This Researcher privacy policy (“Privacy Policy”) explains (a) how we collect, use, disclose and transfer personal information collected from Researchers and visitors, other than Participants, while accessing or using the Platform (“Researcher Data”); and (b) how Researchers can collect, use, disclose and transfer personal information collected from Participants (“Participant Data”).

Please note that this Privacy Policy does not cover personal information provided by or collected from Participants. Those privacy rights are governed by the Participant Terms and Conditions and Participant Privacy Policy.

The terms ‘information’ or ‘personal information’ as used in this Privacy Policy shall mean and include any personal and sensitive personal information belonging to an individual person (including personal and sensitive information of Participants collected by Researchers), recognised and protected under applicable laws. The information includes but is not limited to, name, contact details including email address, mailing address, street address and/or telephone number, etc. We may collect Researcher Data directly from you, and Researchers may collect Participant Data directly from Participants or through Poocho (as a data processor).

This Privacy Policy does not cover any information collected at any other website, application or offline by Poocho (unless specifically stated).

Under applicable law, Poocho is considered the “data collector” of Researcher Data relating to visitors to our Platform, or of Researchers who are individual persons, and may be considered a “data processor” of Researcher Data collected by the Researchers belonging to individuals / natural persons and lawfully transferred to Poocho, or of Participant Data collected by the Researchers (directly by the Researcher or indirectly through Poocho and/orthe Platform) and lawfully transferred to Poocho. In other words, Poocho is responsible for deciding how to collect, use, share, and disclose Researcher Data relating to visitors to our Platform or of Researchers who are individual persons, and Researchers are responsible for deciding how to collect, use, share, and disclose Researcher Data collected by the Researchers belonging to such individuals / natural persons or of Participant Data collected by the Researchers.

Please review this Privacy Policy carefully. By accessing or using the Platform, you agree to this Privacy Policy. IF YOU DO NOT OR CANNOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM.

PLEASE NOTE: THE APP COULD ALLOW POOCHO TO COLLECT AND USE YOUR DEVICE’S PRECISE LOCATION INFORMATION. If applicable, this includes GPS-based, Wi-Fi-based and cell tower-based location information.

Researcher Data:

How we collect and store Researcher Data depends on how you access and use the Platform. We collect Researcher Data when you provide your personal information directly to us, when you permit third parties to provide information to us, and automatically, such as information collected from your browser or device. You can use certain areas of the Platform without providing any information other than that automatically collected as described below.

The Platform may contain hyperlinks to other websites or locations that we do not control and are operated and controlled by third parties (“Third-Party Websites”) in order to provide the service under these terms. Our Privacy Policy does not apply to these Third-Party Websites and we make no representations regarding the policies or business practices of any such Third-Party Websites. When you link us to a Third-Party Website to use our Platform, we shall use all the data available on such third-party platform, upon integration with that third-party in order to provide you with the services. However, Poocho will not be responsible for the collection, use, disclosure, or deletion of any information or data collected by or processed on behalf of such third parties.

(a) Required Registration Information
Researchers must create an account in order to access the Platform.

(b) Project and Study Information
To build a Study, Researchers must provide certain information for the creation of the Study components, including but not limited to a Study name, overview, specs for each Study part, and screener questions.

(c) Automatically Collected Information
• Usage Information and Analytics
In addition to any information that you choose to submit to us, we and the third-party service providers, which include ad networks and analytics companies including Google Analytics, use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Platform (“Usage Information”). This Usage Information includes the browser that you are using, the URL that referred you to the Platform, all of the areas within the Platform that you visit, and the time of day, among other information. In addition, we collect the IP address or other unique identifier (“Device Identifier”) from a User’s computer or other device used to access the Platform (a “Device”). A Device Identifier is a number that is automatically assigned to a Device used to access the Platform, and our computers identify a Device by its Device Identifier.

• Advertisements on Other Websites
We display advertisements for Poocho on other websites and services. When you click on a Poocho advertisement on these other websites and services, we receive information about the website or service that served the advertisement, and which advertisement you clicked. If you then interact with our Platform, we may combine the information about your activity with our advertisement with the information we subsequently collect and/or you subsequently submit on our Website.

• Email Receipt.
If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns. We collect Usage Information using, from methods including but not limited to, cookies, beacons and embedded scripts (and subsequent technology and methods hereafter developed).

(d) Information Third Parties Provide About You
We may, from time to time, supplement the information we collect about you online with outside records lawfully disclosed to us or collected by us from third parties, including networking and marketing resources, in order to enhance our ability to serve you. We may combine the information we receive from those sources with information we collect through the Platform. In those cases, we will apply this Privacy Policy to any such information received, unless we have disclosed otherwise.

(e) Payment and Tax Information
If you are a Researcher, the Platform may collect payment information, such as credit card information and associated account information (name and contact information of your point of contact). Credit card information is stored by a trusted third-party payment processor. Our payment partner will share your payment information with credit card companies to process actual payments.

Participant Data:
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We may store, use, and process Participant Data collected by Researchers (through the Platform or otherwise) and lawfully transferred to us, for the purpose of enabling the use of our Platform features such as accessing or transcribing Sessions, carrying out Studies, providing details of relevant Participants, and similar or related processing activities. It is clarified that Poocho will not be a data collector in relation to such Participant Data, and will act as a data processor to the limited extent required by the Researcher and consented to by the Participant / data subject. Poocho will not be liable or responsible for collecting any consents or processing any data requests for Participant Data or other personal information transferred to it by the Researcher, other than to the extent of maintaining any features enabled on the Platform for the purpose of collecting consents on behalf of the Researcher.

Participant Data collected by the Researcher (whether through the Platform or otherwise) and processed by Poocho includes, without limitation:
• [Videos and transcriptions of Sessions containing personal information];
• [Responses by Participants to ‘screeners’ and questions provided by Researchers for Studies and/or Sessions, in writing, on video, or by any verbal, audio-visual, or other means];
• [any other information collected by Researchers or otherwise disclosed to Researchers, and lawfully transferred and processed by Poocho].

We may collect, store, transfer, process, or otherwise use information (including Researcher Data):

• to create and maintain your account;
• to provide you with access to the Platform;
• to process transactions or payments;
• to process your registration to the Platform, including verifying your information is active and valid;
• to establish and run Studies;
• to transcribe interviews and/or videos;
• to analyze and synthesize research findings;• to analyze the use of the Platform;
• to enhance or improve the Platform;
• to customize your experience on the Platform, or to provide you with specific content that is most relevant to you;
• to contact you (such as via e-mail) with regard to your use of the Platform and, in our discretion, changes to the Platform and/or the Platform’s policies;
• to send offers and promotional materials related to the Platform and for other Poocho marketing purposes;
• for Poocho’s advertising, marketing, publicity and promotional activities;
• for internal business purposes;
• for other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy;
• with the use of demographic and non-personally identifiable information and to the extent of information collected directly by Poocho (excluding personal information collected by or on behalf of Researchers, such as through Screeners or Studies), for research, statistical analysis and business intelligence purposes with the help of computer science technologies including without limitation, artificial intelligence and machine learning.

Such demographic and non-personally identifiable information collected by Poocho (excluding personal information collected by or on behalf of Researchers, such as through Screeners or Studies) will be in an aggregated or non-personally identifiable form thereby ensuring anonymity.

Finally, we will use or disclose your Personal Information if we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or property, violations of the Platform’s other policies, or as otherwise required by law when responding to subpoenas, court orders and other legal processes.

(a) Sharing Study Information
We share information about Studies with potential Participants.

(b) Sharing with Third Parties Providing Services on Our Behalf
We may use third party vendors to perform certain services on our behalf, such as hosting the Platform, designing and/or operating the Platform’s features, tracking App or website analytics, and collecting mobile sensor data. We may provide these vendors with access to certain of your information to carry out the services they are performing for us. These third party vendors are not permitted to use your information other than for performing services for Poocho.

(c) Sharing for Administrative and Legal Reasons
We may access, use, preserve, transfer and disclose your information or information provided by you, including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, summons, governmental requests or legal process if, in our good faith opinion, such is required or permitted by law, including to meet national security or law enforcement requirements; (ii) to protect and/or defend our agreements with our Users and our policies, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Platform, Poocho or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Such disclosures may be carried out without notice to you.

(d) Sharing for Business Transfer
We reserve the right to disclose and transfer all such information:
(i) to a subsequent owner, co-owner or operator of the Platform or applicable database; or
(ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our equity and/or assets or other corporate change, including, during the course of any due diligence process.

(e) Sharing of User-Generated Content
The Platform may permit Researchers to submit ideas, photographs, videos, writings, pictures, data, questions, comments, suggestions or other feedback in a forum available to the public; this information will become publicly available. Poocho is not responsible for the use or misuse of any such content.

(f) Sharing with Your Consent
We may share your personal information for any other purpose disclosed by us and consented by you at the time you provide the information. For the Researcher Data and Participant Data that you provide to Poocho, you represent and warrant that you have such person’s consent to provide the relevant Personal Information to us.

In situations during which we process personal information on behalf of the Researcher and receive a data request from the relevant data subject (whether for deletion, modification, or otherwise any lawful request in relation to personal information), we may refer the request to the relevant Researcher who is the data collector of such information and cooperate with their handling of the request, subject to any special contractual arrangement with that Researcher.

You may deactivate your account by contacting Poocho and requesting that your account be deactivated. See “Contact Us” below in this Privacy Policy. If you deactivate your account, your account information, and/or your credit card information (as applicable) will generally be deleted within thirty (30) working days. However, we may retain certain information even after you have deactivated your account if retention is reasonably necessary to comply with our legal obligations.

The Platform is not intended for use by children under 13 years of age (or in the EU, children under the age of 16 years of age), and we do not knowingly collect personal information from children under 13 (or in the EU, under the age of 16 years of age) without the direct involvement of the minor’s parents or guardians. If we learn that you have collected or received personal information from a child under 13 (or under the age of majority in their legal jurisdiction) or from a child in the EU under the age of 16 without parental or guardian consent or legally-valid consent or other legal basis, we will take reasonable steps to delete that information.

If you believe that the information submitted by you might have any personal information from or about a child under 13 (or under the age of majority in their legal jurisdiction) or from a child in the EU under the age of 16, please contact us as provided in the “Contact Us” section below. The onus of the information uploaded on the Platform or relating to a Study entry of children concerning this age group shall be on the person providing such information and Poocho shall have no responsibility for the use of the said information, except as specifically set out in this Privacy Policy.

We use and implement physical, technical, and administrative measures to protect your information stored within our databases, and we restrict access to such information to those employees who need access to perform their job functions, such as our customer support personnel and technical staff.

Despite these efforts, please note that we cannot 100% ensure or guarantee the security of your information. Unauthorized entry or use, hardware or software failure, and other factors could compromise the security of your Information. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to the Platform and that any such transmission is at your own risk. Poocho shall not be held responsible in such events and you shall in no manner hold Poocho liable for any of the said failures.

We cannot guarantee the security of any information that is transmitted to or by us over the internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we process will not be disclosed in a manner that is inconsistent with this Privacy Policy as a result of events beyond our reasonable control.

In the event, our service providers and third parties distribute personal information outside the scope of our agreement with other such providers’ or third parties, Poocho cannot be held liable except to the extent required under applicable laws. Further, in case breach of security or actions including without limitation, computer hacking, unauthorized access to computer data and storage device, computer crashes etc., Poocho will not be held responsible for the same.

‍The information we obtain from or about you may be processed and stored in India. We comply with generally accepted industry standard regulations regarding the collection, use, and retention of data under applicable laws. By using the Platform, you consent to the collection, transfer, use, storage and disclosure of your information as described in this Privacy Policy. Sensitive information (“Sensitive Information”) means personal information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.

We will not process sensitive information, without first obtaining necessary consents. As long as we are provided with the relevant consent, the Sensitive Information may only be used and disclosed for purposes relating to the primary purpose for which the Sensitive Information was collected. Sensitive Information may also be used or disclosed if required or authorised by law.

If you wish to be informed about what personal information we hold about you and if you want it to be removed from our systems, please contact us on the details as given below.

‍We reserve the right to change this Privacy Policy at any time. If we make material changes to this Privacy Policy, we would advise you to review such changes carefully. If you agree to the changes, simply continue to access the Platform. If you object to any of the changes and no longer wish to use the Platform, you may deactivate your account. Unless stated otherwise, our current Privacy Policy applies to all information we have about you or your account. Accessing the Platform after a notice of changes has been communicated to you or published on the Platform shall constitute consent to the changed terms or practices.

You should be aware that your browser may have settings for Do Not Track. Because there is no common understanding of how to interpret Do Not Track signals yet, Poocho does not honour Do Not Track signals from browsers.

If you have any questions about (a) access to your information; (b) the collection, use, management or disclosure of your information; or (c) this Privacy Policy, you should contact our grievance redressal officer, Taapsi Ramchandani, by email at support@poocho.co or at A-702 Ashoka Towers, Panch Marg, Versova, Andheri West, Mumbai 400061.