This privacy policy (“Policy”) was last updated on January 8th, 2024. We may change or update this policy at any time, and the same will be updated here. If you are an Astuto user or customer, we shall notify you of the changes or updates by sending an email. Please ensure to read such notices carefully.
We sincerely believe that you should always know what data we collect from you, the purposes for which such data is used, and that you should have the ability to make informed decisions about what you want to share with us.
Therefore, we want to be transparent about:
(i) how and why we collect, store and use your data in the various capacities in which you interact with us; and
(ii) the rights that you must determine the contours of this interaction.
While we would strongly advise you to read the Policy in full, the following summary will give you a snapshot of the salient points covered herein:
If you have any queries or concerns with this Policy, please contact our Grievance Officer (refer Section 12). If you do not agree with the Policy, we would advise you to not visit/use the Website or write to us at
FOR THE AVOIDANCE OF ANY DOUBT, WE SHOULD CLARIFY THAT IN THE EVENT WE ANONYMIZE AND AGGREGATE INFORMATION COLLECTED FROM YOU, WE WILL BE ENTITLED TO USE SUCH ANONYMIZED DATA FREELY, WITHOUT ANY RESTRICTIONS OTHER THAN THOSE SET OUT UNDER APPLICABLE LAW.
Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time, by reaching out to us.
It might have come to your attention that a new law was passed in the European Union (EU) called the General Data Protection Regulation (GDPR). The GDPR gives certain rights to individuals who are EU data subjects, in relation to their personal data.
Subject to the GDPR and applicable law’s limitations, the rights afforded to you if you are an EU data subject are:
In case you want to exercise the rights set out above you can contact our Grievance Officer whose details are set out in Section 12 below.
The data provided by you as a Visitor, or when you sign up as a Customer / User or register for our Services will be processed by us for the purpose of rendering Services to you or in order to take steps prior to rendering such Services, at your request. Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time. Additionally, we may process your data to serve legitimate interests.
Accordingly, the grounds on which we can engage in processing are as follows:
If you believe we have used your personal data in violation of the rights above or have not responded to your objections, you may lodge a complaint with your local supervisory authority.
Additionally, please note:
Astuto complies with CCPA by giving you the five privacy rights for California consumers:
In case you want to exercise the rights set out above you can contact our Grievance Officer whose details are set out in Section 12 below.
We will store any personal data we collect from you as long as it is necessary in order to facilitate your use of the Services and for ancillary legitimate and essential business purposes – these include, without limitation, for improving our Services, attending to technical issues, and dealing with disputes.
We may need to retain your personal data even if you seek deletion thereof, if it is needed to comply with our legal obligations, resolve disputes and enforce our agreements.
If you are a Customer, please be advised that:
(i) you will need to inform your Leads about how you store and deal with any data you collect from them using one of our Services, in compliance with applicable laws including the GDPR; and
(ii) after you terminate your usage of a Service, we may, unless legally prohibited, delete all data provided or collected by you (including Lead information) from our servers.
Upon receiving your specific consent, we may share the data we collect from Cookies or Web Beacons with our advertisement partners to track your visits, establish your non-personal identity and present you with targeted advertisements about our Services.
If you are a customer, you are empowered to use proprietary or other third-party technologies (for example Flash Cookies) on your website and host them in our App. If you do, you agree and acknowledge that it is your sole obligation to inform your Leads about any data you collect by using such technologies and the policies by which such collection is bound.
As a business service, we neither target our Services toward nor knowingly collect any personal information from any individuals under the age of 13.
In order for us to facilitate our global operations, we may transfer and access the data we collect and process in accordance with this Policy, to our group companies around the world. Your rights and protections will, under no circumstances, be diluted by this transfer.
Further, in the ordinary course of business, we may employ other companies and people to assist us in providing certain components of our Services in compliance with the provisions of this Policy. To do so, we may need to share your data with them.
Where applicable – if the entities to which these transfers are affected are not situated in countries deemed ‘adequate’ by the European Commission, we shall enter appropriate Data Protection Addendums with the transferee parties that comprehensively protect your data. We shall also put in place industry-standard technical and organizational measures (including robust data handling policies) to ensure that such transfers are completed in accordance with applicable laws.
Some of the examples of where we may subcontract processing activities to third parties include—data analysis, marketing assistance, processing credit card payments, and providing customer service.
We may display links to third-party websites or applications on our website or App for advertising or providing you with relevant content. We will not be responsible for such third-party websites or applications if you choose to access them. If you provide any data to such website/application, please ensure you read their policies given that you will no longer be bound by this Policy in doing so.
In addition to the purposes set out in the Policy, we may disclose any data we collected or processed from you if it is required:
To protect our safety, your safety or the safety of others or in the legitimate interest of any party in the context of national security, law enforcement, litigation, criminal investigation or to prevent death or imminent bodily harm;
We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your data from unauthorized access, use, loss, destruction or disclosure. When we collect particularly sensitive data (such as a credit card number or your geo-location), it is encrypted using industry-standard cry
Your password is your first line of defense once you set up an Astuto account, so we recommend that you set a strong password that you never share with anyone and ensure you sign out of our Astuto account once you have used that same.ptographic techniques including but not limited to SSL, TLS, RSA, and AES.
The name and contact details of our Grievance Officer, who you may contact if you have any concerns, complaints or feedback pertaining to this Policy, are as follows:
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
