The Company respects Your privacy and is committed to reasonably protect it in all respects. The information about You as collected by the Company is: (a) information supplied by Users and (b) information automatically tracked while navigation (c) information collected from any other source (collectively referred to as “Information”).
- 1. INFORMATION RECEIVED, COLLECTED AND STORED BY THE COMPANY
- A. INFORMATION SUPPLIED BY USERS
- i. Registration or comment data:
When You register and/or leave comments on Lumbini Times, We may ask that You provide basic contact information such as your name, sex, age, address, pin code, contact number, occupation, interests, website and email address etc. When You register using Your accounts on third party platforms like Facebook, Twitter, Gmail etc.(as facilitated by the Company on Lumbini Times from time to time), We shall retrieve Information from such account(s) to continue to interact with You and to continue providing the Services seamlessly.
- ii. Subscription, Voluntary contributions or paid service data:
When You choose any subscription, voluntary contribution or paid Service, We or Our payment gateway provider may collect your purchase, address or billing information, including Your credit card number and expiration date etc. However, when You order using an in-app purchase option, this activity is handled solely by such platform providers. The subscriptions, voluntary contributions or paid Services may be on auto renewal mode unless cancelled. If at any point You do not wish to auto-renew your subscription, You may cancel Your contribution or subscription before the end of the contribution/subscription term.
- iii. Voluntary information:
We may collect additional Information at other times, including but not limited to, when You provide feedback, change Your content or email preferences, respond to a survey, or communicate with Us.
- B. INFORMATION AUTOMATICALLY COLLECTED/ TRACKED WHILE NAVIGATION
- i. Cookies:
To improve the responsiveness of the Lumbini Times for You, We may use “cookies”, or similar electronic tools to collect Information to assign each User a unique, random number as a User Identification (User ID) to understand Your individual interests using the identified computer. Unless You voluntarily identify Yourself (through registration, for example), We will have no way of knowing who You are, even if we assign a cookie to Your computer. The only personal Information a cookie can contain is Information You supply. Our advertisers may also assign their own cookies to Your browser (if You click on their ads), a process that We do not control.
- ii. Cookies – Opting out:
If a User opts out using the Ads Settings, the unique ‘DoubleClick cookie ID’ on the User’s browser is overwritten with the phrase “OPT OUT”. Because there is no longer a unique cookie ID, the opt-out cookie can’t be associated with a particular browser.
- iii. Log File Information:
We automatically collect limited Information about Your computer’s connection to the Internet, mobile number, including Your IP address, when you visit Lumbini Times. Your IP address is a number that lets computers attached to the Internet know where to send you data — such as the pages you view. We automatically receive and log Information from Your browser, including Your IP address, your computer’s name, your operating system, browser type and version, CPU speed, and connection speed. We may also collect log Information from Your device, including Your location, IP address, Your device’s name, device’s serial number or unique identification number (e.g. UDiD on Your iOS device) etc.
- iv. Clear GIFs:
We may use “clear GIFs” (Web Beacons) to track the online usage patterns of Our Users in an anonymous manner, without personally identifying the User. We may also use clear GIFs in HTML-based emails sent to Our Users to track which emails are opened by recipients. We use this Information to inter-alia deliver Our web pages to You upon request, to tailor Lumbini Times and Services provided thereunder to the interests of Our Users, to measure traffic within Lumbini Times to improve the quality, functionality and interactivity of Lumbini Times and let advertisers know the geographic locations from where Our Users come.
- v. Information from other Sources:
- vi. Demographic and purchase Information:
We may reference other sources of demographic and other Information in order to provide You with more targeted communications and promotions. We use Google Analytics, among others, to track the User behavior on Lumbini Times. Google Analytics specifically has been enabled to support display advertising towards helping Us gain understanding of Our users’ demographics and interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that You may have shared with Us. You can opt-out of Google Analytics for ‘Display Advertising’ and customize ‘Google Display Network ads’ using the ‘Ads Settings’ options provided by Google.
- 2. LINKS TO THIRD PARTY SITES / AD-SERVERS
- ii. We use third-party advertising companies to serve advertisements when You visit Lumbini Times. These companies may use Information (not including Your name, address, email address or telephone number and/or other personally identifiable Information) about Your visits to Lumbini Times and other websites or applications, in order to provide advertisements about goods and services of interest to You.
- 3. INFORMATION USE BY THE COMPANY
- i. The Information as supplied by the Users enables Us to improve the Services and provide You the most User-friendly experience. All required Information is Service dependent and the Company may use the above said User Information to, maintain, protect, and improve the Services (including advertising on the Lumbini Times) and for developing new services. Pursuant to Your confirmation to access the Services, We may also use Your email address or other personally identifiable Information to send commercial or marketing messages without Your consent [with an option to subscribe / unsubscribe (where feasible)]. We may, however, use Your email address without further consent for non-marketing or administrative purposes (such as notifying You of major changes, for customer service purposes, billing, etc.).
- ii. Any personally identifiable Information provided by You will not be considered as sensitive if it is freely available and/ or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like facebook, twitter etc.
- iv. In case You choose to decline to submit personally identifiable Information on Lumbini Times, We may not be able to provide certain services on Lumbini Times to You. We will make reasonable efforts to notify You of the same at the time of opening Your account. In any case, We will not be liable and or responsible for the denial of any Services to You for Your failure to provide the necessary personal Information.
- v. When You register with Lumbini Times, We contact You from time to time about updating of Your personal Information to provide You with such features that We believe may benefit / interest You.
- 4. INFORMATION SHARING
- i. The Company may share Your Information with a third party without obtaining Your prior consent in the following limited circumstances:
- c. The Company may present Information to its advertisers – to help them understand Our audience and confirm the value of advertising on Lumbini Times – however it is usually in the form of aggregated statistics on traffic to various pages within Lumbini Times without identifying any specific User;
- d. The Company may share Your Information regarding Your activities on Lumbini Times with third party social websites to populate Your social wall that is visible to other people however You will have an option to set Your privacy settings, where You can decide what You would like to share or not to share with others.
- 5. ACCESSING AND UPDATING PERSONAL INFORMATION
When You use the Lumbini Times (or any of its sub sites), We make good faith efforts to provide to You, as and when requested by You, with access to Your personal Information and shall further ensure that any personal Information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal Information or sensitive personal data or information to be retained by law or for legitimate business purposes. Before processing requests by a User pertaining to access, correction or removal of any Information related to such User, we may ask each User to identify themselves initially and thereafter, the Information requested to be accessed, corrected or removed . We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning Information residing on backup tapes), or for which access is not otherwise required. In any case, where We provide Information access and correction, We perform this Service free of charge, except if doing so would require a disproportionate effort. Because of the way We maintain certain Services, after You delete Your Information, residual copies may take a period of time before they are deleted from Our active servers and may remain in Our backup systems.
- 6. INFORMATION SECURITY
- i. We take appropriate security measures to protect Lumbini Times and Your Information against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of Our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where We store personal data. All Information gathered on Lumbini Times is securely stored within the Company controlled database on a best-effort basis. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, We cannot guarantee the security of our database, nor can we guarantee that Information You supply will not be intercepted while being transmitted to Us over the Internet. Further, You agree and confirm that any Information You include in a posting to the discussion areas on Lumbini Times is available to anyone with Internet access.
- 7. GRIEVANCE REDRESSAL
- i. Any complaints, abuse or concerns with regards to the processing of Information provided by You or breach of these terms shall be immediately informed to the designated Grievance Officer as mentioned below in writing or through email signed with the electronic signature to [email protected].
- ii. We request You to please provide the following Information in your complaint:
- a. Identification of the Information provided by You;
- b. Clear statement as to whether the Information is personal information or sensitive personal information;
- c. Your address, telephone number or e-mail address;
- d. A statement that You have a good-faith belief that the Information has been processed incorrectly or disclosed without authorization or any other grievance, as applicable;
- e. A statement, under penalty of perjury, that the information in the notice is accurate, and that the Information being complained about belongs to You;
- iii. The Company shall not be responsible for any communication, if addressed, to any non-designated person in this regard.
- 8. Governing Law
- 9. General Terms