Last modified: 12thJan 2023
Introduction
ANCORAA RESOLUTIONPVT. LTD (“Company” or “We”) respect your privacy andare committed to protecting it through our compliance with this policy.
This Policytogether with the terms of use and/ or any other document/ information,describes the Company’s policies and procedures on the collection, use anddisclosure of the information provided by the user (“You”)who accesses the website www.ancoraa.com or the RezolutionEngine® platform on the www.ancoraa.com (hereinafter collectivelyreferred to as “Website”) whetherfor service or otherwise. The Company does not use Your information in anymanner except as provided under this Privacy Policy. Anyone who accesses oruses the Website shall be bound by this Policy.
We feel it isimportant to post a privacy statement in accordance with best established practicesand for the knowledge of customers and anyone who visit our website. Theinformation you share with us will be kept private. We also want to stateunequivocally that suitable safeguards have been taken to secure informationconnected to clients and their interactions with us from malicious andfraudulent individuals.
We are extremelyconcerned about the confidentiality and privacy of our users. Our personneltreat the information we have about your accounts with the same care and confidentialitythat we would like our own financial matters handled. This Policy is herebypublished pursuant to existing applicable laws in India. The Policy sets outthe type of information collected from You, including the nature of data orinformation, the purpose, means and modes of usage of such information and howand to whom the Company shall disclose such information. This policy describesthe types of information we may collect from you or that you may provide whenyou visit the website and our practices for collecting, using, maintaining,protecting and disclosing that information.
This policy appliesto the information we collect:
● On this Website.
● In email, text, andother electronic messages between you and this Website.
● Through mobile anddesktop applications you download from this Website or other websites or appstores including but not limited to Apple’s App Store and Google’s Play Storeetc. which provides dedicated non-browser-based interaction between you andthis Website.
● When you interactwith our advertising and applications on third-party websites and services ifthose applications or advertising include links to this policy.
● The information youprovided while signing up on the Rezolution Engine® platform on our websiteand the information you feed in it.
● The information youprovided while signing up on the other such software as a service platformwhich may be added to the Website from time to time.
It does not applyto information collected by:
● Us offline orthrough any other means, including on any other website or email operated byCompany or any third party (including our affiliates and subsidiaries); or
● Any third party,including through any application or content (including advertising) that maylink to or be accessible from or through the Website.
Please read thispolicy carefully to understand our policies and practices regarding yourinformation and how we will treat it. If you do not agree with our policies andpractices, your choice is not to use the Website.
Notice
By accessing orusing this Website, you agree to this privacy policy. This policy may changefrom time to time (see Changes to Our Privacy Policy). Your continueduse of this Website after we make changes is deemed to be acceptance of thosechanges, so please check the policy periodically for updates. You alsoacknowledge that the Company reserves the right to remove, preserve, anddisclose any Information it deems necessary or appropriate to:
· satisfy any applicable law, regulation, legal process orgovernmental request;
· enforce this Policy, including investigation of potentialviolations hereof;
· detect, prevent, or otherwise address fraud, security, ortechnical issues;
· protect the rights, property, or safety of the Company, You,and/or the general public;
· investigate or defend the Company against third-party claimsor allegations.
Information We Collect About You and How WeCollect It
We collect severaltypes of information from and about You through the website, includinginformation:
● By which you may bepersonally identified, such as name, postal address, email address, mobile/telephonenumber, Aadhar No., PAN, CIN, DIN, IP/RP Reg. No., Bar Reg. No. or any suchinformation which help us to identify you so as to provide you an effective andefficient services to you. (“personal information”)
● That is about youbut individually does not identify you, such as financial as well asnon-financial details of any Organization / Individual which may be requiredfor processing the Insolvency Process involving any Corporate Debtor, FinancialCreditor, or Operational Creditor, Personal Guarantor(s) and/or any otherservice which may be provided by us to you including but not limited to the servicesprovided on the Resolution Engine platform on our website. (“non-personalinformation”)
● That may bedirectly or indirectly obtained which pertains to any third party involvementin the matter which would be necessary for providing our services through the RezolutionEngine® or otherwise. Such a third party would include but not limitedto Liquidators, Valuers, Receiver, Insolvency Professionals, Lawyers,Accountants, Financial Institutions, other professionals and clients.
● Which may bebrought on to us by you is of any legal nature or of non-legal nature which canbe used in any legal process or requirement while undergoing through the processof Insolvency, Liquidation, Restructuring, reorganization or the services oflike nature. It may include any document which is required to be filed in acourt of law by us as a service provider / Insolvency Professional.
● About your internetconnection, the equipment you use to access our Website, and usage details.
We collect thisinformation:
● Directly from youwhen you provide it to us while accessing the Resolution Engine platform on thewebsite.
● Automatically asyou navigate through the site. Information collected automatically may includeusage details, IP addresses, and information collected through cookies, webbeacons, and/or other tracking technologies.
● From third parties,for example, google account sign up, signing up using IBBI email ID etc.
Information You Provide to Us
The information wecollect on or through our website may include:
● Information thatyou provide by filling in forms on our website. This includes informationprovided at the time of registering/signing up to use our website or theservices we provide, subscribing to our service, any posting material, orrequesting further services. We may also ask you for information when you enteron the Resolution Engine platform on the website as and when demanded orrequired, and when you report a problem with our website.
● Records and copiesof your correspondence (including email addresses), if you contact us throughthe means and feature of the website.
● All suchinformation which is directly provided by you to us for the services we providewhich may include but not limited to the financial records such as a record of the default recorded with theinformation utility or such other document or evidence of default, the name of the resolution professional proposedto act as an interim resolution professional, copy of invoices, demand notice,copy of loan agreement, deed of guarantee, details of personal guarantors,certification of financial institutions, any resolution plans, MoM of Committeeof Creditors and other sensitive financial information etc.
● Details oftransactions you carry out through our website and of the fulfilment of yourorders. You may be required to provide financial information before placing anorder through our website.
Information We Collect Through Automatic Data CollectionTechnologies
As you navigatethrough and interact with our website, we may use automatic data collectiontechnologies to collect certain information about your equipment, browsingactions, and patterns, including:
● Details of yourvisits to our website, including traffic data, location data, logs, and othercommunication data and the resources that you access and use on the website.
● Information aboutyour computer and internet connection, including your IP address, operatingsystem, and browser type.
We also may usethese technologies to collect information about your online activities overtime and across third-party websites or other online services (behavioraltracking). The information we collect automatically does/may/is onlystatistical data and does not include personal information. It helps us toimprove our website and to deliver a better and more personalized service,including by enabling us to:
● Estimate ouraudience size and usage patterns.
● Store informationabout your preferences, allowing us to customize our website according to yourindividual interests.
● Speed up yoursearches.
● Recognize you whenyou return to our website.
The technologies weuse for this automatic data collection may include:
● Cookies (or browser cookies): A cookie is a smallfile placed on the hard drive of your computer. You may refuse to acceptbrowser cookies by activating the appropriate setting on your browser. However,if you select this setting you may be unable to access certain parts of our Website.Unless you have adjusted your browser setting so that it will refuse cookies,our system will issue cookies when you direct your browser to our website.
● Web Beacons: Pages of our Website and our emails maycontain small electronic files known as web beacons (also referred to as cleargifs, pixel tags, and single-pixel gifs) that permit the Company, for example,to count users who have visited those pages or [opened an email] and for otherrelated website statistics (for example, recording the popularity of certain websitecontent and verifying system and server integrity).
● Flash Cookies: Certain features of our website may uselocal stored objects (or Flash cookies) to collect and store information aboutyour preferences and navigation to, from, and on our website. Flash cookies arenot managed by the same browser settings as are used for browser cookies.
It is pertinent tonote that we do not collect personal information automatically, but we may tiethis information to personal information about you that we collect from othersources or you provide to us.
How We Use/Process Your Information
We use informationthat we collect about you or that you provide to us, including any personalinformation:
● To present our websiteand its contents to you.
● To provide you withinformation, products, or services that you request from us.
● To fulfill anyother purpose for which you provide it.
● To provide you withnotices about your case/resolution details.
● To carry out ourobligations and enforce our rights arising from any contracts entered intobetween you and us, including for billing and collection.
● To notify you aboutchanges to our website or any products or services we offer or provide thoughit.
● For filingdocuments to the court of law for your interest and benefit or under any legalobligation.
● In any other way wemay describe when you provide the information.
● For any otherpurpose with your consent.
Disclosure of Your Information
We may discloseaggregated information about You, and information that does not identify anyindividual without restriction.
We may disclosepersonal information that we collect, or you provide as described in thisprivacy policy:
● To our subsidiariesand affiliates.
● To contractors,service providers, and other third parties we use to support our business andwho are bound by contractual obligations to keep personal informationconfidential and use it only for the purposes for which we disclose it to them.
● To a buyer or othersuccessor in the event of a merger, divestiture, restructuring, reorganization,dissolution, or other sale or transfer of some or all of assets if requiredunder any resolution plan or liquidation process you are part of, whether as agoing concern or not, and whether on order or direction of court of law.
● To third parties toprovide you with more effective and efficient services. Such a third party mayinclude lawyers, accountants, liquidators, valuers or other professionals. Wecontractually require these third parties to keep personal informationconfidential and use it only for the purposes for which we disclose it to them.
● For any otherpurpose disclosed by us when you provide the information.
● With your consent.
● To comply with anycourt order, law, or legal process, including to respond to any government orregulatory request.
● To enforce or applyour terms of use and other agreements, including for billing and collectionpurposes.
● If we believedisclosure is necessary or appropriate to protect the rights, property, orsafety of our customers, or others or ourselves. This includes exchanginginformation with other companies and organizations for the purposes of fraudprotection and credit risk reduction.
Data security and storage
All information yousend to us or collected by us is securely stored/saved. The Company has put inplace appropriate security measures to prevent your personal data from beingaccidentally lost, used or accessed in an unauthorized way, altered ordisclosed. If we have provided you (or you have selected) a password to accessparticular portions of our website/services, you are responsible for keepingsuch password secure. We recommend that you do not share your password withanybody.
Furthermore, werestrict access to your data to employees, agents, contractors, and other thirdparties that have a need-to-know basis. Third parties who process your personalor non-personal information will only do so on our instructions and are boundby confidentiality. We have mechanisms in place to deal with any suspected datasecurity breach, and we will inform you if we are legally compelled to do so.
We will store theinformation in our systems for as long as is necessary to fulfil the reasonsfor which it was collected, including meeting any legal, accounting, orreporting requirements, or as required to comply with any legal obligations towhich we/you are subject to.
Limitation on Liability and Disclaimer
To the maximumextent permitted by law, the Company, its affiliates, licensors, suppliers, orany third parties mentioned on the website shall not be liable for anyincidental, direct, indirect, exemplary, punitive, or consequential damages,lost profits, or damages resulting from lost data or business interruptionresulting from the use of and/or inability to use the website, the Company systems,information, services, or the content, whether based on warranty, contract,tort, or otherwise. To the extent permissible by law, the remedies specified inthese terms of service for you are exclusive and limited to those specificallyindicated herein.
The internet is anopen system, and the Company does not guarantee that data, which the registereduser furnishes will not be intercepted or accessed by others and decrypted. TheCompany or its associates/partners/employees/directors/agents & representativesshall not be liable or responsible, should any confidential or otherinformation provided by you or pertaining to the visitor (including bankaccount information, passwords, credit/debit card details, transaction details)are intercepted and subsequently misused by an unintended recipient.
Rights of User
In respect to yourPersonal Information, you have many options. You have the following rights inparticular:
● receive confirmation that we are processing your PersonalInformation and a copy of the Personal Information we have on file for you;
● request that we update the Personal Information we have onfile for you, or request that we correct Personal Information that you believeis wrong or incomplete;
● request that we deleteor restrict the use of Personal Information we hold about you;
● withdraw consent toour processing/use of your Personal Information (to the extent such processingis solely based on previously obtained consent);
● receive a copy of thePersonal Information concerning you that you have provided to us in astructured, commonly used, and Engine-readable format; and transmit suchPersonal Information to another party (to the extent the processing is based onconsent or a contract); and
● object to ourprocessing/use of your Personal Information.
Grievance andContact
If you want tocontact us about any aspect of this Privacy Policy, including, withoutlimitation and subject to applicable data protection law, if you want toexercise any of your data protection rights or file a complaint or grievance,please contact our Head Office using the information provided below.
If you file acomplaint against the Company for a violation of relevant data protectionrules, the Company will react as quickly as possible to let you know who is incharge of handling your complaint. The Company will examine your complaint and,if necessary, engage with third parties who may have been involved in theprocessing of your personal data. The Company will respond to any complaintswithin the periods prescribed by law. If more research is necessary, it will beconducted, and you will be advised of a suggested solution. This will beverified in writing to you.
If you do not get aresponse from us within the periods allowed by relevant legislation, or if yourcomplaint is not addressed to your satisfaction within that timeframe, you mayfile a complaint with the appropriate data protection authorities. We will examine any complaint and tell you as soon aspossible when a decision has been taken in respect to your complaint.
Note: This PrivacyPolicy is to be interpreted with and not in derogation to the website’s termsand condition.
Contact Details:
For further details, clarifications or objections, you mayreach us at: support@ancoraa.com
Or
By Post:
1412, 14th Floor,Real Tech Park, Sector 30 A, Vashi, Navi Mumbai, Pin-400703.
Registered Address:
1412, 14th Floor, Real Tech Park, Sector 30 A, Vashi, Navi Mumbai 400703.
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