Policy Effective Date: 31/01/2024
Introduction
BookIT Digital Technologies Pvt. Ltd. (“BookIT”, “us”, “we”) helps organizations from across the world achieve their business goals through its learning content, digital marketing, and technology services. We design and build our solutions on core principles of innovation, end-user experience, and customer satisfaction, such that they work across traditional and newer mobile platforms, formats, and devices to deliver and manage highly compelling and engaging digital content.
This Privacy Policy describes how BookIT collects, uses, and discloses information, and what choices you have concerning your information. You hereby expressly consent to the processing of your personal information in accordance with this Privacy Policy. Your personal information may be stored, processed, or transmitted in India or any other part of the world, where laws regarding storing, processing, or transmitting personal information may be less restrictive than the laws in your country. If you do not agree to the terms of this Privacy Policy, please do not use, or access the Services.
Services
It is BookIT’s policy to respect your privacy regarding any information we may collect while you use or access our software applications and websites.
This Privacy Policy applies to your use and access to the software, applications, products, and/or services offered by BookIT (which includes BookIT’s websites, stores, e-reader apps, digital contents, etc.), each as defined/described in BookIT’s ‘Terms of Service’ available at www.kitaboo.com/terms-and-conditions/
BookIT operates web-based applications such as Kitaboo and ePub3Automation, which are part of our services. These products are offered through the domain www.kitaboo.com. All such products, applications, and websites are collectively called “Services”.
This Privacy Policy applies when you use and/or access our Services. A link to this privacy policy is also available in “the application” for our customers and their end customers.
Acceptance
This document is an electronic record in terms of the Information Technology Act, 2000 and the rules framed thereunder, as applicable and amended from time to time, about electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
Data Controller/Data Fiduciary and Data Processor
We process two main types of personal data.
Our Customers are the Data Controller (for the EU region)/ Data Fiduciary (for the India region) of ‘Customer Data’. BookIT is the processor of ‘Customer Data’ and the controller/fiduciary of ‘Other Data’.
Domains and Websites for this Policy
For this Policy, the term, “Websites”, shall refer collectively to www.kitaboo.com, www.kitaboo.com as well as the other websites that the BookIT Group operates and that link to this Policy.
Information We Collect
Customer Data that you provide
As customers, you provide data to us for processing as part of the usage of our BookIT applications.
‘Customer Data’ may be processed by us as a result of the customer’s use of the Services when our customers, or their end-users, input or upload information into the Service. For example, customers who use our Kitaboo application may upload ‘Customer Data’ about themselves or their employees, institutional partners, or schools.
If you are a school, you should contact your publisher about their privacy practices. If you are a school student, you should contact your school or teacher to understand your school’s privacy practices.
Other Data that we collect
BookIT also collects data when you use our Websites, Social Media, Blogs, and applications:
Website Visitor Data
Data from Others
User registration services that you use
You may also use third-party registration services or applications to sign up with Kitaboo. We then get data from these applications.
Google Analytics
We currently use Google Analytics to collect information anonymously and report website trends without identifying individual visitors.
As our customer, you have the option to decide if the following personal data can be captured by Google Analytics:
We use Google Analytics for analytics and measurement to understand how our services are used. For example, we analyse data about your visits to our sites to do things like optimise product design.
Cookies
We collect data through cookies.
BookIT uses cookies to help BookIT identify and track visitors, their usage of the BookIT website, and their website access preferences. We may also use navigational data like Uniform Resource Locators (URLs) on our products and services to gather and store information about your activities relating to our products and services. If cookies or Flash cookies are disabled, then certain areas of our products and services may not work properly.
BookIT visitors can control cookies through your browser settings. You have the option of blocking or not allowing cookies, which is provided for by our cookie banner asking you which type of cookie you wish to enable.
For more details about how we use these technologies, please see our Cookie Policy.
How We Use Your Data
How we use your personal data will depend on which Services you use and how you use those Services.
Customer Data will be used by BookIT by Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. BookIT is a processor of Customer Data and Customer is the controller/fiduciary.
Other Data is used by us to provide our services, send our newsletters, send promotional material, and communicate with you by responding to your requests, comments, and questions.
Lawful bases for processing
We have lawful bases to process your personal data. We also use your consent to lawfully process your personal data.
We process your personal data only when we have a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the EU General Data Protection Regulations. If you believe certain services are not in your interest, you have a right to object.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Also, as provided under India’s Digital Personal Data Protection Act, we use your consent as a basis for processing your personal data. In some cases, we may also have a Certain Legitimate Interest to lawfully process the personal data.
Where you have consented to a particular processing, you have a right to withdraw the consent at any time by sending an email to our product support team at gdpr.compliance@kitaboo.com.
How we use Customer data
We use your data to authenticate you and authorize access to our services.
We only process Customer Data on behalf of our customers and in accordance with their instructions provided in the applicable Services agreement with us. We use the data that we have about you to provide our services and provide support to you. In each case, BookIT collects such information only in so far as is necessary or appropriate to fulfil the purpose of the interaction with our services.
How we use Other data
We may set up product demos or send you marketing / promotional materials. You may choose to restrict the collection or use of your personal information
We will update you with improvements in our services, and new features and from time to time also carry out direct marketing of our products and services. Direct marketing is carried out only if you consent to receiving such communications from us.
We also send invitations to our events or conferences.
Users under 16 years of age
The Sites and Services do not knowingly collect personal information from users under the age of 16 as per the EU region and the age of 18 as per India region.
If you are under the age of 16 as per the EU region and the age of 18 as per India region, you are not permitted to use the Sites and Services except as an end-user student.
Data Retention Policy
We will retain your personal information for as long as is needed to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
Customer Data – We retain your information for as long as you have an active Services account. We may also retain your personal information for an extended period under applicable statutory laws.
BookIT will retain Customer Data by a Customer’s instructions, including any applicable terms in the Customer Agreement, or for two years if there are no such instructions, and as required by applicable law. When you decide to close your account, we delete all personal information about you including any user-generated content save and except the personal information required to be retained under applicable law and order.
Other Data – We retain your information for as long as necessary for the purposes that we have described in this Privacy Policy.
BookIT may retain Other Information about you for as long as necessary for the purposes described in this Privacy Policy.
Your Rights
You can request to access, update or correct your personal information. You also have the right to object to direct marketing.
For all requests relating to your rights, you can contact us at “gdpr.compliance@kitaboo.com.”
You may have additional rights under your local law applicable to the processing.
For example, if the processing of your personal information is subject to the GDPR, and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation.
Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.
Customer’s Rights to Control Data based on Jurisdiction:
For EEA (“European Economic Area”) Users
Whenever you use our services, we aim to provide you with easy means to access, modify, delete, object to or restrict the use of your personal information.
We strive to give you ways to access, update/modify your data quickly or to delete it unless we have to keep that information for legal purposes. Some rights can be accessed from within the BookIT application. For visitors, these rights can be exercised by contacting us with your specific request.
For India Users
Account Closure
We keep some personal data even after account closure.
Once you choose to close your account, we generally delete your personal information within 30 days of the closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, and invoicing data will be retained as necessary.
Your information shared with others
Recipients of your data
Your data will be shared with other recipients to provide you with services.
While we aim to limit the sharing of your data, at times, it is necessary to share your data with certain service providers. Examples of when and for what purpose your data is shared include data centre/hosting services, email marketing services, etc.
The following categories of recipients will most likely receive your data for us to provide services to you:
To comply with laws. If we receive a request for information, we may disclose if we reasonably believe disclosure is by or required by any applicable law, regulation or legal process.
Customer Profiles
Your data that is publicly accessible may be seen by others.
Your username, public profile information, and public content may be seen by other users of our products and services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
BookIT may share information as per the terms of this Privacy Policy; however, BookIT shall endeavour that such use of information does not create hindrance to your use of the Website.
BookIT may disclose your information to third parties if it determines that such disclosure is reasonably necessary to: (a) comply with the laws; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of its name, brands, trademarks or such other rights belonging to it or its other users; or (d) protect its rights.
Stewardship of your data is critical to BookIT and a responsibility that BookIT embraces. BookIT believes that its users’ data should receive the same legal protections regardless of whether it’s stored on its servers or your home computer systems or devices. BookIT will abide by the following principles when receiving, scrutinizing, and responding to government requests for its users’ data:
Cross-Border Data Transfers
Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region and India Region. Your data will be processed within Third Party Data Centers in the USA, India, and Germany. Data of our customers operating from the European Union and the United Kingdom is located in Frankfurt, Germany. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer which you hereby agree and acknowledge.
BookIT offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between BookIT and its Clients, suppliers, or data processors outside the EU), binding them to protect the privacy and security of the data.
Security Measures to Protect Your Data
Security Measures
We implement security controls to prevent breaches and unauthorised access to your data. We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access controls, encryption, HTTPS, restricted access to data, monitoring for threats and vulnerabilities, etc.
We also subject our services to internationally recognised certification and attestation standards.
Protection of personal information
Our Sites and Services use commercial efforts to maintain safeguards for the protection of your Personal Information. BookIT takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally identifying and personally-identifying information.
However, no method of transmission over the internet, or method of electronic storage, is 100% secure so BookIT cannot fully ensure or guarantee the security of any information you transmit to BookIT or guarantee that information on the Website may not be accessed, disclosed, altered, or destroyed by any person.
Other Information
Contact Information
You can contact us about this privacy policy or use of our services.
If you have questions or complaints regarding this Policy, you may contact us through email at gdpr.compliance@kitaboo.com. You may contact us at our mailing address below:
BOOKIT DIGITAL TECHNOLOGIES PRIVATE LIMITED
SF-B-01, ART GUILD HOUSE
WING B, PHONEIX MARKET CITY COMPLEX,
KAMANI JUNCTION,
LBS MARG, KURLA
Mumbai, Maharashtra 400 070, IN
Privacy policy change:
BookIT may change this Privacy Policy from time to time, at our sole discretion.
BookIT encourages visitors and customers to frequently check this page for any changes to its Privacy Policy. We will notify you of material changes in advance by email or by notice when you log in to the Sites and Services or both. You confirm that your continued use of our services after any change in this Privacy Policy will constitute your acceptance of such changes and agree to be subject to the revised privacy policy.
We often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.