We, the representatives, administrators, directors, employees, officers, agents and their successors and assignees at IT Collaborative Inc., Canada, the owners and operators of the Mobile Application MyEClone (collectively “we” “our” “the App” of “the company”), are committed to protect the privacy of our business Partners, Clients, end users  (“you”, “user”, “visitor” or “client”)  who have access to any of the data resources monitored by our software (“the “ Software ”). We are a Document Management App, that allows you to digitize, preserve and manage paper and digital documents such as identities, financial, medical, health, legal and work-related records. We encourage you to read this Software Privacy Policy (“ Privacy Policy ”) carefully and use it to make informed decisions. By using our Software, you agree to the terms of this Privacy Policy, and your continued use of the Software constitutes your ongoing agreement to it.

1. WHAT DOES THIS PRIVACY POLICY COVER?

This privacy policy covers our treatment of Personally Identifiable Information ('Personal Information') that we gather when you are accessing or using our App, service and products. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. 

2. LEGAL BASIS OF THIS PRIVACY POLICY 

This Privacy Policy is an electronic record in the form of an Electronic Contract formed in compliance with the various provisions of the Personal Information Protection and Electronic Documents Act (PIPEDA),  California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR) & other provincial Privacy Laws in Canada. This Privacy Policy does not require any physical, electronic or digital signature.  This privacy policy is a legally binding document between You and MYECLONE. The terms of this Privacy Policy will be effective upon your acceptance of the same (directly or indirectly in electronic form, by clicking on or by the use of the App or by any other means), and will govern the relationship between You and MyEClone for your use of the App. 

3. ACCESS TO THE APP        

Your access to, browsing, review and use of the App is subject to these policies, terms and conditions and all applicable laws. By accessing and using the App, you accept the Privacy Policy & Terms of Service without limitation or qualification. If you do not agree to the terms and conditions, do not use the App.  If, at any time, any part of the Privacy Policy/Terms of Serviceis no longer acceptable to you, immediately terminate the use of the App. 

4. ELIGIBILITY 

The services of the App are available only to persons of 18 years and above or the age or majority in your jurisdiction. Persons who are below this age are not eligible for the services provided for this App and hence shall not register as a user or transact on this App. However, children between the ages of 13-18 can still access our services with parental consent and supervision.  

5. WHAT DATA IS BEING COLLECTED?

• We collect and process the user specific Personal Data that you directly and voluntarily provide through our App. Your personal information is collected directly from you when you sign up or create an account on our App.
• We also collect Metadata which is a generic information that our products use to create a generic user profile and for any third party marketing purposes
• Payment Information. When submitting a payment through our Service, we ask for your information such as the name, address, phone number, and government identification number. We may also ask you to provide information about the person for whom you are submitting a payment. As part of the payment process, or to process a refund or charge-back, we and/or our partners may need the payer’s credit card information, financial account information, such as bank account numbers, names, and routing codes.
• We also get information about your IP addresses, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier.  If you use our Services from a mobile device, that device will send us data about your location.  Most devices allow you to prevent location data from being sent to us and we honour your settings.
• You can choose not to provide us with certain information, but then you may not be able to take advantage of some of our services/features/products and will not be able to receive the product or service. 

6. PERMISSIONS WE ASK TO AN END USER

Our App will ask the following permissions to an end user:

• Location Permission : Which helps us to know where a user’s location is, which helps us to serve users’ localized contents and to power some features like Invite friends etc.
• Camera Permission : Which helps users to take photos and videos from our App and post/share it directly in our App.
• Gallery Permission : Which help us to show the users photos and videos and other files in our App and user can share/post these files in our App

7. HOW DO WE USE YOUR PERSONAL INFORMATION? 

 We use the information described for the purposes specified at the time of collection or hereafter in this Policy:

• To operate, improve, understand and personalize our services based on our legitimate interests in operating and improving our services in a way that benefits us and our users
• To keep your account secure and protect our Services (including to verify the identities of creators and prevent fraud and abuse)
• To verify accounts and activities, to monitor suspicious or fraudulent activities and to identify violations of policy.
• To create and administer your account, contact you, and customize your experience on our App (for example, to show you projects that we think may interest you based on your previous use)
• To process your payment transaction and keep you informed about the status of your payment
• To comply with and enforce applicable legal requirements, industry standards and our policies
• To prevent potentially illegal or prohibited activities and enforce our Terms of Service
• To respond to your inquiries, resolve disputes and provide support
• To communicate with you for Service-related purposes, such as sending payment reminders
• Contact you about service announcements, updates or offers
• To track and analyse use of the Services so that we can improve how our App is performing and provide users with the best experience possible
• To customize your experience with us and to tailor our marketing activities to fit your needs and interests to better serve you and respond to your needs
• To provide support and assistance for the services
• To personalise and improve your experience on our digital platforms
• To personalize App content and communications based on your preferences
• To maintain transaction and other business record for legal, administrative and audit purpose
• To meet legal, insurance and processing requirement
• To respond to user inquiries or questions
• To comply with our legal or contractual obligations
• To protect against or deter fraudulent, misuse, illegal or harmful actions
• To communicate with you about your account or our relationship: we may contact you about changes to the App or about service updates 

8. INFORMATION WE SHARE

We share your data with the third-party, who works on our behalf or provides us with services related     to the purposes described in this Privacy Policy or our Terms of Service. We do not share your personal information with companies, organizations, or individuals outside of MyEClone except in the following cases:

• To process your payment, we may share some of your information with the Designated Entity, for whom we serve as the payment agent.
• Staff augmentation and contract personnel
• Service provider or agent who perform services on our behalf
• Any third party as part of business restructuring or reorganization 
• We also share Personal Data when necessary, to complete a transaction   initiated or authorized by you.
• We may share your information with service providers and vendors who assist us with the delivery of our Service. 

We also share personal data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraudulent activity.
• We do share user information to any third parties for the Analytics purposes, such as Google Analytics (https://firebase.google.com/docs/analytics), Apple Analytics (https://www.apple.com/legal/privacy/data/en/device-analytics/). However, we share non-personally identifiable information only to those analytics services.
• We also share Personal Data with third parties when you give us consent to do so. Furthermore, if we choose to sell assets, user information is typically one of the transferred business assets to the third parties. If we go out of business or enter bankruptcy, user information would be transferred to such third parties along with the assets, based on our legitimate business interest of being able to provide you with continued services. You acknowledge that in the event of such transfers, the acquirer of us may use your Personal Information as set forth in this Policy. We do not rent, sell, or share personal information about you with other people or non-affiliated companies for their direct marketing purposes, unless we have your permission.
• We also use the OTP feature of the Twilio application (https://www.twilio.com/legal/privacy). When a user requests  an OTP, we send that number in the international format to Twilio and from Twilio an SMS/Automated voice call to an end user to send OTP to a user’s mobile. 

9. THIRD PARTY COLLECTING DATA AND LINK

Our App and the advertisements we serve on behalf of users may contain links to other sites whose information practices may be different from ours. In addition, there may be links to other sites provided within the body of advertisements on other websites. We do not have control over the information that is submitted to, or collected by, these third parties. You should consult the privacy policy of these other sites to learn how your privacy is protected 

10. STORAGE & TRANSFER OF YOUR PERSONAL DATA

The personal information we collect will be stored and/or processed on the Google Firebase servers located in the USA. The United States has its own laws governing data protection and government access to information. The rules that protect your personal information under United States law may be different than in your home country. If you choose to use the Services, you need to agree to our Terms of Service, which set out the contract between MyEClone and its users.  

11. IS THERE ANY USAGE OF COOKIES OR WEB BEACONS AND COLLECTION OF ANONYMISED DATA?

• When you visit our Service or open our emails, we and our third-party service providers may collect certain information by automated means, such as cookies, web beacons and web server logs. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Service. We may link this data to your profile. You may be able to change browser settings to block and delete cookies when you access the Service through a web browser. However, if you do that, some of the app or services features may not work properly.
• Our advertising partners may collect your information in order to show you ads that may interest you. Where required under applicable law, we will request your consent to such collection and use of your information. You may opt out of receiving personalized advertisements from us and our advertising partners. 

12. RETENTION OF DATA

We retain your personal information for as long as you have an open account with us or as otherwise necessary to provide the services to you and improve the services for all users generally. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.  

13. CHILDREN’S PRIVACY

Our Services are not designed for use by individuals under the age of 18 (or 16 for children located in Europe). If you are under the age of 18 (or 16 for children located in Europe), please do not use the Services and/or submit any information through the Services. If you have reason to believe that a child under the age of 18 (or 16 for children located in Europe) has provided personal information to MyEClone through the Services, please contact us at MyECloneapp@Gmail.com, and we will delete that information from our databases to the extent required by law. 

14. LEGAL DISCLOSURES

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably to:

• investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies
• enforce our agreements with you 
• investigate and defend ourselves against any third-party claims or allegations 
• protect the security or integrity of our service (such as by sharing with companies facing similar threats); or
• exercise or protect the rights and safety of our company, our Members, personnel, or others.  We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency.  We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand 

15. RIGHTS YOU HAVE

• Right to information: You have the right to get informed about how your personal data is being processed, when your personal data is being collected and information about the processing of your personal data 
• Right to access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. If you request such access, we will provide you with all the information as required by law on the purposes of the processing, categories of data processed, categories of recipients, data retention with us, etc.
• Right to be forgotten/deletion/Erase: You have every right to restrict or prevent us from continuing disclosure of data processed about you till date; If you would like to delete your personal data in our records you have the right to do so by informing us at our email MyECloneapp@Gmail.com.
• Right to correction: You have right to correct or update your personal data
• Withdrawal of consent: If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Please note, however, that if you exercise this right, your services may be terminated, and any of your user account and associated data may be deleted. If you want to exercise any of the above rights, please feel free to write to us at MyECloneapp@Gmail.com We will reach you out within 48 business hours and guide you how you can exercise any of these rights timely and accurately. 

16. SAFEGUARDING YOUR PERSONAL DATA AND SECURITY

We take all reasonable precautions to keep your personal data secure and require any third parties that handle or process your personal data for us to do the same. Access to your personal data is restricted to prevent unauthorised access, modification or misuse and is only permitted among our business partners, employees and agents on a need-to-know basis. We value the security of your Information, including but not limited to the Information collected via the App or service. We have taken appropriate technical and organisational measures to protect the Information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. However, to the extent that the Internet is not completely secure, we cannot guarantee that any of your personal information stored or sent to us will be completely safe. We encourage you to use caution when using the internet to access our App or any services. 

17. OPT-OUT

We provide all users, prior to the collection of     information including Sensitive Personal Data or information, an option to opt out of receiving non-essential (promotional, marketing-related) communications from the App or on behalf of any of the other partners after setting up an account.  You can unregister/unsubscribe from the lists/newsletters/and promotional mails by pressing the unsubscribe button provided on the promotional communications if sent to you.        

Further, the user can edit the given data at any point of time during and after the registration process. 

We store data for as long as it’s necessary to provide services to you and others, including those described above. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide our services.  You also have the option of deleting your account that you created on the App at any point of time. When you delete your account, we may also delete the information that you have provided to us. 

Whenever you deactivate your account at our App, we will stop collecting data from you. Once a user has deleted the account with us, all data of the user will be deleted from our side. 

18. LINKS TO OTHER APPS  

Our App may include links to other Apps. When you access another App, we strongly suggest you review the privacy policy or notices on those external Apps. MyEClone is not responsible for the content or privacy practices of external Apps. 

19. UPDATES TO THE PRIVACY POLICY

We will notify all users of any material changes to this policy through a notice on our App or by other means and provide you an opportunity to review before you choose to continue using our Products.  We update the “Last Updated” date at the top of this policy, which reflects the effective date of the policy. By accessing or using the Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. 

20. COMMITMENT TO GDPR COMPLIANCE OF THE EUROPEAN UNION (EU) 

We are committed to the principles inherent in the General Data Protection Regulation (GDPR) and particularly to the concepts of Privacy by Design & Privacy by Default, the Right to be Forgotten, Consent & Risk Based Approach.  In addition, we aim to ensure:

• Transparency with regard to the use of data
• That any processing is lawful, fair, transparent and necessary for a specific purpose
• That data is accurate, kept up to date, and removed when no longer necessary
• That data is kept safely and securely 

21. CALIFORNIA PRIVACY STATEMENT

This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS (“California Privacy Statement”) supplements the information contained in the Privacy Policy of MyEClone and applies solely to users who reside in the state of California and who create an account with our App. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  Any terms defined in the CCPA have the same meaning when used in this California Privacy Statement.

22. CALIFORNIA PRIVACY RIGHTS

I f you are a California resident you have the right to request information from MyEClone regarding the manner in which we share certain categories of your personal information with third parties, for the third parties direct marketing purposes. California law provides that you have the right to submit a request to MyEClone at its designated Email ID and receive the following information:

• WE DO NOT SELL YOUR PERSONAL INFORMATION
• The categories of information MyEClone disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and
• The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed. 

You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. You may make such a request by sending an email to us at  MyECloneapp@Gmail.com.  

23. WHOM CAN YOU APPROACH IN CASE OF GRIEVANCES

If you wish to contact us for any reason regarding our Privacy Policy, kindly email it to us at the following address:The name and contact details of Grievance Officer are provided below:    

Name: Babita Mehta        

Address: 589 Beachgrass Crt., Mississauga, ON, Canada    

Email ID: ITCollaborative@gmail.com  

For issues such as Copyright, Trademark, Privacy and for all other purposes:  MyECloneapp@Gmail.com.