PRIVACY POLICY

Last updated on 31 August 2021

We, Margo Networks Private Limited (hereinafter referred to as "we", "us" "our", "SugarBox"), value the trust placed in use by our Users ("You" / "Your" / "Yourself") and therefore, we follow the highest standards of privacy guidelines to protect the information shared by You with us.

This document is an electronic record, generated by a computer system and does not require any physical or digital signatures. This Privacy Policy shall be construed to be provided in compliance with the Information Technology Act 2000 and the rules framed thereunder (as amended from time to time) ("IT Act"). The words and expressions used in this Privacy Policy not defined herein will have the meaning assigned to them under the IT Act. It shall be assumed that you have read, understood and unconditionally accepted this Privacy Policy. The Terms of Use along with this Privacy Policy govern all use of Application and collectively constitutes a binding and enforceable agreement between you and us.

1.   SugarBox Terms of Privacy Policy

This Privacy Policy (Privacy Policy) describes how and when SugarBox collects, processes, uses and shares your information when you use SugarBox, including our mobile applications and websites (the "Services" or the "Platform"). SugarBox receives your information through our mobile applications, websites, email notifications, messages and other interactions with our Platform. By accessing and/or using the Platform, you consent and authorize us to the collection, transfer, processing, storage, disclosure and other uses of your information as described in this Privacy Policy. If you do not agree with any or all of the following terms of the Privacy Policy, please Do Not Use and/or access the Platform.

2.   Personal Data Collection and Use

When you use the Platform, we collect several different types of information for various purposes to provide the Platform services and improve the Platform. By visiting/accessing the Application and/or using the services, you agree to provide us with information as detailed below, and you are consenting us to use the information in accordance with this Privacy Policy.

2.1 Types of Data Collected:

The types of data gathered, collected, stored, processed, shared and deleted by us are:

  1. Personal Data: While accessing Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). 'Personally Identifiable' Information may include name, address, email id, password, phone number, social media information, etc.

  2. General Information: The general data we collect may include SDK/API/JS code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent device identifier, Android ad master identifier, network card (MAC) address, and international mobile device identification code (IMEI) the equipment model, the terminal manufacturer, the terminal device operating system version, the session start / stop time, the location, the language, the time zone and the network state (WiFi and so on)

  3. Log Data: The servers automatically record information ("Log Data") created by your use of the Services. Log Data may include information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive Log Data when you interact with our Services, for example, when you visit our websites, sign into our Services, view videos hosted by SugarBox, or interact with our email notifications. SugarBox uses Log Data to provide our Services and to measure, customize, and improve them. If not already done earlier, we will either delete Log Data or remove any common account identifiers, such as your username, full IP address, or email address, after 18 months or such other period as required by us.

  4. Telemetry Data: Telemetry Data shall mean all information and data that the Platform generates in connection with your usage, including but not limited to, network policy, log and configuration information; threat intelligence data, URLs/Websites metadata or net flow data; origin and nature of malware; the types of software or Websites installed on a network/device or an endpoint; information about the devices connected to a network; information generated by sensors, devices and machinery; information related to the usage, origin of use, traffic patterns or behavior of the users of a network or Platform; and information relating to the existence of cookies, web beacons, and other similar Websites.

  5. Tracking Cookies Data: We use cookies and similar tracking technologies to track the activity on Platform and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. The tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse Platform. Most Internet browsers automatically accept cookies. If you do not want cookies from SugarBox or other websites, you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, if you do not accept cookies, you may not be able to use some portions of the Platform. Examples of Cookies we use:

    1. Session Cookies: We use Session Cookies to operate Application and record your sessions of usage of the Platform.

    2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings and may enable them for subsequent use.

    3. Security Cookies: We use Security Cookies for security purposes.

    4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests, if enabled by us.

  6. Other Non-Personal Identification Information: We do not collect the "Personal Information" which can identify you or another person. We may collect non-personal identification information about Users whenever they interact with our apps. Non-personal identification information may include the type of your phone, apps and other technical information about Users means of connection to our apps, such as the versions of phone model and other similar information.

2.2 Use of Data:

We use the collected data for various purposes:

  1. Verifying your identity, access, privileges assigned and relationship with us for using the Platform.

  2. to provide access to Channel Content and maintain the Platform.

  3. to provide personalized Channel Content and recommendations on the basis of your interests and needs.

  4. For the purposes of our internal record keeping.

  5. Support to law enforcement agencies or in connection with an investigation on matters related to public safety or for compliance with law.

  6. SugarBox may (and you authorize SugarBox to) disclose your name, street address, city, state, pin/zip code, country, phone number, email, social media account(s) and company name to intellectual property right's owners, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity.

  7. to notify you about changes to Platform.

  8. to allow you to participate in interactive features of Platform when you choose to do so.

  9. to provide customer support.

  10. to gather analysis or valuable information so that we can improve Platform.

  11. to monitor the usage of Application.

  12. to detect, prevent and address technical issues on the Platform.

  13. to fulfil any other purpose for which you provide such information.

  14. to carry out our obligations and enforce our rights arising from the Terms of Use and this Privacy Policy, including for billing and collection for Platform and services under it, if any.

  15. to provide you with notices about your Platform account, including suspension, resumption, expiration, email-instructions, etc.

  16. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about including by email, or through pop-up or push notifications unless you have opted not to receive such information. In order to provide with a personalized advertisement experience to you, third parties, including Facebook, may collect or receive information from our app and other apps and use that information to improve services and targeted ads.

  17. in any other way we may describe when you provide the information.

  18. for any other purpose with your consent.

You shall be responsible for the accuracy and quality of your data.

Your Personal Data will be kept confidential as required under applicable laws. We will strive to keep your Personal Data confidential and will place reasonable security controls to protect it.

Further, with respect to Non-Personal Information automatically collected and stored in files, we shall use this information to understand and analyze trends, to administer Platform, to learn about user behaviour on the Platform. As Non-Personal Information does not personally identify you, we may use and disclose Non-Personal Information at our discretion.

3.   Third-Party Services

SugarBox uses a variety of third-party services to help provide our Services, including to host our various blogs and wikis and to help us understand the use of our Services. These third-party service providers may use cookies and other technologies to collect information about your use of our Services and other websites and services, including your IP address, device ID, pages viewed, and links clicked.

4.   Sensitive Personal Data and Information

SugarBox will never ask you and you must never provide Sensitive Personal Data or Information to SugarBox or to any person/entity representing SugarBox. Any disclosure of Sensitive Personal Data or Information shall be at your sole risk and without any liability to SugarBox (including its directors, key managerial personnel, officers and employees). You understand, acknowledge and agree that SugarBox or any other person acting on behalf of SugarBox shall not in any manner be responsible for the authenticity of the Personal Information or Sensitive Personal Data or Information provided by you to SugarBox.

You must note that any information that is freely available or accessible in public domain shall not be regarded as Personal Information or Sensitive Personal Data or Information for the purposes of this Privacy Policy and SugarBox shall not be obliged to take any measures to protect the same since the same is freely available in the public domain. Please further note that identity theft and the practice currently known as "phishing" are of great concern to SugarBox. We do not and will not, at any time, request your credit card information/debit card information/financial pin numbers and passwords.

5.   Information Sharing and Disclosure
To improve our products and provide you with better service, We also share Personal Data with vendors or agents working on our behalf for the purposes described in this Privacy Policy. For example, companies we've hired to provide data analytical services may need collect and access to Personal Data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements.

  1. Your Consent: SugarBox may share or disclose your information at your direction, such as when you choose to publicly post a video or update your profile information.

  2. Service Providers: SugarBox may engage third party companies and individuals (service providers) to facilitate to perform functions and provide services to us in India and abroad. We may share your Personal Information with such service providers subject to confidentiality obligations consistent with this Privacy Policy, and on the condition that the third parties use your Personal Data only on our behalf and pursuant to our instructions.

  3. Law and Harm: SugarBox may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect SugarBox"s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party's, including a government's, request to disclose your information.

  4. Business Transfers: If SugarBox is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new entity. By providing your information to us, you consent to any transfer and processing in accordance with this Privacy Policy.

  5. International Transfers: If SugarBox needs to host/ store its data which includes the Users data as available with SugarBox to severs falling out of Users jurisdiction, SugarBox will take all reasonable efforts to ensure that transfer and storage of such data to servers located outside the Users jurisdiction are bound by duty of confidentiality.

  6. Non-Private or Non-Personal Information: SugarBox may share or disclose your non-private, aggregated or otherwise non-personal information, such as your public user profile information, public posts, the people you follow or that follow you, or the number of users who clicked on a particular link (even if only one did).

6.   Legal Basis for Personal Data Processing
SugarBox processes Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data includes processing that is:

  1. necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use our Service);

  2. necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);

  3. necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services);

  4. and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Services.

7.   Retention of Data
SugarBox will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Once the purposes are achieved, all Personal Data is deleted in a safe and secure mode.
We will also retain Telemetry Data for internal analysis purposes. Telemetry Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Application or we are legally obligated to retain this data for longer time periods. Nothing set out herein shall apply to the anonymized, aggregated datasets generated by your data provided through the Application or any reports, or other visualization created using such datasets.

8.   Third Party Websites / Apps
SugarBox Platform contains links to other websites/applications owned and operated by third parties which are not under the control of SugarBox ("Third-Party Websites/Apps"). Any Third-Party Websites/App you visit by a link from our Platform is solely the responsibility of owners of such Third-Party Websites/Apps. The content of, including materials and information contained on, any Third-Party Websites/Apps to which you link from our Platform is solely the responsibility of the owner and provider of such Third-Party Websites/Apps. Any transactions that you enter into with a third party listed in this Platform or linked from our Platform are solely between you and owner/provider of such Third-Party Websites/Apps. SugarBox is and shall not be responsible for any such Third-Party Websites/Apps, any products or services sold or provided by such Third Party Websites/Apps, nor the organizations publishing those Third Party Websites/Apps, and hereby disclaim any responsibility and liability for the same. The inclusion of any links does not constitute or imply an endorsement or recommendation by us of the Third-Party Websites/Apps and the services and products offered therein, of the quality of any product or service, advice, information or other materials displayed, purchased, or obtained by you as a result of an advertisement or any other information or offer in or in connection with the Third-Party Websites/Apps. SugarBox shall not be liable, accountable or responsible for your Personal Information and/or Sensitive Personal Data or Information being used or misused by such Third-Party Websites/Apps. Note that access and usage of any Third-Party Websites/Apps is entirely at your own risk. SugarBox shall not be a party to any transaction between you and a Third-Party Websites/Apps. Your use of a Third-Party Websites/Apps is subject to the terms and conditions and privacy policy of such Third-Party Websites/Apps in addition to our Terms of Use/User Agreement and Privacy Policy.

9.   Limited Liability
Security of your Personal Information is a paramount importance for Us, and we want the same to be as safe as possible while using and accessing our Services. To this extent, we have implemented reasonable technical safeguards to protect your Personal Information. Whilst we will take all the reasonable steps to protect your Personal Information against potential risks and exposures, there is no absolute security in the online/ internet sphere as known to public. Therefore, you must not disclose any information on our Platform that is Sensitive Personal Data or Information. You understand that the transmission of information over the internet is not completely secure and there are risks associated with it. Although we strive to protect your personal information, we cannot guarantee the security of the same while it is being transmitted to our Platform and any transmission is at your own risk.

10.   Support
If you do not consent to any part of the terms of this Privacy Policy or wish to withdraw consent to process Your Personal Data then you may stop using the Services and ask us to remove your Personal Data/ Information from our records by writing at governance@sugarboxnetworks.com.
In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Nikhil Dhamija
Margo Networks Pvt Ltd.
701-713, 7th Floor, A Block,
Dynasty Business Park, Near J B Nagar Metro Station,
Andheri Kurla Road, Andheri East, Mumbai - 400065
Telephone: 022 4613 2100
Email: compliance@sugarboxnetworks.com

11.   Changes to this Policy
We may revise this Privacy Policy from time to time without any further notification (except for material changes). The most current version of the policy will govern our use of your Personal Information and will always be updated and available at  https://sugarboxnetworks.com/privacy-policy.html. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.