1. Background

1.1 Real Variable (“Company”) is an information technology company which supports its customers with providing its products, platforms and services with respect to various digital platforms (“Products and Services”).

2. Applicability


2.2 "Personal information" means any information that relates to a natural person, 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, which without limitation includes name, date of birth, gender, mobile number, email address, address, et cetera.

2.3 “Sensitive personal data or information” means such data or information which consists of information relating to, (i) password; (ii) financial information such as Bank account or credit card or debit card or other payment instrument details ; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) Biometric information; (vii) any detail relating to the above as provided to the Company for providing Products and Services; and (viii) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise.

(For the purposes of this Policy the "Personal information" and “Sensitive personal data or information” shall be collectively be referred to as “Information” or “Data” and may used interchangeably.)

2.4 Any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Data or Information for the purposes of the laws in India.

2.5 When you visit our Website, we collect some information related to your system, device, your browser and the way you navigate our content, upon the consent being provided by you. This information helps us enhance our user experience of our Website.

2.6 The information so collected from you shall be handled and secured in accordance with the Information Technology Act, 2000 read with Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 and The Aadhaar Act, 2016, and such other law that may be applicable from time to time.

3. Consent for use of Website

3.1 This Website does not store or capture your Information unless you are registered with us.

3.2 In order to avail Products and Services offered by our Company, you may register with us and provide your express consent by clicking on the ‘CONSENT’ button in order the Company may collect, process, store, share and purge the Information submitted by you, failing which you will be unable to avail the Products and Services offered on the Website.

4. Collection and use of Information

4.1 We receive and maintain this information on your behalf in order to provide our Products and Services, and we do not use such information for any other purpose except as set out herein, or as directed by you, or as otherwise required or permitted by applicable law.

4.2 While we assure you that it will do our best to ensure the privacy and security of your Personal Information, we shall not be responsible in any manner whatsoever for any violation or misuse of your Personal Information by unauthorised persons despite having taken all measures prescribed under law.

4.3 By accessing and using this Website, you hereby consent to the collection, use and disclosure of information for the purposes of availing the Products and Services as provided by the Company.

5. Storage and purging of Information

5.1 We store and maintain your Personal Information as long as it is required for processing your request and as permitted by law in this regard. In the event, we are not in a position to process the Personal Information submitted by you in furtherance to the Products and Services, the same shall be deleted immediately, unless is required by us to do so under law and/or as may be required for any internal or external audit purposes.

5.2 Any data destroyed shall be purged in a manner that protects the privacy of the Information received by us in an appropriate manner as per the industry standard practices and norms, in compliance with the law in force at the time in India.

6. Sharing of the collected information

6.1 We shall not transfer the Information provided by you to, (a) any third parties unless it is required to do so in furtherance to providing the Products and Services under this Agreement and/or, (b) government agency unless we are required or entitled to do so pursuant to any legal requirement.

6.2 We shall share the information, so collected, strictly on “Need to Know” basis, only for the limited purposes set out for providing the Products and Services under the Website.

6.3 If required, the Personal Information so received from you may be shared with any third party with your consent.

7. Data Security

7.1 We shall make all reasonable efforts to protect your Information with all reasonable security measures as prescribed under law including a variety of security technologies and procedures to help protect such Information from any unauthorized access, loss, use or disclosure.

7.2 We shall endeavour to take reasonable measures to prevent unauthorized access to and improper use of your Personal Information submitted to us by you. We shall adopt all the suitable measures to diagnose any problems with our server and to administer this Website including by blocking certain addresses that it feels are inappropriately using this Website. In the event of any breach or attempted breach by any third party, in compliance with the applicable information technology laws, we will try to rectify the problems as soon as possible.

7.3 We are committed to providing you safe and secure environment for ensuring that the Information is processed in line with the reasonable security standards prescribed under law. In view thereof, in furtherance to providing the Products and Services we shall be entitled to collect following information:

a) We collect anonymous data from every visitor of the Website to monitor traffic and fix bugs which includes (without limitation) information like web requests, the data sent in response to such requests, the Internet Protocol address, the browser type, the browser language, unique identifiers of the device through which the Website is accessed, such as VPN, information of wifi connectivity and a timestamp for the request.

b) Log file information is automatically reported by your browser each time the Website is viewed. When a user registers information with the Website, its servers automatically record certain information sent by the web browser whenever such user visits the Website. These server logs may include information such as web request, Internet Protocol (IP) address, Analytical Code, Geo Stamp, browser type, browser language, referring/exit pages and Universal Resource Locators (URL), platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular page, the date and time of the request (“Log File Information”). Such Log File Information collected is not associated with any Personal Information and is only tagged to the unique identifier for a particular device.

8. Use of Cookies

8.1 A cookie is a piece of software code that an internet web site sends to your browser when you access information at that site. You may opt-out of collection and usage of data through cookies by changing your settings on your browser. It is generally used for small text files which a Website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site, allow a site to track usage behaviour and compile aggregate data that will allow content improvements, et cetera.

8.2 You are requested to note that certain information may be automatically collected through the standard operations of our internet Products and Services or through the use of ‘cookies’.

8.3 These cookies themselves do not personally identify you, but they do identify your computer. You can erase or block this information by changing the settings on your computer. If you do erase or block this information you may not be able to utilise some features of the Website.

9. Link to other sites

9.1 For your convenience, this page may contain certain hyperlinks to other sites. While we try to link only those Websites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other Websites, and we do not necessarily endorse the views expressed by such third-party Websites. Mere presence of the link or its listing on this Website should not be assumed as endorsement of any kind. We cannot guarantee that these links will work all the time and we have no control over the availability of such linked pages. We recommend that you check the policy of each Website you visit and contact the owner or operator of such Website if you have any concerns or questions.

9.2 You are requested to note that we shall be not be responsible towards any information or document that is submitted by you by accessing such third-party Websites and/or by clicking on such hyperlinks. The Privacy Policy governing this Website shall not be applicable to these third-party Websites.

10. Modification or changes in the policy

10.1 We reserve the right to change this Policy at any time. If we decide to change this Policy, such changes will be posted on this page. You may note that this Privacy Policy itself and any such modification or change in the Policy may be effective from the date announced by us and not from the date of posting on the site.

10.2 This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in favour of any user or viewer or on behalf of any other party.

11. Usage by children and minors

11.1 This Website is not intended for providing any Products and Services for use of children and minors. Parents are requested to ensure that Personal Information is not provided by minors on this Website. However, this does not intend to prohibit information on minors and children being provided by the parents with respect to any Service offered by this Website or any other third party permitted to offer any service on its Website, which are beneficial to or are designed for the benefit of children and minors.

12. Limitation of Liability

12.1 The Company shall in no event be liable for any damages, including without limitation, direct or indirect, special, incidental, or consequential damages, losses or expenses arising in connection with this Website or any linked third-party Website, or use thereof, or inability to use by any user, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation of transmission, computer virus, or line or system failure.

13. Governing Law

13.1 The use of Products and Services on this Website shall be governed by the laws of India, and the Courts of Telangana, India, shall have exclusive jurisdiction on any disputes arising out of such use of the Website.

14. Contact Us

14.1 In the event of any query or clarification you are requested to reach out to us at reachus@realvariable.com

14.2 In the event of any grievance relating to the Products and Services you are requested to reach out to us at reachus@realvariable.com

14.3 In the event of any grievance relating to the Privacy relating to the Information so shared with us you are requested to reach out to our Data Privacy Officer at reachus@realvariable.com

14.4 In the event you are not satisfied with the resolution provided by us, they you may escalate your grievance by writing to the Grievance Redressal Officer at reachus@realvariable.com.