Privacy Policy

Effective Date: 22.09.2022

1. Introduction

Welcome to (“we”, “our”, “us”, or “99Notes”). We are committed to protecting and respecting your privacy. This Privacy Policy outlines the types of information we collect, how we use and protect it, and your rights regarding your personal data in compliance with the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

2. Information We Collect

We may collect and process the following types of information about you:

2.1 Personal Information

  • Identity Information: This includes your name, username, or similar identifiers.
  • Contact Information: This includes your email address, phone number, and mailing address.
  • Educational Information: This includes your academic records, qualifications, and other related information.
  • Financial Information: This includes your payment information, billing address, and transaction details.

2.2 Non-Personal Information

  • Technical Information: This includes your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
  • Usage Data: This includes information about how you use our website, products, and services.
  • Marketing and Communications Data: This includes your preferences in receiving marketing from us and your communication preferences.

3. How We Collect Information

We use different methods to collect data from and about you, including:

3.1 Direct Interactions

You may provide us your Identity, Contact, and Financial Information by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

  • Register on our website
  • Subscribe to our service or publications
  • Request marketing to be sent to you
  • Participate in discussion boards or other social media functions on our site
  • Enter a competition, promotion, or survey
  • Provide feedback or contact us

3.2 Automated Technologies or Interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

3.3 Third Parties or Publicly Available Sources

We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    • Analytics providers such as Google
    • Advertising networks
    • Search information providers
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services

4. Use of Your Information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate Interest: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Compliance with a Legal Obligation: Where we need to comply with a legal or regulatory obligation.

5. Purposes for Which We Will Use Your Information

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/ActivityType of DataLawful Basis for Processing including Basis of Legitimate Interest
To register you as a new customerIdentity, ContactPerformance of a contract with you
To process and deliver your order including managing payments, fees, and chargesIdentity, Contact, Financial, Transaction, Marketing and CommunicationsPerformance of a contract with you, Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include notifying you about changes to our terms or privacy policyIdentity, Contact, Profile, Marketing and CommunicationsPerformance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)Identity, Contact, TechnicalNecessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise), Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youIdentity, Contact, Profile, Usage, Marketing and Communications, TechnicalNecessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiencesTechnical, UsageNecessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to youIdentity, Contact, Technical, Usage, ProfileNecessary for our legitimate interests (to develop our products/services and grow our business)

6. Disclosure of Your Information

We may share your personal data with the parties set out below for the purposes set out in the table above:

  • Internal Third Parties: Other companies in our group acting as joint controllers or processors and who are based in India and provide IT and system administration services and undertake leadership reporting.
  • External Third Parties:
    • Service providers acting as processors based in India who provide IT and system administration services.
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in India who provide consultancy, banking, legal, insurance, and accounting services.
    • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in India who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. You can set your browser to refuse all or some browser

  • cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

11. Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

12. International Transfers

We may share your personal data within our group of companies. This may involve transferring your data outside of India. Whenever we transfer your personal data out of India, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards.