The Cleared for Use App and Services have been developed and made available by Nidhi-Dutt Content Private
Limited with a registered office at 102, Sunbeam, near Infant Jesus School, Ahimsa Marg, Malad (West) Mumbai –
400064, India (“our”, “us”, “we” or “Company”). To operate and successfully provide the Cleared for Use
(“CFU”) App and Services, we collect various data and information from our Users. This Cleared for Use Privacy
Policy (“Policy”) addresses the manner in which this data and information is collected, retained, shared, and
clearedforuse.com/termsofuse . Capitalized terms used but
not defined herein will have the same
meaning as ascribed to them in the Terms.
If a User does not agree with our data storage and handling practices, he/she/they must stop using the Cleared for Use App and Services immediately.
Background and applicability
1.1. We allow organizations that avail of our Services (“Customer”) to on-board multiple Administrators onto the Cleared for Use Admin Portal and to create Administrator Accounts for each designated Administrator (“Administrator Account”). Through these Administrator Accounts, the Administrator can manage a dedicated workspace for each Project he/she/they are assigned. Through the Administrator(s), the Customer controls the manner in which the Cleared for Use App and Services are used. Specifically, each Project created on the Admin Portal includes, but is not limited to, the following features and procedural and operational capacity: the addition, removal and management of Field Team Members assigned to any Project, granting Project-assigned Field Team Members access to Project details and materials, which include templatised Forms, Project briefs and notes, other documentation, and Subject Data, plus any and all information, statements, and consent contained in such documents and materials. The Customer, its Administrator(s) and on-boarded Field Team Members shall be known as “Authorized Users”. The Administrator(s) and Field Team Members onboarded by the Administrator shall be referred to as “Personnel”.
1.2. For the purpose of availing our Services, the Customer provides us with certain data about itself (“Customer Data”). Customer Data means and includes the contact details of the Customer, i.e., the full name, phone number(s), photograph (if provided) and email address(es) of the Customer, where the Customer is a natural person. If the Customer is a legal person, then the full name, phone number(s), email address(es) and photograph (if provided) of the person(s) who is (are) representing the Customer is recorded. Such person(s) represent and warrant to us that they have the legal right and authority to enter into this binding contract on behalf of the Customer.
1.3. While adding Personnel, the Customer and the Personnel provide us with certain data about the Personnel (“Personnel Data”). This includes the full names, phone numbers, photograph (if provided) and email addresses of the Personnel. Personnel Data and Customer Data shall collectively be referred to as “Authorized User Data”.
1.4. Each and every Customer represents and warrants to us that:
(a) They have informed the Personnel of our data collection, storage, retention and processing practices.
(b) They have the valid right and authority to disclose the Personnel Data to us for the purposes provided in this Policy.
(c) They have informed the Personnel and Data Subjects that any audiovisual content or information gathered, filmed and recorded in any way and stored via the Cleared for Use App and Services shall be stored with us in perpetuity and they shall not be entitled to withdraw their consent to such content being stored on the Cleared for Use App or Services at any time. Provided, however, we shall not publicly disclose or make available such content or information, unless compelled by law.
(d) They will not use or cause to be used the Cleared for Use App and Services for any illegal purpose(s), including collecting of any information or data from minors or persons who are not competent to contract or provide information to the Customer.
1.5. This Policy does not apply to any third-party applications or software integrated with the Cleared for Use App and Services and the data collection and storage practices of such third-party services are governed by their own privacy policies and statements.
Information we collect and receive
2.1. Customer and Personnel Data: We collect and retain Customer Data and any further information provided to us by the Customer. We collect and retain the Personnel Data and any further information provided to us by the Personnel or Customer relating to the Personnel.
2.2. Usage Information: Authorized Users provide us certain data over the course of their usage of the Cleared for Use App and Services. This data includes:
(a) Feedback and Other Data: We collect and record: (a) any calls an Authorized User makes to our call centers or customer service personnel; (b) feedback or comments provided to us via the Cleared for Use App and Services, including any crash reports and lag reports generated by the Authorized User.
(b) Services Metadata: When an Authorized User interacts with the Cleared for Use App and Services, metadata is generated that provides additional context about the way the Authorized User uses the App. This includes the access dates and times, features accessed, pages viewed, system activity, operating systems, and browser used to access the Cleared for Use App and Services.
(c) Device Geolocation: We collect location data from mobile devices when enabled. We collect this data even while the Cleared for Use App is running in the background of a mobile device.
(d) Log Data: As with most websites and technology services delivered over the Internet, our servers automatically collect information when someone accesses or uses the Cleared for Use App and Services and records this use in log files. Log data includes the Internet Protocol (IP) address, the address of the web page visited before using the Cleared for Use App or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences, and cookie data.
(e) Gallery and Image Access: We access the media gallery on your mobile device, including, without limitation, the images, videos, and audio files, as well as the storage space on your mobile phone.
Use of Information Collected
We use the data collected in accordance with Section 2 above for the following reasons and purposes:
3.1. To Enable the Cleared for Use Platform: We use the data collected to provide, maintain and improve our Services. This includes using data to:
(a) Create, update and enable Administrator Accounts and Field Team Member Accounts.
(b) Provide access to the Cleared for Use App and Services.
(c) Enable filling, storage, retention, and sharing of Forms and digital signatures.
(d) Perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems.
3.2. To Enable Customer Support: We use information provided by Authorized Users to provide customer support, including to resolve concerns raised by the Authorized Users via and about the use of the Cleared for Use App and Services, and training our customer services/technical support executives. We also use the data so collected to communicate with the Authorized Users.
3.3. For Automated Decisions: As the Cleared for Use App grows, we may keep adding more automated features to it, including but not limited to, features such as automated responses to Customers and Personnel.
3.4. For Research and Development: We may use the data so collected for research and product development to improve the User Interface (UI)/ User Experience (UX) – all of which will ultimately improve how our users experience the Cleared for Use App and Services.
3.5. For User Communication: We use the data to enable the Customer and Personnel to speak with, and reach out to, each other.
3.6. For Legal Compliance and Requirements: We may use the data we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
3.7. Data Subject Consents: We collect and store the full name, age, mobile phone number, and email address of Data Subjects (“Data Subject Information”). We collect this Data Subject Information so that we can:
(a) Authenticate the Data Subject.
(b) Communicate with the Data Subject, i.e., send them relevant links and notifications about the Forms, as the case may be from time to time.
(c) Allow the Data Subject to view the Form(s). If the Data Subject is unable to access and view their executed Form(s), they may reach out to the Grievance Officer identified in Section 10 (Grievance Officer). In such an event, the Grievance Officer may ask for further information and documents which the Grievance Officer feels are necessary to verify the identity and credentials of the Data Subject.
Sharing and Disclosure of Data
4.1. We do not share any personal information or the data we collect with any third-parties, unless necessary. We may, however, share or disclose the Authorized User Data so collected with third-parties under certain circumstances which include, but are not limited to:
(a) Customer’s instructions: We shall share and disclose Customer Data and Personnel Data if required by the Customer. This includes sharing of such Authorized User Data with any of the data subjects being interviewed (“Data Subjects”) by the Customer or its Personnel. We also share executed Forms.
(b) Sharing with third-parties: We may share the Authorized User Data with our service providers, and subcontractors (whether in or outside India) to provide our Services.
(c) Sharing with related entities: We may share the Authorized User Data with our affiliates, parent companies, subsidiaries, and other related companies (whether in or outside India), for the purposes provided under this Policy.
(d) Sharing for marketing purposes: We may share the Authorized User Data with third-parties for research, marketing, or advertising purposes. This includes sharing your feedback, ratings, and screen names for purely promotion and marketing purposes.
(e) Change in control: We may share the Authorized User Data pursuant to a change of corporate control such as a restructuring, merger or sale of our assets. At such time, we may have to disclose our databases and the information we have stored over the course of our operations.
(f) Sharing with law enforcement when needed: We may share Authorized User Data with any governmental authority or enforcement officer who requests or requires any information and where we think disclosure is required or appropriate in order to comply with orders from a statutory authority and applicable law.
(g) To enforce our rights, prevent fraud, and for safety: To protect and defend our rights, property, employees or third-parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
User Rights Regarding the Data
5.1. It is important for us that our Users remain in control of their data. Users shall have the following rights under the Policy, and all rights shall be exercised by writing at email@example.com. Do keep in mind that certain rights may not be exercisable if you are Personnel, without adversely affecting your use of the Cleared for Use App and Services. Additionally, if you are Personnel exercising any of the rights contained herein, we may need to notify the Customer of the same to ensure that the Projects remain operational. The rights are as follows:
(a) Right to information: Authorized Users can request information about the purpose for which the Personal Data is collected, and how it is stored and processed.
(b) Right to rectification: In the event that any personal data provided by Authorized Users is inaccurate, then they shall have the right to provide the accurate personal data for rectifying such data immediately.
(c) Right to the restriction of personal data processing: Authorized Users have the right to object to the usage of the personal data for advertising and/or market research.
(d) Right to erasure: Authorized Users have the right to demand the deletion of their personal data after the purpose for which it was collected ceases to apply.
(e) Right to opt-out: Authorized Users have the right to opt out of receiving promotional emails and/or push notifications on their computer and/or mobile devices from us by writing to firstname.lastname@example.org.
(f) Right to lodge a complaint: Without prejudice to any other administrative or judicial remedy, Authorized Users have the right to lodge a complaint with the relevant supervisory authority against the use of any personal data. Authorized Users may approach the Grievance Officer to lodge such complaints as well.
(g) Right to information: Authorized Users have the right to receive a copy of all of their personal data collected. They further have the right to know the identity of the third-parties with whom their personal data is transmitted or shared.
We shall retain the data provided to us and collected by us to facilitate the smooth use of the Cleared for Use App and Services. We may retain the data pertaining to the Authorized Users for as long as necessary for the purposes described in this Policy or required under the applicable law, whichever period is longer. This includes keeping the Authorized User Data after the user account for the Personnel or the Customer has been deactivated for such period of time for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.
Standard Model Clauses and Important Data Practices
Our internal data usage policy and regulations are provided here: clearedforuse.com/termsofuse. This Policy lays down the principles of data processing and control that we expect all of our Customers and processors to comply with for the adequacy and security requirements for our Customers.
Data Security Practice
8.1. We have implemented the following data security measures to ensure that the data collected by us stays secure:
(a) Prevent unauthorized persons from gaining access to data processing systems in which personal data is processed by placing access controls on such systems.
(b) Prevent physical access to the servers or hard drives wherein personal data has been stored with measures such as locks, alarm systems, fences, cameras, etc.
(c) Ensuring that personal data and the Cleared for Use App and Services are protected against undesired destruction or loss by having secured internet connections (e.g.: SSL/TLS technology), secured internal networks with firewalls, and anti-virus software on the processing/storage systems.
(d) Encryption of devices or databases containing personal data (e.g. full disk encryption of laptops and mobile devices).
Dealing with Breaches
For the purpose of this Policy, a ‘breach’ of personal data shall include a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
In case a breach of personal data comes to our notice, the Grievance Officer shall promptly identify such breach and record all necessary information pertaining to such breach in a notification report (“Report”). Such Report shall contain a description, in clear and plain language, of the nature of the personal data breach, details of the personal data involved, an approximate number of persons concerned or affected by such breach, and the measures which have been undertaken by us for the mitigation and remedying of such breach. In the event that a Customer or Personnel notify us of a breach, the Grievance Officer will initiate an investigation into the incident, look specifically into the source of the leak of personal data, and will inform the concerned Authorized User of the progress and the outcome of the complaint at reasonable periods of time.
Authorized Users can contact the Grievance Officer confidentially by email to enquire about the treatment of their information and any grievance regarding our handling of their personal information. The details of our Grievance Officer can be found below:
Full Name: Grievance Officer
From time to time, when we consider it necessary to do so, we may send Authorized Users announcements/updates related to the Cleared for Use App and/or Services. This includes, but is not limited to, when we temporarily suspend the Cleared for Use App and/or Services for maintenance, security, privacy, or administration-related communications). We shall send these announcements/updates via SMS/push notifications/email/instant messaging, or any other method and platform as shall be deemed fit by us.
The Cleared for Use App and Services may contain links to third-party websites and online services. We are not responsible for the privacy or security practices of any third-party (including third-parties that we are permitted to disclose an individual’s personal data to in accordance with this Policy or any applicable laws). This Policy does not describe the privacy practices of those third-party websites or services. Please review the privacy policies of those websites or services before providing personal information to them.
Updates to This Policy
We may update this Policy from time to time. Use of the Cleared for Use App and Services after an update constitutes consent to the updated notice to the extent permitted by applicable law. Please take the time to periodically review this Policy for the latest information on our privacy practices.