Privacy Policy

A.The event CODE 2023 (“CODE”) organised by Mantarav Private Limited, a company incorporated under the provisions of the Companies Act, 2013 with its corporate office at Incuspaze, 4th Floor, Phase 4, Maruti Udyog, Sector 18, Gurugram, India (hereinafter, referred to as “EMB”, which term will mean and include, unless the context otherwise dictates, its officers, directors, agents, and representatives).

B.CODE is proposed to be a convention for fostering and encouraging digital entrepreneurship. CODE is proposed to be organised in New Delhi in June 2023.

C.To this end, EMB has developed the CODE application and website (together, the “CODE Platform”). Your use of the CODE Platform is subject to your compliance with the Terms of Use and this Privacy Policy (this “Policy”).

D.EMB may change this Policy at any time. By continuing to access or use the CODE Platform, you accept any changes or revisions to this Policy.

IF YOU DO NOT AGREE TO THIS POLICY, DO NOT USE THE CODE PLATFORM

1. Information Available on the CODE Platform

1.1.EMB provides information regarding the CODE event on the CODE Platform. This information pertains to, without limitation, timings of the event, announcements in regard to the event, as well as other information either publicly available or provided by you and other users of the CODE Platform.

1.2.While EMB takes every effort to ensure accuracy of information on the CODE Platform, EMB cannot guarantee the accuracy of the information provided on the CODE Platform by its users.

2.Opt-in/out Policy for the Attendee List on the CODE Platform

2.1.EMB supports the following policy on whether an attendee is listed in the event attendee list on the CODE Platform:

·  Attendees (except some VIPs selected by EMB) are listed in the attendee list on the CODE Platform to help foster pre-event networking. If a user does not want his/ her name and profile to be listed and viewed by other attendees, he/ she needs to explicitly opt out by changing the visibility setting on the Settings menu to be “invisible”.

·  Once an attendee signs in to the CODE Platform, his/ her name will be listed in the attendee list of this event to facilitate networking. They can still become invisible by changing the visibility setting on the Settings menu. If an attendee never signs in to the CODE Platform, his/ her name is not listed.

·  Once an attendee signs in to the CODE Platform, he/ she is explicitly asked whether he/ she wants to be listed in the attendee list for other attendees to network with him/ her. Based on the answer, his/ her initial visibility status will be set to “visible” or “invisible”, and he/ she can still switch between the two by changing it on the Settings menu. If an attendee never signs in to the CODE Platform, his/ her name is not listed.

2.2.However, please note that regardless of opt in/out policy, attendees’ contact information (e.g. emails, phone numbers) is not disclosed to other attendees unless users explicitly permit EMB so to do.

3.Remove Your Information from the CODE Platform

You have a choice to remove your information from the CODE Platform by contacting us at code@exmyb.com. After verification (we will need you to verify that you are removing your own information instead of others), we remove your information from the CODE Platform. Note that EMB may collect information from third party sources, having information removed from the CODE Platform does not mean that it is removed from such third party sources. On the CODE Platform, a user can also validate and revise his/ her own profile.

4.Personal Data the CODE Platform Collects

4.1.The CODE Platform collects information about your usages. This may include information about any IP address used to access the CODE Platform and your activities on the CODE Platform. This is intended to help us improve the CODE Platform to give users a better experience.

4.2.EMB collects information that you provide in creating an account at the CODE Platform. This may include information such as your name, email address, social network sign- in. We do not provide your information to any third party (subject to Clause 5 below).

4.3.EMB allows you to retain and access your search history and bookmark profiles on the CODE Platform. You may delete one or all at any time when the CODE Platform are available. EMB does not share your history and bookmarks with any third party (subject to Clause 5 below).

4.4.Certain functionalities of the CODE Platform require you to enter Personal Data to access your accounts with third-party websites, such as third-party social networks and websites. Your third-party login credentials will be stored for your convenience of continuously accessing the third party information upon your requests. We do not use this information for any other purpose. Your third-party login credentials are hashed and stored with the strictest security standards.

5.Use and Sharing of Personal Data

5.1.EMB may use Personal Data you provide to the CODE Platform to create and maintain your account, to personalise your experience, and to send email communications relating to the CODE Platform. EMB does not sell, exchange, transfer, or give this type of Personal Data to any other company without your consent.

5.2.EMB may use Personal Data about your use of the CODE Platform to improve its services. EMB may also use personal data with third parties service providers as described below:(a)   Monitoring services, such as Google Analytics, to assist EMB in improving its quality of service; and/ or(b)   Cloud hosting providers, such as AWS, to ensure service availability and permanent storage; and/ or(c)   Cookies, Pixel Tags, Local Shared Objects, Web Storage, and other similar technologies.As a result, information about how you use the CODE Platform may be available to other companies such as Google to the extent that their technology collects such information for EMB’s use. EMB actively protects your usage anonymity and does not distribute personally identifiable information about your use of the CODE Platform to any third parties other than as described above.

5.3.EMB reserves the right to disclose Personal Data to third parties if required to do so by law, or if EMB has a good faith belief that disclosure is necessary to: (i) comply with legal process served on us; and/ or (ii) protect and defend our rights or property; and/ or (iii) act in an emergency to protect someone’s safety.

5.4.EMB reserves the right to transfer Personal Data to any successor in interest to EMB’s business.

5.5.This Privacy Policy describes EMB’s handling of personally identifiable information as required by the Information Technology Act, 2000.

6.Cookies
EMB uses cookies and other similar technologies to recognise you when you visit and use the CODE Platform.

6.1.What are cookies and Web Beacons?A cookie is a small file placed on a computer hard drive. Web browsers can be configured to restrict or entirely block cookies, to configure cookie notification settings and/or to delete cookies already present on the browser or device. Information on how to do this is provided by the web browser’s help/reference section. Limiting or restricting certain types of cookies may prevent a user from using certain functionalities of the CODE Platform, depending on how the browser settings are configured. For example, Attendees may not be able to use the CODE Platform’s desktop/ laptop applications properly if cookies are disabled in the web browser. Unless a browser’s setting has been adjusted to decline cookies, our system will store cookies when a browser interacts with the CODE Platform. For more information about cookies and how to disable them, see www.allaboutcookies.org.

6.2.Why do we use cookies?The CODE Platform uses first- and third-party cookies for several reasons. Some cookies are required for technical reasons in order for the CODE Platform to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us to better understand your use of our Online Applications, to track and better serve the interests of EMB users, and to improve the experience of users on the CODE Platform. Third parties may serve cookies through the CODE Platform, for analytics and other purposes such as error diagnosis.

6.3.Types of cookies we use(a)   First-party cookies: These cookies are created by EMB. They are primarily used to allow you to use the CODE Platform. They may also assist us in our analytics activities. These cookies may use non-personal data (e.g., aggregate or de-identified information about your use of the CODE Platform) or information that uniquely identifies the browser or device you are using to access the CODE Platform.(b)   Third-party cookies: In addition to the first-party cookies we use, some third-party libraries and modules may place cookies on your computer through our the CODE Platform, access those cookies, and associate web beacons with them. These cookies enable third-party features or functionalities to be provided on or through the CODE Platform. The parties that set these third-party cookies can use them to recognise your device both when it visits the CODE Platform and also when it visits certain other, unaffiliated websites.

6.4.Types of first- and third-party cookies we useThe types of first- and third-party cookies we use on the CODE Platform are detailed below. These cookies may use non-personal data (e.g., aggregate or de-identified information about your use of the CODE Platform) or information that uniquely identifies the browser or device you are using to access the CODE Platform.(a)   Essential cookies: These cookies are strictly necessary to provide you with access to and the basic use of the CODE Platform. These cookies cannot be turned off.(b)   Performance: Also known as “statistics cookies”, and including analytics cookies, performance cookies collect information about how you use the CODE Platform, like which pages you visited and which links you clicked on. None of this information can be used to identify you. Their sole purpose is to improve the CODE Platform. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.(c)   Functionality: Also known as “preferences” cookies, these cookies allow a website to remember choices you have made in the past, like what language you prefer. They are used to enhance the user experience of the website but are non-essential to their use, but without these cookies, certain functionality may become unavailable.

6.5.Duration of cookies stored on your deviceCookies are either “temporary” or “persistent” in duration.(a)   Temporary cookies: We use temporary cookies on the CODE Platform to allow you to browse the CODE Platform without interruption. We may also use temporary cookies for internal tracking purposes. After your browsing session ends, this type of cookie does not store any information on your device.(b)   Persistent cookies: Some of our first-party analytics cookies and certain third-party cookies are persistent cookies. They allow us and third parties to understand visitors’ browsing behaviour over a longer period of time, to provide you with additional and customised features related to your use of the CODE Platform and the content that you have saved or stored through them. Depending on their function, this type of cookie may persist for different lengths of time ranging from several hours, to a week, or even several years. This type of cookie will persist after you end a browsing session and can be used by the CODE Platform or third parties to recognise your device when you begin a new browsing session.

6.6.Cookie management(a)   All cookies: You can adjust your preference to receive all types of cookies by managing cookies using your web browser settings. As the means by which you may allow or refuse cookies using browser settings varies from one web browser to another (e.g., Microsoft Edge, Chrome, Safari, or Firefox), you should use your web browser’s help menu for more information on setting your browser-based cookie preferences. You can also configure your browser at any time to be notified of the receipt of a cookie, so that you can decide whether you want to accept it or not.(b)   Cookies do not access other data on your hard drive, and you can delete them from your computer at any time using browser controls. At the moment, it is technically impossible for you to synchronise your settings between your browsers and your devices (your computer or your mobile devices). You must set them on each browser/device that you currently use and each time you use a new browser or device. Please note that if you choose not to allow, or otherwise disable or deactivate all cookies, this will apply to all cookie types and will affect the functionality of the CODE Platform. You may not be able to use the CODE Platform or certain features, and in some cases the CODE Platform simply will not work properly.(c)   Analytics cookies: To disable all analytics cookies managed by our third party analytics partners, please use the browser disablement mechanisms discussed immediately above

6.7. How often will EMB update this Cookie Policy?This Cookie Statement may be updated from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please check this Clause regularly to learn about our use of cookies and related technologies.

6.8. Where can I get further information?If you have any questions about our use of cookies or other technologies, please email us at code@exmyb.com.

7.THIRD-PARTY SERVICES

7.1.The CODE Platform is directed to people who are at least 18 years old, and EMB does not knowingly collect Personal Data from anyone under the age of 18. If You are aware that EMB has collected Personal Data from someone under the age of 18, please alert EMB at code@exmyb.com and the information will be removed from our system as soon as is reasonably possible. This policy regarding collection of data from children exceeds the requirements of the Information Technology Act.

7.2.EMB does not knowingly aggregate or provide Public Information about people under the age of 18.

8.We have tried our best in removing any possible security holes in the CODE Platform, but since it is hard to 100% verify software, we cannot provide 100% guarantee that the CODE Platform has zero security vulnerability. EMB is not responsible for any security issues caused by the CODE Platform.

9.International Data Transfers and Certain User Rights

9.1.Location of DataEMB is based in India. We provide services globally using computer systems, servers, and databases located in India. When you use our services from outside of India, your information may be transferred to and processed in India. Please note that Indian data and privacy laws may not be as comprehensive as those in your country. Residents of certain countries may be subject to additional protections as set forth in Clauses 9.2, and 9.3 and 9.4 below.

9.2. EEA, Switzerland, & UK only9.2.1   The EU General Data Protection Regulation (GDPR)
The EU General Data Protection Regulation (or the “GDPR”) requires EMB to provide users with the following information about the processing of their Personal Data.9.2.2   Legal grounds for processing your Personal Data
GDPR requires us to tell you about the legal ground we’re relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data include:(a)   you provided your consent;(b)   it is necessary for our contractual relationship;(c)   the processing is necessary for us to comply with our legal or regulatory obligations; and/or(d)   the processing is in our legitimate interest to fulfil our service as an event organising, and content providing platform (for example, to provide you with customer service, and to protect the security and integrity of our systems, etc.).9.2.3   EMB as a data processor/ data controller
GDPR makes a distinction between organisations that process Personal Data for their own purposes (known as “data controllers”) and organisations that process Personal Data on behalf of other organisations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data. EMB acts as a data controller as it collects the data for itself.9.2.4   Data Access and Data Deletion
Data protection law provides you with rights in respect of Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, and unsubscribe from marketing communications. Users of the CODE Platform can exercise these rights by editing their profiles on the the CODE Platform, as well as deleting messages or photos posted by them. If you cannot find what you’re looking for, please contact us at code@exmyb.com. Please note that requests to exercise data protection rights will be handled by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.9.2.5   Data Incident Notifications
In cases of data accessed in an unauthorised manner, we will notify the affected users directly.

9.3. USA9.3.1   California Users
Under California’s “Shine the Light” law, California residents have the right to opt out of disclosing information to third parties for the purpose of allowing such third parties to directly market their products and services. At this time, we do not engage in this type of disclosure. Under the California Consumer Privacy Act (“CCPA”), California consumers have the following rights, which can be exercised directly or in certain cases, through an authorized agent:(a)   Right to Know: You have the right to request information about the categories and sources of personal information we collect, our purposes for collecting the information, and the types of third parties that receive that information. Details about our data collection, use and third-party disclosures can be found in Clauses 4 and 5 above. In addition, you have the right to request a copy of your personal information. You may exercise this right once per 12 month period by sending your request to code@exmyb.com.(b)   Right to Delete: You have the right to request that we delete some or all of the personal information that we have about you. Deleting all data will typically require the deletion of your account, along with all content. Notwithstanding the foregoing, we may retain information to provide services you have ordered, complete transactions, honour opt-outs, prevent fraud, spam, and other abuse, comply with our legal obligations, cooperate with law enforcement, and to exercise and defend our rights. You can exercise your right to delete by sending a request to code@exmyb.com.(c)   Do Not Sell: You have the right to opt out of the sale of your personal information, and to request information about whether we have sold your personal information in the past 12 months. When you use our services, we may share your personal information with advertising partners in a way that may constitute a sale under the CCPA. You may opt out via the link provided on the relevant page or app. If we do not provide an opt-out mechanism, it is because we do not believe in good faith that your personal information is being sold.(d)   Non-Discrimination: We won’t discriminate against you because you exercise any rights herein. To exercise your rights to know and delete, we must be able to verify your identity as the owner of the CODE account you are inquiring about. We may not be able to fulfil your request until we can do so. In general, we verify identity by confirming that you are the owner of the email address associated with the account. An authorised agent submitting a request on your behalf must also have access to the email address associated with the account, along with sufficient evidence that you have authorised that person to submit the request on your behalf. Although you need not have a CODE account to submit a request, we may not be able to locate certain information to process your request if you don’t have one.9.3.2   Nevada Users
Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we don’t have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, you can send your request to code@exmyb.com. You can provide us with your name and email address here. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our plans change. At that time, we will create a process for verifying your identity and providing an opportunity to verified consumers to complete their opt-out. Please become familiar with our data practices as set forth in this Policy. We may share your data as explained in this Policy, such as to enhance your experiences and our services, and those activities will be unaffected by a “Nevada do not sell request”.