal Information, including through the use of standard contractual clauses or another lawful transfer mechanism approved by the EU authorities (or other relevant governmental authority).

For other international transfers of Your Personal Information from the EU, We shall implement such measures as are necessary to ensure that appropriate safeguards are provided to Your transferred Personal Information, as agreed with You.

3.6 PROTECTION OF PERSONAL DATA/ INFORMATION

• We follow generally accepted standards to protect the Personal Information submitted to Us, both during transmission and once We receive it. Since no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, We cannot guarantee its absolute security. If You have any questions about security on Our Platform, You can contact Us at assist@markey.ai
• We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of Your online session and to protect Our online accounts and systems from unauthorized access.
• When You register for the Services, We require a password from You for Your privacy. We transmit information such as Your login credentials for Platform or account credentials securely.
• Our servers are in secure cloud facilities maintained by reputed infrastructure providers like Amazon Web Services (AWS) where access requires multiple levels of authentication, and security procedures.
• Our databases are protected from general employee access both physically and logically. We encrypt Your Service password. All backup drives and tapes also are encrypted.
• We enforce physical access controls to Our buildings and employees are not permitted to access any Personal Information of Our Clients or their End Customers from an insecure machine. We permit only authorized employees who are trained in the proper handling of customer information, to have access to aforesaid Personal Information.

3.7 CHILDREN’S PERSONAL INFORMATION

If We learn that We have collected the Personal Information (defined below) from a User who is under the age of 18 that was not provided under the supervision and consent of the minor’s parents or guardians, We will promptly delete such information. If You believe that We have collected Personal Information from someone under the age of 18, please contact Us at assist@markey.ai.

3.8 CHANGES TO POLICY

We may update our Privacy Policy from time to time. When We update the Policy, We will notify You by updating the “Last Updated” date at the top of this Policy and posting the updated Policy here, and we may also send you an email or a notice by any other means available under law. We recommend that You review the Policy regularly to stay informed of Our privacy practices. 

If you do not agree with any changes to this Policy, please email us or write to us at the correspondence address given in the ‘Contact Details’ clause below and discontinue any further access and use of our Site and Platform immediately. Should you chose to not accept the revised Policy even after discussing your concerns with us, you can ask for termination or deletion of your Account with us, and if you have an active paid subscription with us, you will be eligible for refund of pro-rated subscription fee for the balance period remaining in your subscription as per Our Terms of Use and Master Service Agreement. 

3.9 CONTACT DETAILS

In case of any complaints, or concerns with regards to the use, processing and disclosure of Personal Information provided by You; any enquiries or feedback on Our personal data protection policies and procedures; and/or any breach of this Policy or any applicable law should immediately be informed to us through any of the following channels. We will endeavor to respond to any verifiable requests received by Us within a reasonable time frame as per applicable regulations, with expediency. This is without prejudice to Your right to launch a claim with Your data protection authority or follow the dispute process set forth in the Terms of Use.
Attn: DATA PRIVACY & SECURITY OFFICER
Email: assist@markey.ai
Correspondence Address: GALE Creative Agency Pvt Ltd, #3/1, Ground Floor, JP Techno Park, Millers Rd, Vasanth Nagar, Bengaluru 560052, Karnataka, India