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Data Controller, International users/stakeholders, and Transfer
Collection of Personal Information
Use of Personal Information
Use of Cookies and other Tracking technologies
Data sharing and disclosure
Security of Information
Access to your Personal Information
Data retention and deletion
Children’s Information
Referral Programs
Complaint about Privacy Policy
Changes & Update to Privacy Policies
Your Choice and Transparency
Introduction
When you use services through our application, which is through Customer Cooperative-21 (“CC-21”) which is a concept and process engineering of Jeevanshailly Household Management and Market Pvt ltd and which is developed by Netspeq solutions(India) and jointly operated, administered, maintained and managed by Netspeq Solutions Pty Ltd (Australia), Netspeq solutions (India) and Jeevanshailly Household Management and Market Pvt ltd (India) collectively refereed as (“Netspeq,” “Netspeq solutions (AI),” ”we,” ”us, ”or “our”). We may collect personal information (as that term is defined in the Privacy Act 1988 (Cth)) to assist you with provisions to:
place, process and receive delivery orders.
To improve CC-21 service
To process, record and manage system transactions such as financial, administrative, customer care, operational etc.
We do understand that you trust us with your personal data. This notice describes on what personal data (data) we collect and how we handle and share your personal information and your choices regarding this data; when you visit or use www.cc21.com (the “website”), the CC-21 mobile application and any other associated service linked to this privacy policy.
User Overview
This notice applies to all users in Australia and includes users of CC-21 website, CC-21 application and features and other services unless covered by separate privacy notice. This notice specifically applies to following users and are collectively referred as users in this notice:
Order recipients: They are individual who request or receive food, groceries or other product and services for delivery or pickup via CC-21 account. This also include individuals who use our guest user feature to access delivery or pickup services without creating and or logging into their account.
Guest User: They are Individual who receive delivery services through provision of minimal information such as contact number, name, delivery address and payment related information, biometric identity, etc. Or else they may also be an individual who receive order ordered by other CC-21 account owner who may be friend, family member, or individual account holder.
Delivery Person: Individual who facilitates and/ provides delivery services via CC-21 such as delivery partner, shoppers, squeezers.
Business: Owners or employees of restaurants or other merchants on the CC-21 platform.
This Privacy Practices are subject to applicable laws in places in which we operate (Australia). This notice also governs Netspeq solutions policy for other collection of data with its services.
Data Controller, International Users and Transfer
Netspeq Solutions Pty ltd (Australia) is the data controller for data collected in connection with use of CC-21 services in Australia. As Netspeq solutions Pty Ltd (Australia) is a associate company through international association, we are an International association and may require to processes your data Internationally to manage and offer you seamless experience regardless of where you use our services. The information collected whilst that use may be transferred to and maintained on servers located in countries other than Australia and a third-party data storage providers may be used from time to time for this purpose. As we are based in India, any information we obtain about you will at minimum be stored in accordance with India privacy law, standards and regulations and may not be equivalent to laws in your country of residence. Netspeq Solutions Pty Ltd (Australia) is controller of data for requirement related to compliance of worker rights in Australia. You also acknowledge that we will not be required to take reasonable actions to ensure that the overseas user complies with Australian Privacy laws and if overseas user is in breach of Australian Privacy law, the user may not be accountable under Australian Privacy laws and may not be able to seek redress under Australian Privacy law for the breech. As the oversea users or stakeholders are subject to different privacy policies, laws, and regulation they may not be subject to any privacy obligations to Australian privacy law. It must also be noted that the foreign users or stakeholders are subject to a foreign law that may compel the disclosure of personal information to third party such as oversea agency or authority. Your usage of this service automatically provides your consent to this collection, transfer, processing, storage and administration of personal information to, and in countries other than Australia; for instance (but are not limited to) regions like Europe, Asia pacific, North America, South America. On appropriate request, we may transfer personal data to countries other than your home country to:
provide you with our services in different country.
Respond to a customer support request submitted by you.
Enable access of authorized and limited order histories data by the user in another country after they have left the country where the service was rendered.
Determine and authorize the scale and type of date access that can be provided to the customer based on consideration such as multiuser transactions, time, country in which access is requested, user agreement, user instructions, prior consent, adequacy decisions for relevant countries.
Respond to request for personal data from law enforcement agency. This shall be based on Netspeq solutions Internal procedures for processing such request and shall ensure that any such data disclosure to the designated law enforcing agency is in the manner that is consistent with regulatory requirement of applicable law.
Questions, suggestions, comment and complaints about Netspeq Solutions data practice can be submitted through the form provided in the link .This will be handled centrally on behalf of the relevant controller. You can also use this link to submit questions or ask for standard transfer clause or transfer mechanism in place for any relevant data processing activity.
Collection of Personal Information
Based on our services, Netspeq solutions Pty Ltd may from time to time, receive and store personal information you enter onto our website, CC-21aplication or any other associated services linked to this privacy policy. Types of personal information that we may collect about you are:
Direct information's:
Basic information: Name, alias, account name, phone number, delivery address, postal address, email address, login name and password, guest user details and other relevant information that may identify you.
Demographic data: information and proofs regarding you date of birth and age, gender, occupation to enable us you determine you eligibility for appropriate promotion and procurement of products and services.
Biometric: With your consent and permission we may collect and use your personal biometric information such as photos, images, face and voice biometric data and other biometric data as required for the purpose of identity confirmation.
Commercial information: information related to your procurement of product & /or services in terms of search conducted, order placed, date and time of purchase, delivery, delivery ratings, merchant rating, feedback, etc. to evaluate your purchasing and or consuming history or tendency.
Payment information: information related to complete the payment transactions such as name of financial institution, payment methods preference, billing address, etc. As we will be using third party payment processors to collect the payment information and process the payment made over or through the service, we may obtain only a limited information with regards to your payment card from our payment processors.
Background check information: this information is required to identify and verify for safety, security, and identity purpose. This type of information may include government issued identification, driver history or criminal records (where permitted by law), known aliases and prior addresses, right to work, etc.
Information collected automatically and through direct communication:
Communicated information: Information is collected and stored automatically whilst you use our services, complete electronic forms, communicate with customer care or communicate with our shoppers, delivery personal, businesses, squeezers through online chat, text, phone or email. For example: order details, personal information such as name and contact numbers, address, email address, purpose of communication and / interaction, details of action taken, feedback, real time updated status of ordered product &/ services, your response to survey and/ promotions etc.
Site usage information: This includes information related to users’ interaction with our services through use of our website, the CC-21 mobile application and any other associated service linked to this privacy policy. This information collected may be technical information (such as information related to users’ activity on our site through internet or other network activity. Such information may include users information on user browsers, operating system, IP address, personal and online identifier, unique device identification, device type, version of app being used, etc.),site preferences( for user experience enhancement using cookies), site browsing information ( information related to site visited before accessing our website or mobile application CC-21,the feature or pages of our site or mobile application that were visited by the user, search history, time spent over the platform or particular page, app performance , app crashes, etc.).
Third parties’ information: Netspeq solutions and its associates may receive personal information from third parties. If we do, this information will be protected as set out in this policy.
Geo location information: such information shall be collected through appropriate permission system used by your mobile operating system or browser. Data such as precise or approximate location, from delivery partner, order recipient, and other associated stake holders may be collected from the mobile device when C-21 application is running in the foreground and / background. The users have option to disable or not grant permission for collection of data, however this might impact certain features of the application, or any other system and provisions linked to this policy. This information may be used for but not limited to activities such a provision of accurate deliveries of your order, provisions of recommendations for you, enhancement of user experience, further improvement in service delivery, etc.
Transaction information: Such as information relating to and/ needed to complete your order, including order detail and associated transaction history, order timeline, payment transaction information, applicable promotions.
Referee and /Referral information: This includes Information and transaction records relating to referee associations with referral and participating referral user in our referral programs to enable revenue sharing in accordance to set and authorized referral contribution Policy.(Note (for customers only) : Netspeq solutions or its Associates shall not provide the referee with transactions information related to their referral, however we will provide with a provisions where a referee can request for framework based enquiry on periodic consolidated referral contribution statement and the corresponding referral can respond appropriately subject to referral willingness.)
Data from other Source: such as but not limited to only those mentioned below:
users or account holders who request service for or on behalf of others (Friends, families).
users or other providing information related to claims or disputes.
service providers or vendors who support to verify users’ identity, background credentials, eligibility to work, etc.
insurance, vehicle, or financial service provider for delivery partner.
Law enforcement officials, public health officials and government agencies.
Services that use CC-21 APIs or Service providers whose AP's is used by CC-21 platform.
Financial service provider's such as financial institution in partnership, payment providers.
Publicly an available source and social media.
Other information and/ Data: other information not specifically listed here which we will use as described in the privacy policy or disclosed at the time of collection.
We will not be able to provide you with our services or may be able to provide you with users limited service if you choose not to provide us with your relevant personal information.
Use of your Personal Information
We may use your personal information from you in various possible ways and in various combinations on the basics that such an action by us is necessary to fulfill the terms of our agreement with the users or they are necessitated for the purpose of CC-21 or its users legitimate interests. Some of such requirements are mentioned below:
Maintain, improve and provide you with personalize information, updates and experience related to our services that may require:
To establish and maintain your user profile (Create/update user account)
To provision customer support and enable communication between user
To authorize and enable delivery of food item or products by matching available delivery personal to user requesting services based on availability, user proximity, user preference and other factors such as system behavior.
To ensure appropriate data sharing between users for logistical, financial and administrative purpose.
To ensure the provision of need based customized delivery service such as facilitation of services to those with disabilities
To support with logistical requirement of digital navigation through location data for order pick up and drop offs. For calculation of Delivery parameters such as EPT, EDT, TSO, etc.
Enable dynamic pricing for CC-21 platform based on real-time factors such as estimated distance, system time requirement for delivery, address area classification, estimated time requirement for delivery, return factor, estimated traffic, users requesting or providing service, other service supplements /factor's ,etc.
Research and development work for analyzing and improving services and our business. We may also use your information for any other purpose disclosed to you at the time we collect those information or otherwise with your consent or as permitted by law.
To maintain compliance with legal and regulatory requirement that may necessitate us to process your relevant personal information.
To enforce compliance with our users terms and condition we may require to process your personal information by actively monitoring, investigating managing and reporting any violation and illicit or illegal activities on our services/ platform
Facilitate insurance, invoicing and vehicle finance solutions.
Perform necessary operations relating to maintenance of our services, trouble shoot software bugs and address other operational problem
To inform the users on any relevant changes to our terms, service, policies, recommendation, etc.
To create anonymous, aggregated, or de-identified data from your personal information by removing information that makes data identifiable to you. This data may be shared with third parties for our lawful business purpose including analysis for further improvement of services and business promotion.
When we no longer require the personal information we have collected about you, we shall either delete synonymize it or isolate it from further processing.
We may share your information with third party service providers that provide service on our behalf or help us operate the services or businesses. (for example hosting information, information technology, customer support, marketing, platform analytic, advertising partners, professional advisors, etc.)
We may share information with business transferees in business transactions for the purpose of negotiations or diligence for such transaction that may involve merger, consolidation, acquisition, reorganization, corporate divestiture. Sale or disposition of partial or complete business asset of or equity interests in Netspeq solutions Pty Ltd or our affiliates (also including proceedings related to bankruptcy or similar proceedings.
We shall make commercially reasonable efforts to verify that parties involved in information sharing and information processing by the application CC-21 provide a level of protection of personal information consistent with the practices described in this privacy policy, expect that all such parties described above other than the service provider and affiliates may to extent permitted by law use personal information as described in their own privacy policies.
Authorities and other such as law enforcement agency, government authorities, and private parties, in good faith or appropriate for compliance and protection purpose described above. This shall be based on Netspeq solutions Internal procedures for processing such request and shall ensure that any such data disclosure to the designated law enforcing agency or party is in the manner that is consistent with regulatory requirement of applicable law.
While you are using our services, we require to process your personal information such as your device information, activity information, and other relevant information for account and network security purposes. Such information may be required to combat spam, malware, Malicious activity, security risk, enforcement, and optimization of security measures, and for authorized access to your information. This may include features such as real time ID checks, use of biometric such as facial recognition, identification photographs, etc., object verification technology, age and image of government issued identification to verify eligibility to order ( link to recipient identification framework) , navigation and driving behavior of delivery personal to detect driving and delivery quality parameters and vehicle authorization, incident reporting (Link to incident reporting page) and other feedbak to encourage compliance to community guidelines,data review for the purpose of management and de-escalation’s of interpersonal conflicts between users while making delivery, user rating and review for management and monitoring for service delivery quality, etc.
Use of Cookies and other Tracking Technologies
First party and third party cookies along with other identification and tracking technologies such as web beacons, replay session, advertising technologies, mobile applications, etc. are used on our website and/ application, email and online adds from time to time to identify ,authenticate and to store your details about your use of website or application. As most browsers automatically accept cookies, the user has the option to reject the cookies by changing your browser setting. However kindly take a note that doing this might prevent you from taking full advantage of our website. These cookies are from time to time used to analyze website traffic and help us to provide better website visitor experience. In addition, it is also used to serve relevant adds to website visitors through third party services by provisioning analytic. Please see our cookie Notice for more information.
Data sharing and disclosure
Personal information is only supplied to and shared with and / between a third party and / system defined users and/ service providers and/ business partners when it is required for the delivery and/ administration of our services and businesses. Such information may be reasonably be disclosed to any of our employee,officers, insurers, professional advisers, agents, suppliers or subcontractor, service providers, or any legitimate third parties for the purpose as set out in this policy.(e.g. payment processors and facilitator)
background check and identity verification providers, cloud storage providers, google in connection with use of google map in CC-21 application (See googles privacy policy for information relating to their collection and use of data), advertising intermediaries, marketing partners, application safety and security service providers, consultants, professionals)
Personal information may be provided in response to request for personal data from law enforcement agency, government authorities, and private parties, in good faith or appropriate for compliance and protection purpose described above and/ legal reasons or event of disputes. This shall be based on Netspeq solutions Internal procedures for processing such request and shall ensure that any such data disclosure to the designated law enforcing agency is in the manner that is consistent with regulatory requirement of applicable law. For detail information see our guidelines for Law enforcement authorities and guideline for third party data request and service of legal document.
We may share information with business transferees in business transactions for the purpose of negotiations or diligence for such transaction that may involve merger, consolidation, acquisition, reorganization, corporate divestiture. Sale or disposition of partial or complete business asset of or equity interests in Netspeq solutions Pty Ltd or our affiliates (also including proceedings related to bankruptcy or similar proceedings).we reserve the rights to transfer to the extent permissible by law our users databases, together with any personal information, non-personal ,processed information, etc. as contained in those database.
We provide your personal information to group of companies (Entity that control or are under the control by Netspeq Solutions) for business purpose. These companies are required to comply to terms of this policy regarding their use of your information.
We may provide your information to third parties with your consent and directions
We may use your information to protect the copyright, trademarks, legal rights, property, or safety of Netspeq solutions.
In case of Emergencies and based on applicable law we may offer feature to share your personal details with emergencies services such as police, ambulance, fire. Please refer to “ Emergency data sharing”.
Security of Information
We are committed to ensuring that the information you provide to us is safeguarded and secure. we shall put in places suitable physical, electronic and managerial procedures to safeguard and secure information to avoid and / prevent misuse, interference, information modification, disclosures, loss, or unauthorized access. However, as no online activity is ever fully secure or error free, we cannot assure you that personal information we collect will not be disclosed in a manner that is inconsistent to privacy policy as the transmission and exchange of information sent to us or received from us is carried out at your own risk and we cannot grantee the security and accuracy of transmitted information.
Access to your Personal Information
You may request details of personal information that we hold about you in accordance with the provisions of Privacy Act 1988 (Cth). This may be subject to small administrative fee payable to us for provision of information. Any relating copy of information we hold about you or request to change any inaccurate, out of date, incomplete, irrelevant, misleading information we hold about you can be communicated to us at (web link add).However we reserve the right to refuse to provide you with information that we hold about you, in certain circumstance set out in the Privacy act.
Data Retention and deletion
Netspeq solutions shall retain your personal information for as long as your account is active with us or as needed to provide you with our services and/ for the purpose of maintaining the transaction records such as financial reporting and/ comply with our legal obligation and / to resolve dispute and/ to enforce agreements. The period for which data is retained will be determined by the necessity of data for purpose of safety, security, fraud prevention and for legal and regulatory requirements. Data retention may also consider some administrative factors relating to users account such as unresolved claim, transitional dispute, incomplete applications, rejected application, customer service communication.
User may request to delete their account at any time however kindly take notice that even after deletion of the user account we may retain certain category of data such as profile data, tax data, vehicle data, etc. due to legal and regulatory requirements or reasons stated in this policy. Subsequently Netspeq solutions may also aggregate and anonymize data and may retain aggregate and/ anonymize data indefinitely. Following a user account deletion request we shall delete the user account and data unless they must be retained for purposes mentioned above or till the applicability of statutory retention period after user account deletion period for instance for drivers their account and data is retained for 7 years after deletion request, for order recipients, their data is generally deleted within 90 days of deletion request until and unless retention is necessary for above reasons.
Children’s information
The services provided by Netspeq solutions, and its associates linked to this privacy policy is not intended for children under 13 years of age and no information for them is knowingly collected by us. If as a parent, you acknowledge that you child who is under 13 years of age has disclosed personal information to us please contact us at privacy@cc-21.com to review and request deletion of child personal information.
Referral program
Our service through the platform CC-21 is based on a cooperative revenue sharing and timeline based committed expenditure &/effort between users (Customers/ Delivery agent) (where such services is available) and conceptualizes on fundamental philosophy of give to get and associated aura of happiness build around it. Subject to user specific referral policies/ program users may require to grant access to their mobile device address book for directing us to send referral request to contact’s; the user selects in the user’s address book. However, if the user chooses to do so the user represents that they have in prior received the consent of the recipients &/ friend &/ referred. If you are referred or someone has attempted referring, you to one of our referral programs over the CC-21 platform we may share your personal data such as name and contact details upon appropriate requirement irrespective of your engagement status over the platform. Kindly take into notice that Netspeq Solutions does not control the timing, content, or recipients of the messages &/ communication &/ referral links. The users shall not send any referral emails, text message or other communication to children under the age of 13. In addition the user shall also not send, publish or share any false , misleading, or deceptive communication in connection with participation in the referral program.
Consequent to referral program, the user may require sharing the banking information with our payment gateway service provider to enable transfer, any revenue made in accordance to our revenue sharing referral policy/programs.
Complaint about Privacy Policy
If you have any complainants, questions or concerns about our Privacy Policy or practice, Please feel free to send in details to (Address ). your queries are taken up very seriously and will be responded after receiving written notice of your compliant. Alternatively, you can also contact us at privacy@cc-21.com We shall endeavor to respond to your queries/complaints as soon as possible. If your are dissatisfied with our response, you may have the right to make a compliant to the office of Australian information commissioner by phone 1300 363 992 or email enquiries@oaic.gov.au.
Changes & Update to Privacy Policies
As we shall evolve through the timeline our services, offer, guidelines and policies may change from time to time. Consequently, we reserve the right to modify or update this privacy policy at any time and from time to time without any prior notice. We shall notify you through appropriate communication channel. We also encourage users to periodically review these notices for the latest information. Subsequently use of services after an update shall constitute consent to updated notice to the extent permitted by law.
Your Choice and Transparency
The registered users of CC-21 shall be allowed to access, modify, delete, object to data usage, and/ request for data portability for certain personal information that we collect by logging into their account and by authenticating change procedures on their account page. This account page can also be used to manage their services preferences and subscriptions (edit preferences for privacy settings, device permission, in-app rating, marketing choices, notification, etc.) . Subsequently for complete access, modify, or deactivation of your account you will have to communicate to us at Privacy@CC-21.com.