INTRODUCTION

• This privacy policy is applicable to all the users of this website, platform, or application for the information or data provided by them to us via this website, platform, or application collectively called the (“Online Platform”) owned by Smart Family Solutions Private Limited (hereinafter referred to as “we”, “us”, “our”, “Company”, “SmartFRP” or “SMSPL”) respects the privacy of our end users (hereinafter referred to as “you”, “your”, “User”, “Customer”).
• This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Online Platform.
• Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.
• We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.
• You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

1. COLLECTION AND USE OF PERSONAL INFORMATION

We may collect information about you in a variety of ways. The information we may collect on the Online Platform includes:

1. i. Registration Information:

   • 1. Personally identifiable information, such as your name, Postal address, email address, mobile number, and demographic information, such as your age/date of birth, gender, country of birth and country of residence, that you voluntarily give to us when you register with the Online Platform.
   • 2. When you choose to participate in various activities related to the Online Platform like providing feedback, contacting us via various mediums such as but not limited to email, Facebook, X and Instagram
   • 3. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Online Platform. We may also use personal information for internal purposes such as auditing, data analysis and research to improve Smart Family Solutions Private Limited's products, services and customer communications.
2. ii. Non-Personal Data:

   Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

3. iii. User Data

   Our application software is designed to ensure that none of the user data except the Registration Information as mentioned elsewhere is accessible or visible to anyone other than the user via authorized access. The application software is encrypted with Industry standard algorithm. Our Online Platform do not have access to any user data.

4. v. Cookies and Other Technologies

   Our Online Platform uses cookies (very small files that are sent by the website to customer’s computer or other access device) which it can access when customers visit its site in future. These cookies enable the customers to browse the Online Platform and use its features. We use these cookies to measure and analyze how the customers use the Online Platform. This allows us to continuously improve the Online Platform and the customer’s experience. When browsing, the Online Platform will remember preferences customer’s make (for example customer’s user name, language or location). This makes their browsing experience simpler, easier and more personal. These cookies are used to deliver relevant adverts. In addition, they limit the number of times customers see an advert as well as helping it measure the effectiveness of the advert campaigns. By using Online Platform customer agree that it can place these types of cookies on customer’s device and access them when they visit the site in the future. If customers want to delete any cookies that are already on their computer, please refer to the help and support area on the internet browser for instructions on how to locate the file or directory that stores cookies.

5. vi. Contact form

   You agree to receive news, offers, and other promotional material from Smart Family Solutions Private Limited, including your email, phone number and name to the contact information you are submitting. You consent to Smart Family Solutions Private Limited, its affiliates, and service providers processing your personal data for these purposes and as described in the Privacy Policy. You understand that you can withdraw the consent at any time.

2. USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Online Platform to:

• Assist law enforcement agencies, if required and as per applicable law.
• Compile anonymous statistical data and analysis for use internally or with third parties.
• Create and manage your account.
• Process your application to use our services and to provide you with the requested services.
• Comply with our obligations arising from any contracts entered into between you and us and to provide with the information, products and services that you requested from us.
• Help protect your information and prevent unauthorized access to it.
• Deal with any queries, complaints or problems reported by you.
• Email you regarding your account, subscription, license information, order or billing.
• Fulfil and manage purchases, orders, payments, and other transactions related to the Online Platform.
• Generate a personal profile about you to make future visits to the Online Platform more personalized.
• Increase the efficiency and operation of the Online Platform.
• Monitor and analyse usage and trends to improve your experience with the Online Platform.
• Notify you of updates to the Online Platform.
• Offer new products, services, and/or recommendations to you.
• Perform other business activities as needed.
• Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
• Process payments and refunds.
• Request feedback and contact you about your use of the Online Platform.
• Resolve disputes and troubleshoot problems.
• Respond to product and customer service requests.
• Send you a newsletter.
• Solicit support for the Online Platform.

3. DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

1. By Law or to Protect Rights

   If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

2. Third-Party Service Providers

   We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
   Marketing Communications: With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
   Our appointed auditors, accountants, lawyers and other professional advisers (e.g. compliance consultants), to the extent that they require access to the information in order to advise us;

3. Security

   The security of your personal information is important to us. Smart Family Solutions Private Limited takes precautions, including administrative, technical, procedural and physical measures, to safeguard your personal registration information against loss, theft and misuse, as well as against unauthorized access, disclosure, alteration and destruction. We follow industry standards and best practices for the security and safety of your data.
   We are legally bound by the (Indian) Information Technology Act, 2000 and rules specified thereunder, and shall comply with all its provisions. Under Section 43A of the (Indian) Information Technology Act, 2000, we must maintain reasonable safety measures and establish security procedures to safeguard your data and information.

   Privacy Practices

   1. We will never rent or sell your information or data to anyone. We never use or transfer your data for serving ads, including retargeting, personalized, or interest-based advertising;
   2. We will never provide any part of your information to anyone unless explicitly agreed by you.

   Cloud Infrastructure:

   1. SmartFRP is hosted on a Virtual Private Cloud on DigitalOcean which provides a secure and scalable technology platform to ensure we can provide you services securely and reliably.
   2. Our infrastructure is launched in compliance with the DigitalOcean Well Architected Framework and from the security perspective incorporating practices from the DigitalOcean Trust Resources.
   3. We use HTTPS protocol for our website and mobile applications (hereinafter referred to as “Platform”).
   4. All communication between the Platform and our servers are protected via 256bit encrypted HTTPS protocol. This prevents MITM (Man in the Middle) attacks on our platform and connection between us and our user is fully secure.
   5. We have strict network segmentation and isolation of environments and services in place.

   Host Security:

   1. We use industry leading solutions around anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, application control, application and audit log aggregation, and automated patching.
   2. All our servers are launched using the Center for Internet Security Benchmarks for Linux Server.

   Data Security:

   1. We take data security seriously. No one except you can access your OTP or password. To protect your data, please protect your handset from unauthorized usage. We do not undertake any liability for any unauthorized use of Your account.
   2. In case there is a data security issue or if you think that your data is compromised, please change your password immediately and inform us at the contact details mentioned below.
   3. Our employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every User’s personal information or sensitive personal data and information.
   4. All user data and internal stored data is protected by encryption at rest and sensitive data by application level encryption.
   5. We employ separation of environments and segregation of duties and have strict role-based access control on a documented, authorized & need-to-use basis.
   6. We use key management services to limit access to data even to the data team.
   7. We use data replication for data resiliency & disaster recovery, snapshotting for data durability and backup/restore testing for data reliability.
   8. We only use anonymized and aggregated data for internal analytics and business intelligence purposes.

   Incident and Change Management:

   1. We have deployed mature processes around Change Management which enables us to release thoroughly tested features for you both reliably and securely enabling you to enjoy the SmartFRP experience with maximum assurance and security.
   2. We have a very aggressive stance on Incident Management on both Systems downtime and Security and Network Operations Center and an Information Security Management System in place which quickly reacts, remediates or escalates any Incidents arising out of planned or unplanned changes.
   3. Vulnerability Assessment and Penetration Testing
   4. We have an in-house network security team which uses industry leading products to conduct manual and automated VA/PT activities
   5. We employ both static application security testing and dynamic application security testing which is incorporated into our continuous integration / continuous deployment pipeline
   6. We will leverage CERT-IN certified auditors to do periodic external testing and audits.

   Security assessment:

   1. We undergo security assessment at regular intervals and request certifications from the Cloud Service Providers to demonstrate the data security.
   2. Here is the link that display the level of security by our Cloud Service Provider (Digital Ocean) https://www.digitalocean.com/trust/certification-reports. Our Online Platform is hosted in DigitalOcean’s Bengaluru server

1. DATA RETENTION PERIOD

   We retain user's data as per the requirement of regulations and laws and do not retain your data for longer than mandated

2. MODIFICATION

   Online Platform reserves the right to amend this Privacy Policy at any time. The policies, as and how modified, shall be updated on the Online Platform and the same shall be notified on the Online Platform. We encourage you to review this Privacy Policy whenever you visit our Online Platform to understand how your personal information is used.

3. LEGAL DISCLAIMER

   Online Platform reserves the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process.

4. UNSUBSCRIBE

   The Online Platform provides the user the opportunity to stop receiving communications from Smart Family Solutions Private Limited. In order to do the same, you shall be required to send an email or click on “Unsubscribe” facility provided.

5. CONTACT FOR ANY QUERY

   In case, you have any questions about this Privacy Policy, or this Online Platform, or your dealings with this Online Platform, you may contact a representative of Smart Family Solutions Private Limited by emailing us - contact@smartfrp.com