Privacy Policy - CFO Genie

Welcome to CXO Genie, we take your personal data seriously and we work hard to protect your information.

CXO Genie (collectively “We”, “Us”, “Our”) owns and operates this App. This privacy policy is a legal agreement between You, as the user of the App (CXO Genie Mobile Application) , Websites (cxogenie.com ,cfogenie.com, chrogenie.com, cscogenie.com, cmogenie.com, foundersgenie.com) and CXO Genie, as the owner of the App and the Websites. This Policy is only applicable to the Users of the App and the Websites, and the information and data gathered from the Users directly and not to any other information from any other external links.

This Privacy Policy describes what personal information CXO Genie collects, how we use this information, how this information may be shared, and what choices and rights you have with respect to this information. Access and use of our Platform is subject to this Privacy Policy.

You are hereby advised to read this Policy carefully and fully understand the nature and purpose of gathering and/or collecting sensitive, personal and other information and the usage, disclosure and sharing of such information.

This Policy has been prepared under the provisions of (Indian) Information Technology Act, 2000 (IT Act) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (IT Rules) promulgated thereunder, and sets out the practices and policies for the protection of personal information (including sensitive personal data or information) collected, received, possessed, stored, dealt with or handled by CXO GENIE.

BY VOLUNTARILY PROVIDING US WITH INFORMATION, YOU ARE CONSENTING TO OUR USE OF IT IN ACCORDANCE WITH THIS POLICY.

1. Applicability

1.1 This privacy policy (Policy) describes Our policies and procedures on the collection, use, storage and disclosure of any information including, business or personal information provided by You (You/r) while using Our platform. This Policy specifically governs

1.2 The collection and use of personal data and sensitive personal data or information provided by You.

1.3 The processing of personal information and sensitive personal data or information provided by You while using Our platform.

1.4 Your use of the platform will be governed by this Policy in addition to the Terms of Use as applicable to You. The Policy together with the Terms of Use are referred to as the platform Documents.

1.5 During the course of your association with CXO Genie, You may be required to execute certain other commercial agreements and such commercial agreements and this Privacy Policy shall, together with the Terms of Use unless explicitly specified to the contrary, govern your business relationship with CXO Genie.

1.6 However, in the event of a conflict between the terms contained in the platform Documents and the terms contained in the commercial agreements, as applicable to You, the terms of the commercial agreements shall prevail unless specifically provided otherwise in the respective commercial agreement.

2. Definitions

Capitalized terms not otherwise defined in this Privacy Policy or the Terms of Use shall have the following meaning

2.1 Personal Information or Business Information shall mean any information that relates to a natural person or that of a company, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person and is not otherwise publicly available. For avoidance of doubt, examples of personal information include a person’s name/company’s name, address (including home/work addresses and personal/work email addresses), date of birth, voice, opinions, permanent account number, etc.

2.2 Sensitive Personal Data or Information and Sensitive Business Information shall mean personal company’s information, which consists of information relating to any to the following of an individual/company:

a. Passwords

b. Aadhar card details

c. Financial information such as Bank account or credit card or debit card or other payment instrument details, etc.

2.3 User Information shall mean, collectively, Your personal information and sensitive personal data or information or any other information collected from you.

3. Collective of Information

3.1   CXO Genie will use the User Information provided by You only in accordance with the purposes described in this Policy

3.2   In general, You can utilise Our platform only when you register – you would be logging in with a unique username and password giving you access to your profile and access to other features as applicable without revealing Your personal information to other users. However, You may not be able to access multiple areas of the platform or features provided on the platform once your subscription period/membership expires. Once your membership expires, You would only get access to limited information as deemed fit by the admin.

3.3   Minors are prohibited from using Our services and We are committed to not collecting Personal Information from any minors.

3.4   During Your use of Our platform, We may collect and process such information from You, including but not limited to the below mentioned:

3.4.1 Information that You provide to Us by filling in forms on the platform. This includes both Personal Information and Sensitive Personal Information including contact information, name, gender, email address, mailing address, phone number, skills, current and previous employer name and some other personal preferences including areas of interest and any other related information.

3.4.2 Information relating to Your company/employer provided by you may be used by Us on the platform or otherwise as agreed to in the Terms of Use. As a default setting, CXO Genie shall be creating your basic profile, which is available to other users of the application containing name, your photograph, logo, sectors, etc. CXO GENIE will also be creating a detailed profile from the information that You provide as well as collected from the platform, which contains all data available with CXO GENIE relating to Your company.

3.4.3 Information that You provide when You write directly to Us or while interacting with other users on our platforms (including by e-mails or letters).

3.4.4 Information that You provide to Us over telephone. We may make and keep a record of the information You share with Us.

3.4.5 Information that You provide to Us by completing surveys, feedbacks etc.

3.5 Sensitive Personal Information:

3.5.1  CXO Genie will not collect Sensitive Personal Data or Information from You unless the collection of such sensitive personal data or information is considered necessary for the purpose for which it is being collected and even in such a case, You will be made aware of the following:

a. The fact that Your Sensitive Personal Data or Information is being collected

b. The purpose for which the Sensitive Personal Data or Information is being collected

c. The intended recipients of the Sensitive Personal Data or Information

3.5.2   You shall have the option of not disclosing Your Sensitive Personal Data or Information to CXO GENIE. In the event that you choose not to disclose Sensitive Personal Information, processes that might get affected.

4. Remarketing

We also may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities in the Mobile Application. These companies may deliver ads that might place cookies and otherwise track user behaviour.

5. Advertisement

We may display online advertisements and we may share aggregated and non-identifying information about our customers that we collect through the registration process or through online surveys and promotions with certain advertisers. We do not share personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.

6. Affiliates

We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Privacy Policy.

7. Access to User Information:

7.1 You shall have the right, upon request, to access and review Your Information provided to Us. You may decline to submit identifiable information through the platform, in which case You may not be allowed to access certain features / parts of the platform. If You are a registered user, You may update or correct Your account information and email preferences at any time by logging in to Your account. Alternatively, if You believe that any of Your information held by Us is inaccurate, You may write to Us at swati.saxena@cxogenie.com. It is Your responsibility to ensure that any information You provide to Us remains accurate and updated.

7.2 The Information collected by Us shall not be retained for longer than is required for the purpose for which the information may lawfully be used or is otherwise required under any other law for the time being in force.

8. Use of Information

8.1We may use the User Information or other information provided by You in the following ways:

8.1.1 Monitor, improve and administer Our platform.

8.1.2 Conduct audit, research and analysis.

8.1.3 Analyse how the platform is used, diagnose service or technical problems, maintain security.

8.1.4 Remember information to help You efficiently access the platform.

8.1.5 Monitor aggregate metrics such as total number of viewers, visitors, traffic, and demographic patterns.

8.1.6 To confirm Your identity in order to ensure that You are eligible to Use the platform.

8.1.7 To ensure that content from Our platform is presented in the most effective manner based upon Your interests.

8.1.8 To contact You to ensure user satisfaction with respect to Your use of the platform.

8.1.9 To provide You with information that You request from Us, where You have consented to be contacted for such purposes.

8.1.10 To carry out Our obligations arising from any contracts entered into between You and Us as well as between Us and third party service providers, namely our technology partners.

8.1.11 To notify You about changes on Our platform.

8.1.12 In relation to the functioning of any feature/service you access or have signed up for in order to ensure that we can deliver such features/services to you.

8.1.13 In relation to any transaction entered by you on our platform to subscribe to Services.

8.1.14 In relation to any issued query or requested information by You from us.

8.1.15 To enable Us to comply with Our legal and regulatory obligations.

8.2 Personal Information that You provide towards creation of a publicly visible profile on Our platform may be indexed by search engines (such as www.google.com and www.bing.com) and may appear in search results on such search engines.

8.3 We shall notify You if We intend to use Your Personal Information or Sensitive Personal Information for any use not covered herein or in such other additional terms of use or agreement that you sign with Us. You will also be given the opportunity to withhold or withdraw Your consent for Your use other than as listed above.

9. Disclosure of Information

9.1 Except as provided for in this Privacy Policy, We shall not disclose / transfer Your Sensitive Personal Information to any third party without Your prior consent, unless such disclosure / transfer:

a. Is necessary for performance of a contract between CXO Genie and You and You have authorized Us to share the Sensitive Personal Information.

b. As part of a corporate re-organisation, merger, acquisition or sale of business

c. Is required under applicable laws or through a court order

9.2 In the event that We sell or buy any business or assets, we may share Your Personal Information, with Your prior consent, to the prospective seller or buyer of such business or assets. User, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution.

9.3 We may disclose Your Personal Information to third-party service-providers, solely in the course of their provision of services to Us. We will take reasonable precautions to ensure that these service-providers are obligated to maintain the confidentiality of Your information. E.g our technology partners who are building the App.

9.4 We may disclose Your Personal Information, if We are under a duty to do so in order to comply with any legal obligation, or to protect our rights, property, or safety, or those of Our users, or other third parties. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

9.5 We may disclose Your information, without Your prior consent, to governmental and other statutory bodies who have appropriate authorisation to access the same for any specific legal purposes.

9.6 CXO Genie requires all third parties with whom it shares any Sensitive Personal Information to implement the same level of data protection that CXO Genie has adopted, as provided for under the IT Rules.

10. Links to Third Party Sites

10.1 Our Website may, from time to time, contain links to and from the websites of Our partner networks, affiliates and other third parties. The inclusion of a link does not imply any endorsement by Us of the third party website, the website’s provider, or the information on the third party website. If You follow a link to any of these websites, please note that these websites may be governed by their own privacy policies and We disclaim all responsibility or liability with respect to these policies or the websites. Please check these policies and the terms of the websites before You submit any information to these websites.

10.2 Similarly, Our Website can be made accessible through a link created by other websites. Access to Our Website through such link/s shall not mean or be deemed to mean that the objectives, aims, purposes, ideas, concepts of such other websites or their aim or purpose in establishing such link/s to Our Website is necessarily the same or similar to the idea, concept, aim or purpose of Our Website and/or Our services or that such links have been authorized by Us. We are not responsible for any representation/s of such other websites while affording such link and no liability can arise upon Us consequent to such representation, its correctness or accuracy.

11. Payment

We may use services of certain payment gateways/service providers for processing payments. We/Razorpay do not store your card data on Our/Their servers. The data is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS) when processing payment. Your purchase transaction data is only used as long as it is necessary to complete Your purchase transaction. After that is complete, Your purchase transaction information is not saved. Our payment gateway adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by Our App and its service providers. For more insight, you may also want to read terms and conditions of Razorpay.

12. Storage and Security

12.1 We endeavour to securely store all information we gather within databases controlled by Us. However, We may store information in locations outside our direct control (for instance, on servers or databases co-located with hosting providers.

12.2 Our databases are stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while We strive to use commercially acceptable means to protect Your information, We cannot guarantee its absolute security.

12.3 We use commercially reasonable safeguards to preserve the integrity and security of Your information against loss, theft, unauthorized access, disclosure, reproduction, use or amendment.

12.4 The information that We collect from You may be transferred to, and stored at, a destination inside or outside India. By submitting Your information on Our Platform, You agree to this transfer, storing and/ or processing. We will take such steps as we consider reasonably necessary to ensure that Your information is treated securely and in accordance with this Policy.

12.5 In using the Platform, You accept the inherent security implications of data transmission over the internet and the world wide web cannot always be guaranteed as completely secure. Therefore, Your use of the Platform will be at Your own risk.

12.6 We assume no liability for any disclosure of information due to errors in transmission, unauthorized third party access or other acts of third parties, or acts or omissions beyond Our reasonable control and You agree that You will not hold Us responsible for any breach of security.

12.7 In the event We become aware of any breach of the security of Your information, We will promptly notify You and take appropriate action to the best of Our ability to remedy such a breach.

12.8 You agree to immediately report to Us all incidents involving suspected or actual unauthorized access, disclosure, alteration, loss, damage, or destruction of data.

12.9 Any Sensitive Personal Data or Information provided on the Platform is encrypted using secure socket layer technology (SSL) while transferring such Sensitive Personal Data or Information.

13. Confidentiality

13.1 As a registered user with an account and a password, You are responsible for keeping Your password confidential.

13.2 We will keep confidential and protect any and all information provided by You except where disclosure is required or permitted by law.

13.3 You may obtain certain confidential information, including without limitation, information related to other users or third parties including investors and companies and technical, contractual, product, pricing, business related functions, activities and services, customer lists, knowledge of customer needs and preferences, business strategies, marketing strategies, methods of operation, markets and other valuable information in relation to such Users or third parties that should reasonably be understood as confidential (Confidential Information). You acknowledge and agree to hold all Confidential Information in strict confidence. Title and all interests to all Confidential Information shall be vested in Us.

13.4 We provide access of Personal Information to employees and advisors who We believe reasonably need to come into contact with that information to provide services to You or in order to do their jobs.

13.5 We may provide information, including Personal Information, to third-party service providers to help Us deliver Our services efficiently and effectively. Service providers are also an important means by which We maintain Our Platform and mailing lists. We will take reasonable steps to ensure that these third-party service providers are obligated to protect Personal Information on Our behalf through confidentiality agreements and otherwise.

13.6 We do not intend to transfer Personal Information without Your consent to third parties who do not agree to be bound to act on Our behalf or under this Privacy Policy unless such transfer is legally required. Similarly, it is against Our policy to sell Personal Information collected online without consent.

13.7 The restrictions set out herein shall not apply to disclosure of Confidential Information if and to the extent the disclosure is:

a. required by the applicable law of any jurisdiction

b. required by any applicable securities exchange, supervisory or regulatory or governmental body to which the relevant party is subject or submits, wherever situated, whether or not the requirement for disclosure has the force of law

c. made, by CXO Genie, to its shareholders, managers, advisors and affiliates

d. made to employees and representatives on a need to know basis, provided that such persons are required to treat such information as confidential through written agreement in terms which are no less strict than this Policy.

13.8 This Policy does not apply to any information other than such information collected by CXO GENIE through the Platform. This Policy shall not apply to any unsolicited information You provide Us through this Platform or through any other means. This includes, but is not limited to, information posted to any areas of the Platform which are accessible by other users as well. All such unsolicited information shall be deemed to be non-confidential and CXO GENIE shall be free to use, disclose such unsolicited information without limitation.

13.9 You acknowledge and agree that any User Information you provide directly or indirectly to another User of the Platform, whether or not through the Platform, may not be subject to the same security or confidentiality offered by CXO GENIE and that CXO GENIE shall not have any responsibility in respect of such information under this Policy even if it was provided through the Platform.

14. Indemnity

You agree to indemnify and hold CXO Genie harmless from:

a. any actions, claims, demands, suits, damages, losses, penalties, interest and other charges and expenses (including legal fees and other dispute resolution costs) made by any third party due to or arising out of any violation of the terms of this Policy.

b. any acts or deeds, including for any non-compliance or violation, of any applicable law, rules, regulations on Your part.

c. for fraud committed by You.

15. Severability

We have made every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy

16. No Waiver

The rights and remedies available under this Policy may be exercised as often as necessary and are cumulative and not exclusive of rights or remedies provided by law. It may be waived only in writing. Delay in exercising or non-exercise of any such right or remedy does not constitute a waiver of that right or remedy, or any other right or remedy.

17. Governing Law and Dispute Resolution

17.1 In accordance with the Information Technology Act 2000, the name and the details of the Grievance Officer at CXO GENIE is provided below. You may

a. Request access to Your Sensitive Personal Data or Information

b. Report any grievances in relation to Your Sensitive Personal Data or Information

c. any security breach in relation to Your Sensitive Personal Data or Information; to the Grievance Officer. Jay Sampat

Email: jay.sampat@cxogenie.com

17.2 This Policy shall be governed by and construed in accordance with the laws of the Republic of India and subject to the provisions of arbitration set out herein, the courts at Gurugram, India shall have exclusive jurisdiction in relation to any Disputes (defined below) arising out of or in connection with this Policy subject to the provisions of this Paragraph 13.

17.3 Any action, dispute or difference arising under or relating to this Policy (Dispute) shall at the first instance be resolved through good faith negotiations between the parties hereto, which negotiations shall begin promptly, within 15 (fifteen) days after a party has delivered to the other party a written request for such consultation. If the parties are unable to resolve the Dispute in question within 15 (fifteen) days of the commencement of negotiations, such Dispute shall be referred to and finally resolved by arbitration in accordance with the Arbitration and Conciliation Act, 1996, as amended from time to time and rules prescribed thereunder. When any Dispute is under arbitration, except for the matters under dispute, CXO GENIE and You shall continue to exercise the remaining respective rights and fulfil the remaining respective obligations under this Terms of Use.

17.4 The arbitration shall be conducted by a sole arbitrator jointly appointed by CXO GENIE and You. If parties fail to appoint an arbitrator within 30 days after service of the notice of arbitration, such arbitrator shall be appointed in accordance with provisions of the Arbitration and Conciliation Act, 1996. The venue of arbitration shall be Gurugram, India.

17.5 The language of the arbitration proceedings and of all written decisions and correspondence relating to the arbitration shall be English.

17.6 You agree and acknowledge that the provisions of Paragraph 11 (Confidentiality) are of importance to CXO Genie and monetary compensation may not constitute adequate relief and remedy to CXO Genie for non-performance by You of your obligations thereunder. Accordingly, CXO Genie shall be entitled to claim specific performance and seek mandatory and/or perpetual injunctions requiring You to perform your duties and obligations under such provisions.

18. Foreign Jurisdiction

19. Changes to the Policy

We may update this Policy to reflect changes to Our practices. If We make any material changes We will notify You by e-mail (sent to the e-mail address specified in Your account) or by means of a notice on this Platform upon the change becoming effective. We encourage You to periodically review this page for the latest information on Our privacy practices. By using this Platform and Our services, you consent to the terms of this Policy and to our use and management of User Information for the purposes and in the manner herein provided.

20. Contact

20.1 You can always withdraw Your consent for usage, processing of Your information by Us by writing to Us at the address mentioned above.

20.2 We may contact You using the Personal Information You have given Us:

(i). in relation to the functioning of any service You have signed up for in order to ensure that We can deliver the services to You.

(ii). in relation to any transaction entered by You on Our Platform to subscribe to services.

(iii). where You have opted to receive further correspondence.

(iv). to invite You to participate in surveys, opinion polls, etc., about Our services or otherwise (participation is always voluntary).

(v). to provide you updates and information in relation to Our services.

At any time if you have any questions or concerns regarding your privacy or if you would like to: correct, amend or delete any personal information we have about you or simply want more information, contact us at harsh.sharma@cxogenie.com or you can contact us at the following address:

Unit No 239, JMD Megapolis, Tower A, Sector – 48, Gurgaon, Sohna Road, 122018

21. Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the Mobile Application or its Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the Mobile Application and its Services.