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Colombia Online Privacy Policy

Times Internet Limited, (“TIL”) is a wholly owned subsidiary of Bennett Coleman & Co. Limited and powers / manages the website https://ads.colombiaonline.com/ ,https://www.colombiaonline.com/ and its sub-domains thereof (collectively referred to as “Site”).

TIL respects the privacy of its users and is committed to protect it in all respects. With a view to offer most enriching and holistic internet experience to its users, TIL offers a vast repository of online sites and variety of community services. This privacy policy (the "Privacy Policy") describes how Colombia Ad-Tech ("Colombia Online", "We", “Our” or "Us") collects and uses personal information relating to its users (“Customers”) visiting the Colombia Online website

This Privacy Policy only applies to the personal information of Our Customers from California region under the California Consumer Privacy Act (“CCPA”),

If you have any questions or comments regarding this Privacy Policy or its enforcement, please contact us at colombia@timesinternet.in. Where appropriate we may refer you as Our Customer with respect to any queries raised with us as being the data controller.

Application of this Privacy Policy

Please read this Privacy Policy carefully - By visiting our Site or using/availing Colombia Ad- Tech service (the "Service"), you confirm that you have read about and understand our use and processing of your personal information as set out in this Privacy Policy.

If you are a Customer using the Service, this Privacy Policy is to be read in conjunction with Our Terms of Service. "Terms of Service" as used herein shall refer to Our online terms of use as well as the terms of any master service agreement or other agreement governing use of the Service. Customers agree to be bound by the Terms of Service and to have read and understood this Privacy Policy. Capitalized terms used here and defined in the Terms of Service shall have the meanings set forth in the Terms of Service. Any additional agreements to which Customers agree governing the provision of optional Colombia Ad-Tech features shall take precedence over the terms of this Privacy Policy to the extent of any differences, so please read such order forms or additional agreements carefully.

This Privacy Policy only addresses activities on Our Site and usage of our Services.

Links to third party websites

TIL includes links to other websites. Such sites are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. That policy may differ from ours. If you can't find the privacy policy of any of these sites via a link from the site's homepage, you should contact the site directly for more information.

User Consent

By using the Site, you agree to our terms of collection, storage and use of your personal information which you provide to us in accordance with this policy. In case of any roaming Customer profile or if you are a traveller visiting various countries around the world and avail our services, then we will consider the country of registration as your primary country and the consents obtained at the time of registration will be valid for your processing of personal information.

Collection, Usage and Source of Personal Information

‘Personal Information’ or ‘PII’ is defined as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” such as the individual’s name, postal address, email address, mobile number and any other identifier indicating to that particular person. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information. We or our service providers may collect the below categories of information for the business or commercial purposes.

Categories of personal information We collect Categories of sources Examples of uses
Personal Identifiers Such as name, Company Name, email address, photograph, designation, contact number, date of birth, gender, website, username, employment related information, education related information, Google sign in id -You, if you choose to provide it to Us
  • - Providing the Services
  • - Registration/Sign Up as a Publisher or Advertiser
  • - Contact Us
  • - Report Issue
  • - Providing comments
  • - Advertising Purposes
  • - Providing you with Newsletters
  • - Lead generation campaigns
  • - Prefilled Lead Forms
  • - M360 Sign Up
  • - M360 Report Issue
  • - M360 Newsletter
  • - Managing data (DMP)
Device information and Location identifiersSuch as IP address; unique device ID, UUID, Latitude, Longitude, country code, GAID, IDFA
  • - You, through your device
  • - Third Parties and Service Providers
  • - Providing the Services
  • - Contact Us
  • - Report Issue
  • - Providing Comments
  • - Lead generation campaigns
  • - Managing data (DMP)
  • - M360 Sign Up
  • - Creating User Profile
  • - Prefilled Lead Forms
  • - Advertisements (DFP)
Browsing/navigating data

Cookies

Please refer to our <Cookie Policy> for more details

  • -You, through your device
  • - Providing the services
  • - Marketing and Advertising Purposes.
  • - Analyzing and improving the Services.
  • - Personalizing content
Usage and log data

Such as devices details, interests, page views and interaction with the Site

  • - You, through your usage of our websites
  • - Marketing and Advertising Purposes.
  • - Analyzing and improving the Services.
  • - Personalizing content

Information we collect through third party

The Report Issue functionality on our Site is maintained separately by a third party vendor, Zoho. If you report any issues here, the information which is provided by you through this functionality is stored by Zoho and then passed on to us for issue resolution. We collect and store such information.

Subscription or Paid service data

When you chose any subscription or paid service, Our payment gateway provider may collect your personal information such as address or billing information, including your credit/debit card number and expiration date etc. We may receive email ID, name, mobile number and some financial or transactional information (for e.g., transaction id, etc.) from third party vendors in case of payments, for reconciliation and validation of transactions and also for the purpose of resolutions of complaints (in case of failed transactions and refunds).

Business or Commercial Purpose for Collection of Personal Information

We collect the personal information described above for a variety of business purposes such as-

  • • To perform Our obligations in connection with the Terms of Use which you accept by using the Service and/or to comply with Our contract to provide Services to you or (if you are an employee of a Customer) your employer; or
  • • To run, grow and develop Our business;
  • • To operate Our Site;
  • • To allow Us to identify Customers;
  • • To provide the Service;
  • • To notify Customers of changes or updates to the Service;
  • • To contact you in account recovery and other scenarios (such as breach notifications);
  • • To assist in login and other uses related to Customers’ use of the Service;
  • • To perform systems administration activities;
  • • To track visitor trends;
  • • To enable you to log into and use the Service;
  • • To send marketing emails and newsletters;
  • • For you to report any issue regarding the Services
  • • For contacting Us
  • • For providing you personalized Services
  • • For providing Advertising
  • • For billing and invoicing as per our services consumed
  • • Sending account related emails

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at colombia@timesinternet.in and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide Our Services.

Based on your purchases for availing Our services, payment gateway partners may collect information with respect to your credit/debit card details or other bank account details along with your billing address. We may disclose Customer’s information like name, email, mobile number, etc., to vendors, contractors, or others who assist Colombia in delivering certain services (e.g. wallet payment). This information is stored by our payment gateway partners. For instance, Colombia Online will be using the third party payment gateway partner such as PayU to process and facilitate the payment of your advertising fee to Colombia Online. Please note that Colombia Online does not directly collect any financial information such as credit card or debit card or net banking details from you. Such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. These payment gateways may have their own privacy policies in place, which we recommend you review if you visit any such payment gateways. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to providing them with information about you or entering into any transactions with them.

While transacting with these payment gateways, you may provide your financial information including without limitation your bank account details, credit card account details or your details pertaining to any payment settlement or pre-paid instrument service provider. Your Personal Information, Sensitive Personal Data and financial information will be dealt by these payment gateways in accordance with their respective privacy policies and other terms and conditions and Colombia Online shall not be liable, accountable or responsible for Your Personal Information, Sensitive Personal Data and Financial Information which you provide to these payment gateways.

Onward transfer - disclosure of information to third parties

Except as expressly set out in this Privacy Policy, We will not sell, lease or exchange the personal information relating to Our Customers; to third parties without first obtaining express consent, unless permitted or required by law.

TIL shares the personal information to any third-party without obtaining the prior consent of the Customer in the following limited circumstances:

i) Associated Service Providers

Companies associated with us who process personal information on Our behalf to provide Services such marketing, reporting issues and deriving analytical insights. The personal data is shared to our associated Service Providers under appropriate contractual agreements to safeguard your personal data from any misuse, leak, reselling and unauthorized access.

ii) Associated Third Parties

We may share or disclose the data with Third Parties for various purposes as generating lead campaigns, providing advertisements and managing data captured. We share or disclose your information to third parties only upon obtaining explicit consent from you. In case you do not wish Colombia to share or disclose your personal information to any third parties, you can do so by referring to the Do Not Sell My Info section in this Privacy Policy

iii) Public Authority or Compliance with Law

When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these terms and for complying with the applicable laws and regulations.

iv) Group Companies

TIL proposes to share such information within its group companies and officers and employees of such group companies for the purpose of processing personal information on its behalf. We also ensure that these recipients of such information agree to process such information based on our instructions and in compliance with this Privacy Policy, any other appropriate confidentiality and security measures.

v) Enforce Our Terms of Use and agreements

We may disclose your personal information to third parties in order to enforce or apply Our Terms of Service, or any other agreement or to respond to any claims, to protect Our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.

vi) Protect rights and property

We may disclose your personal information to protect the rights, property, or safety of Colombia Online, Our staff, Our Customers or other persons. This may include exchanging personal information with other organizations for the purposes of fraud protection.

vii) Legal

In the event Colombia Online is merged with or acquired by another company or in case of re-organization or re-structuring of business, we and our affiliates may share your personal information, wholly or in part, with another business entity.

Information use by the company

The Information as supplied by the Customers enables us to improve the Services and provide you the most user-friendly experience. In some cases/provision of certain service(s) or utility (ies), we may require your contact address as well. All required information is service dependent and the Company may use the above said Customer Information to, maintain, protect, and improve the Services (including advertising on the "Website") and for developing new services. We may also use your email address or other personally identifiable information to send commercial or marketing messages with 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, for notifying you in case of breach incidents, etc.) 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.

Any posted/uploaded/conveyed/communicated by Customers on the public sections of the "Website" becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

When you register with our Services, we contact you from time to time about updating of your personal information to provide the Customers such features that we believe may benefit / interest you

How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which We retain personal information depends on the purposes for which We collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend Our legal rights.

Except as required by applicable laws or in order to defend any actual or possible legal claims, We will take reasonable steps to return or irretrievably delete all personal data processed on behalf of Our Customers when it is no longer required to exercise or perform Our rights or obligations under Our Terms of Service, and in any event within 6 months of expiry or termination of Our Terms of Service.

California Residents’ Rights

A. Right to Know

When you use TIL's websites, we make good efforts to provide you, with access to your personal information as and when requested. You can request and receive a copy of the specific pieces of the personal information that We have collected from you in the last 12 months of making the request. You will receive the copy of your requested information electronically in a portable and technically feasible format, free of charge. This request can be made by the user twice in a period of 12 months.

We shall further ensure that any personal information or sensitive personal data 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 to be retained by law or for legitimate business purposes.

You can exercise these rights by sending us an e-mail at colombia@timesinternet.in or <additional method >

If any advertiser wish to verify, correct, update the information provided, he/she may login to the portal and change under billing information tab or can raise the request under report issue.

B. Right to Delete

We retain your personal information as long as necessary for the performance of the contract between you and us to comply with our legal obligations.

If you no longer want us to use your information then you can request that we delete your personal information and close your Colombia Online account, by sending us an email at colombia@timesinternet.in or < additional method >

Please note that if your request for the erasure of your personal information;

  • ● We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Colombia Online account for fraud or safety reasons, we may retain certain information from that account to prevent that Customer from opening a new account in the future.
  • ● We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
  • ● Because we maintain copies of personal information to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
  • ● In certain cases where deletion of your personal information is not feasible, We will implement appropriate measures to deidentify it so that it no longer associates with You Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate.

We may take 45 days from the date of receipt of request to complete your requests. However, if the nature of the requests are excessive in nature or would require significant effort then may ask for an extension of 45 days by giving a prior notice to you with the reason for the extension.

We may take 45 days from the date of receipt of request to complete your requests. However, if the nature of the requests are excessive in nature or would require significant effort then may ask for an extension of 45 days by giving a prior notice to you with the reason for the extension.

Do Not Sell My Info

Under CCPA, users based out of California have the right to “Opt Out” of sale of their information at any time. Please be advised that Colombia does not sell personal information for monetary consideration; however, we may share certain personal information with third parties under circumstances which might be deemed a “sale” under the California Consumer Privacy Act

Therefore, if you would like to proceed with your “Do Not Sell My Info” request, use the following button.

Alternatively, you can submit a request via <email> that includes your name, registered email id or mobile number.

Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization.

Cookies

To improve the responsiveness of the Site for our Customers, we may use "cookies", or similar electronic tools to collect information to assign each visitor a unique, random number as a user identification (User ID) to identify You. 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. A cookie cannot read data off your hard drive. We receive and store certain types of information whenever you interact with us via website, application or service through your computer/laptop/netbook or mobile/tablet/pad/handheld device etc. We only capture cookies essential for the functioning of our Service and do not capture any information that may uniquely identify you.

Privacy protection for children

Colombia doesn't knowingly show any interest based advertisement to & collect and maintain data from children less than 16 years of age. If we realize we have unknowingly collected data from children less than 16years of age, we make considerable efforts to remove such information from our system.

Security

We take appropriate security measures to protect against unauthorized access to the data or unauthorized alteration, disclosure or destruction of the same. These include internal reviews of our data collection, storage, 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 TIL is securely stored within the TIL controlled database. The database is stored on servers secured behind a firewall; access to the servers is password- protected and is strictly limited.

If you know or have reason to believe that your Colombia Online account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.

Data transfer, storage and processing

We may transfer your personal information to individual companies of the TIL affiliated companies or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards.

Colombia is operated in the Republic of India. Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located in the United States, the European Union, Canada or elsewhere outside of India, please be aware that information we collect may be transferred to and processed in India. By using the service, or providing us with any information, you consent to the transfer of such information in and to India and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.

Notification of changes

If We change this Privacy Policy and seek to use personal information which has already been collected and stored by Us in a manner which is different from that stated at the time of collection, We will either notify the relevant website visitors and/or Customers via e-mail or otherwise in some manner through the Site or Service.

If We make any material changes in Our privacy practices that do not affect personal information already collected and stored by Us, We will post a notice on Our Site notifying Customers of the change.

Metrics

California law requires Us to compile metrics for the previous calendar year regarding consumer requests and responses catered. Colombia will disclose the metrics with relevant details by July every year.

Contact us

I. Support

We use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services that may interest you. Any complaints or request or concerns with regards to the content or to report any abuse of laws or breach of these terms may be taken up with the designated grievance officer as mentioned below via post or by sending an email to colombia@timesinternet.in to Mr. Kapil Kapoor ("Grievance Officer").

II. Complaints

You can write to our data protection officer in case of any grievance or compliant. You have the right to complain about the data processing activities carried out by Colombia Ad-Tech before the competent data protection authorities.

If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact our customer support team via colombia@timesinternet.in.

III. Data controller officer

The data protection officer (DPO) appointed by TIL is Mr. Sumit Malhotra who can be contacted at sumit.malhotra@timesinternet.in

You can also write to:

Times Internet Limited

Express Building, 9-10, Bahadurshah Zafar Marg, New Delhi - 110002

If you have any queries, complaints regarding the collecting, processing, transfer of personal data/information or regarding this policy please do contact our Data Protection Officer.