Objective and Scope
PNN Digital (“we”, “us”, “our”, “PNN”, “PNN Digital”, “Primex Media Services Pvt Ltd”) values the trust placed in us by the data subject (“you”, “your”, “user”, “subscriber”). Therefore, we assure you that we follow the highest standards of privacy guidelines to protect the information you share with us.
By using PNN Digital (for example, when you register for an account, enter a contest or promotion, communicate with us, on our sites or applications or through social media), you agree to provide consent to our collection, use and sharing of your personal information as described in this policy. In some cases, particularly if you reside in a country governed by a data protection regulation, we may ask you to provide explicit consent to access our services before proceeding with further operations.
Suppose you are a traveller visiting various countries worldwide and avail of the platform’s services. In that case, we will determine your location using your IP address to determine the relevant PNN Digital services which should be offered to you. In the event IP detection fails, we will consider the last cached location as your current location to provide you with PNN Digital services, and the consents obtained at the time of registration in that location will be valid for processing of your personal information. We use third-party service providers to help us determine your location to provide you with appropriate content and services on our platform.
Upon implementation of GDPR, the existing user, in order to receive full-scale services as provided, will be required to opt-in, subscribe, and consent for the provision of services, failure to subscribe will deny the users access and full use of the services provided by the Primex Media Services Pvt Ltd.
Collection and Use of Personal Information
‘Personally Identifiable Information’ or ‘PII’ is defined as any information that identifies (whether directly or indirectly) to a particular individual or natural person, such as the individual’s name, postal address, email address, mobile number and any other specific identifier indicating to that particular person. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.
A. Information you provide to us
Information Collected at the Time of Registration
When you register using your web accounts like Facebook & Twitter, we retrieve the following information from your account(s) to continue interacting with you and providing you with the Services. Information that we collect include –
- User Name
- Email id
- Mobile number
- Public profile information – (Facebook & Twitter) Information collected under my profile section when a user has completed the registration:
- Date of Birth
- Profile picture upload
- Pin code
We may collect sensitive personal information when you provide feedback, report spam, participate in polls, surveys, contests etc., for the activity it is being collected. This information will only be captured if you have provided us with explicit consent.
Information collected when you use our Mobile Application
When you download our mobile application, we may collect, including but not limited to, the below information from you-
- Email ID
- Mobile number
- Location/IP address for geo-locating
- Device ID
- SMS for OTP
- Android Advertiser ID/ iDFA ID
Information you provide to us voluntarily
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the site, we may collect and store such information.
We may collect additional information at other times, including but not limited to when you provide feedback(s), modify your content or email preferences, respond to surveys, provide comments, or communicate with us. This information may include your name, email id, mobile number, location, etc.
B. Information automatically collected while browsing /navigating through the website
Do Not Track
The Website and PNN Digital currently do not process or respond to “Do Not Track” requests/signals that some internet browsers can send out.
Log File Information
We automatically collect limited information about your computer’s connection to the internet, mobile number, including your IP address, whenever you visit our website(s), application or services. Your IP address is a number that lets computers attached to the internet recognise where you send data – E.g. pages you viewed. We automatically receive and log information from your browser, including your IP address, computer’s name, operating system, browser type and version, CPU speed, and connection speed. We may also collect log information from your device, including your location, IP address, your device’s name, device’s serial number or unique identification number (e.g. UDID on your iOS device), your device operating system, browser type and version, application version, operator name, screen size, CPU speed, and connection speed etc.
We may use “clear GIFs” (Web Beacons) to track the online usage patterns of our users anonymously, without personally identifying the user. We may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by them. We use this information to inter-alia deliver our web pages to you upon request, to tailor our Website/Application or Services to suit the interests of our users, to measure traffic, to improve the quality, functionality and interactivity and to let the advertisers know the geographic locations from where our visitors come.
C. Inferred Information through usage and log data
We may track certain information about you based upon your behaviour on the PNN Digital network. We use this information to conduct internal research on our users’ demographics, devices, interests, and behaviour to better understand, protect, and serve our users.
We may also collect Your Information to track user behaviour and preferences for internal analytics and research. We may also use your information:
i. To evaluate your interest in various genres of content, services, offers;
ii. To perform analytics and conduct customer research to determine your interest, identify content that generates sales, and analyse traffic patterns. If you choose to post messages on social media accounts, message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
The above information may also be captured by keeping cookies on our websites by our affiliates for the purposes mentioned above.
D. Information we collect from third parties
Information obtained from other Sources
We may receive information about you from other online sources. We may add it to our account information system and treat it in accordance with this policy. If you provide information to the platform provider or other partner to whom we provide services, your account information, including PII, may be passed on to us. We may obtain updated contact information(s) from third parties in order to correct our records and fulfil the Services or to communicate with you or share the information with any third party.
Information obtained from third-party websites
If you link, connect or login to your PNN Digital account with third-party services, they may send us information such as your registered email id and public profile information from the service as stated below:
- Facebook – Email ID and public profile information, including name, profile picture, age, gender, etc.
- Twitter – Email ID, see who you follow, read tweets from the timeline, post tweet for you, access direct messages and update your profile
c) Demographic and other Information
We may reference other demographic and other information sources to provide you with more targeted communications and promotions. We use various third-party analytics service providers, among others, to track user behaviour on our website. They are used to support display advertising towards helping us gain an understanding of our users’ Demographics and Interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out or opt-in by consenting to serve you advertisements when you visit our website or applications.
d) Subscription or Paid service information
When you choose any subscription or paid service, we or our payment gateway provider may collect your personal information such as address or billing information, including your credit/debit card number and expiration date. The subscriptions or paid Services may be on auto renewal mode unless cancelled. If you do not wish to auto-renew your subscription at any point, you may cancel your subscription before the end of the subscription term or contact us on our support email.
*In case of sharing or referring the subscription to another user, then the personal information of the referrer will only be used for the purpose for which they have shared it. Other than the purpose, we won’t provide or process the referral’s personal information for analytics, direct marketing etc., without prior consent provided by the referral to receive such services from us.
e) Transactional and Billing Information
Based on your purchase of a subscription or paid service, our payment gateway partner may collect information, including but not limited to your credit/debit card details or other bank account details, along with your billing address. The payment gateway partner stores this information. For instance, the Services will be using third party payment gateway partners to process and facilitate the payment of your subscription fee to the Services for providing you access to the subscription; we do not control such payment gateway partners. When you visit such payment gateways, you do so at your own risk. We encourage you to familiarise yourself with the privacy statements provided by such payment gateways before providing them with information about you or entering into any transactions with them. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them.
We may receive financial or transactional information (e.g., transaction ID, order ID, etc.) from third party vendors in case of payments, for reconciliation and validation of transactions, and the purpose of resolutions of complaints (in case of failed transactions and refunds).
Disclosure to Third-parties
a) Service Providers
b) Promotional Offers
We may share or disclose your personal information outside of PNN Digital when you consent to provide SMS and Email related services such as marketing newsletters, promotions, and offers.
We do not provide any personally identifiable information to third party websites/advertisers / ad-servers without your explicit consent.
In the event PNN Digital is merged with or acquired by another company or in case of re-organisation or re-structuring of business, we and our affiliates may share your personal information, wholly or in part, with another business entity.
e) Business transfers
Information we share with our group companies/affiliates
When you interact with the PNN Digital Website (such as following articles, following other users, following activities, etc.), we will collect your following activities and create a profile against those activities for you to refer to later and review articles of your activities. Primex Media Services Pvt Ltd doesn’t collect any additional personal information but only tracks your behaviour on various Primex Media Services Pvt Ltd websites and the activities you choose to follow or the users you wish to follow. Any comments, views, and shares you perform on the PNN Digital Website will be publicly available.
Usage of our Mobile Applications
This policy shall also apply to our Mobile Applications available in the country governed by a data protection regulation. These Mobile applications have been updated to make them compliant with the country-governed data protection regulations. Few of the services have been discontinued in certain platforms in the country governed by data protection regulations. You are urged to update to the most current version of certain apps listed and/or delete certain apps that we no longer provide access, service or support so that we do not collect or store user information in the country governed by a data protection regulation. If you use an older version of these apps and/or access discontinued services, then we may collect, store and process your information. In such case, we would not be responsible or liable for such collection, storage and processing of your data.
Purposes and Lawfulness of Processing
We will only collect and process personal data about you on a lawful basis. The lawful basis on which we would process your personal information includes obtaining explicit consent from you for processing your personal information or processing for “legitimate interests” where processing is necessary by us to provide you with services (E.g. processing your information by our group companies/affiliates).
We use the information to provide, analyse, administer, enhance, and personalise our service and marketing efforts, process your registration, provide you services, and communicate with you related to the below-mentioned points. For example, we use the information to:
- Analyse and understand our audience to improve our service (including our user interface experiences), recommendation algorithms and delivery, which may require sharing personal information with our group companies and affiliates or third-party service providers.
- To help advertisers understand our audience and confirm the value of advertising on our websites or Applications (however, it is usually in the form of aggregated statistics on traffic to various pages within our site) and provide you with relevant ads.
- To help advertisers understand our audience and confirm the value of advertising on our websites or Applications (however, it is usually in the form of aggregated statistics on traffic to various pages within our site) and provide you with relevant ads.
- Allow you to participate in interactive features offered through our Services.
- Sharing with our customer support team to resolve your queries/concerns related to your rights or services provided to you.
How your information is used for Advertising
We use third-party advertising companies to serve ads when you visit or use our website, mobile application or services. These companies may use information (not including your name, address, email address or telephone number or other personally identifiable information) about your visits or use of a particular website, mobile application, or service to provide advertisements about goods and services of interest to you.
Presentation of Information to our advertisers to help them understand our audience(s) and know the value of advertising on our websites or applications is usually in the form of aggregated statistics on traffic to various pages/content within our websites or Applications.
We do not provide any personally identifiable information to any third-party websites/advertisers/ad-servers without obtaining your consent.
Information Use by the Company
The information supplied by you enables us to improve our services and provide you with the most user-friendly experience(s). In some cases, e.g. provision of certain service(s) or utility (ies), we may also require your contact information. All required information is service-dependent. The Company may use the above-said user information to maintain, protect, and improve the Services (including advertising on the “Application”) and develop new services. We may also use your email address or other personally identifiable information to send commercial or marketing messages with your consent [with an option to withdraw your consent (wherever feasible)]. Any personally identifiable information you provide will not be considered sensitive if it is freely available and/or accessible in the public domain, like any comments, messages, blogs, or scribbles available on social platforms like Facebook, Twitter, etc.
When you register with the Application or Services, we may contact you from time to time about updating your personal information to provide you with features that we believe may benefit/interest you.
Information sharing with third parties
The Company shares your information with any third parties without obtaining the prior consent of the user in the following limited circumstances:
a) When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or the prevention, detection, investigation including cyber incidents, or prosecution and punishment of offences. These disclosures are made in good faith and the belief that such disclosure is reasonably necessary for enforcing these Terms or complying with applicable laws and regulations.
c) The Company may present information to our advertisers – to help them understand our audience and confirm the value of advertising on our websites or Applications – however, it is usually in the form of aggregated statistics on traffic to various pages within our site.
d) The Company may share your information regarding your activities on websites or Applications with third-party comments sites social websites to populate your social wall that is visible to other people; however, you will have the option to set your privacy settings, where you can decide what you would like to share or not to share with others.
How long do we store and use your information?
We retain the information which we have collected no longer than is necessary. It is determined on a case-by-case basis. Normally, we will retain the information as long as you maintain an account with us and till the time you continue to access and use PNN Digital and its services. We will delete your information whenever you request us to do so. However, we may archive and/or retain some information for legal purposes.
Your Controls and Choices
A. Accessing and Rectifying your personal information
When you use the Services Website/application (or any of its sub-sites), we make reasonable faith efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. We ask individual users to identify themselves and the information requested to be accessed or corrected before processing such requests. We may decline to process unreasonable, repetitive or systematic requests, requiring disproportionate technical effort, jeopardising the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
You can make access requests by sending an email to our Grievance Officer. You will get a link on your registered Email address through which you can access all the data PNN Digital collects and stores about you. You can ask us to correct inaccurate or incomplete personal information.
- Concerning your login credentials by editing the same through the My Accounts section through the SSO portal. The same shall be reflected across all properties.
- Concerning details that are separately collected and maintained by PNN Digital by sending an email to our support team to perform the rectification.
B. Data Portability
You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, wherever feasible.
C. Data Retention and Erasure
We retain your personal information as long as necessary to provide services to you, or you ask us not to retain your data. If you no longer want us to use your information, you can request that we erase your personal information and close your PNN Digital account. Please note that if you request the erasure of your personal information,
- The personal information (Name, Email, Mobile No) will be retained as a part of the SSO Login functionality and will be governed by the SSO Login Policy.
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, suppose we suspend a PNN Digital account for fraud or safety reasons. In that case, we may retain certain information from that account to prevent that user from opening a new account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on Primex Media Services Pvt Ltd, even after your account is cancelled. However, the attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database but are disassociated from personal identifiers.
- Because of the way we maintain certain services after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
Please note that if you have multiple accounts with us, then you will have to raise separate requests for each of the accounts, along with the associated email IDs or phone numbers.
D. Withdrawing Consent and Restriction of Processing
For withdrawing your consent at any time during the tenure of your services with us, you may choose to do so by sending us an email. We shall review your request and may ask you to verify your identity. Post verification, we will withdraw the consent for which you made a request and stop any further processing of your personal information
You can write to us in case of any grievance or complaint at the support email address. If you have any complaints regarding processing of your personal information, you may contact our data protection officer at the email address below. You have the right to complain about the data processing activities carried out by PNN Digital before the competent data protection authorities.
F. Objection to Processing
Where your personal information is processed for direct marketing purposes or any contests or promotions, or other services, you may, at any time, ask us to cease processing your data for these direct marketing purposes by sending an email to us.
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences and services to you. Some of our services may not be able to take into account your interests and preferences. If collecting personal information is mandatory, we will make that clear at the point of collection so that you can decide whether to participate. If you have questions about the specific personal information that we process or retain and your rights regarding that personal information, please contact us at the email address below.
We may take 30 days from the date of receipt of a request to complete your requests. However, if the requests’ nature is excessive or would require significant effort, then we may ask for an extension of 60 days by giving prior notice to you with the reason for the extension.
We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests. We may decline to process unreasonable, repetitive or systematic requests, require disproportionate technical effort, jeopardise the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
PNN Digital is not intentionally designed for or directed at persons less than 16 years of age. PNN Digital does not knowingly permit any person under 16 years of age to register with the services or provide any other personally identifying information. Suppose PNN Digital becomes aware that any personally identifiable information of persons less than 16 years of age has been collected on PNN Digital without verified parental consent. In that case, PNN Digital will take the appropriate steps to delete any such information and notify the parent. However, we consider it the responsibility of parents to monitor their children’s use of our services.
Nevertheless, it is our policy not to collect and process any personal information from children below 16 years of age or offer to send any promotional materials to persons in that category. PNN Digital does not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided PNN Digital with personal information without their prior consent, please contact our customer support team to ensure that the personal information is removed from Primex Media Services Pvt Ltd.
Data transfer, storage & processing globally
Security and Compliance with Laws
We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure, or data destruction. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorised access to systems where we store personal data. All information gathered is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall on the cloud; server access is password-protected and strictly limited. However, as effective as our security measures are, no security system is impenetrable. If you know or have reason to believe that your PNN Digital account credentials have been lost, stolen, altered, or otherwise compromised, or in case of any actual or suspected unauthorised use of your account, please contact us by contacting our customer support team.
Changes in the Policy
II. Data Protection Officer/Data Controller
The data protection officer (DPO) and data controller appointed by Primex Media Services Pvt Ltd is Mr. Anand Mishra, who can be contacted at firstname.lastname@example.org
You can also write to:
Registered office address:
101-A, Cannal Walkk Shoppers,
RCC Canal Road, VIP Road,
Vesu-Bharthana, Surat – 395007