Privacy Policy

1. Introduction

Jumbaya Talesfarm Private Limited (“us”, “we”, or “our”) operates a website https://www.jumbaya.com and Jumbaya mobile application (hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to our website and/or use of Services, and explains how we collect, safeguard and disclose information that results from your use of our Service.

We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Our Terms of Service found on https://www.jumbaya.com/terms-of-service (“Terms”) govern all use of our Service and together with this Privacy Policy constitutes your agreement with us (“Agreement”) and shall be read in compliance with the following:

1. The Information Technology Act, 2000;
2. The Information Technology (Reasonable Security Practices and Procedures and Personal Information) Rules, 2011;
3. The Information Technology (Intermediaries Guidelines) Rules, 2011;
4. Any other applicable laws.

2. Definitions

2.1  “Cookies”means small files stored on your device (computer or mobile device);

2.2  “Data Controller” means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data;

2.3  “Data Processors” or “Service Provider” means any natural or legal person who processes the data on behalf of the Data Controller.  We may use the services of various Service Providers in order to process your data more effectively;

2.4  “Data Subject” is any living individual who is the subject of Personal Data;

2.5  “Location Data”has the meaning ascribed to it in Clause 4.3;

2.6  “Personal Data” means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession);

2.7  “Service” means the website https://www.jumbaya.com and Jumbaya mobile application operated by the Company;

2.8  “Usage Data” means data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit); and

2.9  “User(s)” means the person(s) using our Service and who corresponds to the Data Subject, which is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4. Types of Data Collected

4.1  Personal Data

4.1.1  While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”).Personally identifiable information may include, but is not limited to:

1. First name and last name;
2. Contact Details (permanent address, correspondence address, email ID, mobile no. and any other similar personal identifiers.);
3. Age, gender and other demographics;
4. Date of birth, nationality;
5. Information you provide about your child, including age or grade and a name (or nickname) for your child’s profile. We do not collect this information directly from child users.
6. Financial information (like debit/credit card details, banking details, etc.), if applicable
7. Cookies and Usage Data; and
8. Other information you upload and/or provide to us.

4.1.2  You represent to us that the information or data you provide to us on the website from time to time is and shall be correct, current and updated and you have all the rights, permissions and consents to provide such information or data to us. Your providing the information or data to us and our consequent storage, collection, usage, transfer, access or processing of the same shall not be in violation of any third party agreement, laws, charter documents, judgments, orders and decrees.

4.1.3  We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that maybe of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or by emailing at support@jumbaya.com (“Customer Support Email”).

4.2  Usage Data

4.2.1  We may also collect information that yourbrowser sends whenever you visit our Service or when you access and use ourService.

4.2.2  This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

4.2.3  When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

4.3  Location Data

4.3.1  We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.

4.3.2  You can enable or disable location services when you use our Service at any time by way of your device settings.

4.4  Tracking Cookies Data

4.4.1  We use cookies and similar tracking technologies totrack the activity on our Service and we hold certain information.

4.4.2  Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

4.4.3  You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

1. Session Cookies - Session Cookies are used to operate our Service;
2. Preference Cookies - Preference Cookies are used to remember your preferences and various settings;
3. Security Cookies - Security Cookies are used for security purposes; and
4. Advertising Cookies - Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

4.5  Other Data

4.5.1  While using our Service, we may also collect the following information: gender, age, date of birth, place  of birth,  passport  details, citizenship,  registration  at place  of  residence and  actual address, telephone number (work, mobile), details of documents on education, qualification, professional  training,  employment agreements,  non-disclosure  agreements, information  on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.

5. Use of Data

We use the collected data for various purposes such as:

5.1  To provide and maintain our Service;

5.2  To notify you about changes to our Service;

5.3  To allow you to participate in interactive features of our Service when you choose to do so;

5.4  To provide customer support;

5.5  To gather analysis or valuable information so that we can improve our Service;

5.6  To monitor the usage of our Service;

5.7  To detect, prevent and address technical issues;

5.8  To fulfill any other purpose for which you provide it;

5.9  To engage third party. We may use third parties that we refer to as internal service providers to facilitate or outsource one or more aspects of service operations that we provide to you on the website;

5.10  To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection

5.11  To provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

5.12  To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;

5.13  In any other way we may describe when you provide the information;

5.14  Fulfill and manage your subscriptions, other purchases/requests, refunds made for our Services, if applicable; and

5.15  For any other purpose with your consent.

6. Retention of Data

6.1  We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.  We will retain and use your Personal Data to the extent necessary to comply with our contractual or legal obligations, resolve disputes, and enforce our legal agreements and policies.

6.2  We will also retain Usage Data for internal analysis purposes.  Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

6.3  We may also retain information which has been de-identified or aggregated such that it can no longer reasonably identify a particular individual. All retained personal information will remain subject to the terms of this Privacy Policy.

7. Transfer of Data

7.1  Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

7.2  If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there.

7.3  Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

7.4  The Company will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

8. Disclosure of Data

We may disclose personal information that we collect, or you provide.

8.1  Disclosure for Law Enforcement

8.1.1  Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

8.2  Business Transaction

8.2.1  If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

8.3  Other cases

8.3.1  We may disclose your information also:

1. To our subsidiaries and affiliates;
2. To contractors, service providers, and other third parties we use to support our business;
3. To fulfill the purpose for which you provide it;
4. For the purpose of including your company’s logo on our website;
5. For any other purpose disclosed by us when you provide the information;
6. With your consent in any other cases; and
7. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

9. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% (One Hundred Percent) secure.  While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security

10. Your Data Protection Rights Under General Data Protection Regulation (GDPR) and/or The California Consumer Privacy Act, 2018(CCPA)

10.1  If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by   GDPR. –See  more   at   https://eur-lex.europa.eu/eli/reg/2016/679/ojor if you are a resident of California, you have certain additional privacy rights under CCPA – see more at https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1121

10.2  For personal data, we rely on several legal bases to process the data. These legal bases include where:

10.2.1  The processing is necessary to perform our contractual obligations in our Terms or other contracts with you (such as to provide you the Services as described in our Terms);

10.2.2  You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);

10.2.3  The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;

10.2.4  The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the App, marketing the Services, such as new features or products that may be of interest, and promoting safety and security as described above;

10.3  Residents in the European Union are entitled to certain rights with respect to personal information that we hold about them;

10.3.1  the right to access, update or to delete the information we have on you;

10.3.2  the right to have your information rectified if that information is inaccurate or incomplete;

10.3.3  the right to object to our processing of your Personal Data;

10.3.4  the right to request that we restrict the processing of your personal information;

10.3.5  the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format; and

10.3.6  the right to withdraw your consent at any time where we rely on your consent to process your personal information;

10.4  We aim to take reasonable steps to allow you tocorrect, amend, delete, or limit the use of your Personal Data.

10.5  If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at Customer Support Email.

10.6  Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

10.7  You may have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

11. Educational institutions

11.1  We may provide Services to teachers, schools, schools districts, and other educational institutions (“Educational Institutions/Providers”) for use in educational settings, in which case the Education Providers may provide consent for the collection of personal data from students. We may also ask Educational Institutions to obtain consent directly from a parent or guardian instead of, or in addition to, the school providing consent. In these cases, the Services may allow for the parent or guardian to be added as a moderator of the student’s account. Parental or guardian consent would also allow a child to continue using the Services outside of school.

11.2  We strive to ensure that our privacy controls and measures are designed to protect personal information of the child and student in accordance with all applicable data privacy laws, including any data considered an “educational record” under the Family Educational Rights and Privacy Act (“FERPA”) and personal information of students under the age of 13 years consistent with the Children’s Online Privacy Protection Act (“COPPA”).

11.3  To the extent that Education Providers subject to FERPA provide the Company with student personal information, the Company will be considered a “school official” (as that term is used in FERPA and its implementing regulations);

11.4  The Company will comply, within a reasonable time frame, with your requests to review, modify, de-identify or delete any student personal information that the Company maintains about any student of the Educational Institutions; and

11.5  For more information about FERPA, please visit the FERPA site and the U.S. Department of Education website.

12. International Visitors

Our Services are operated and managed on servers located within India. If you choose to use our Services from the European Union, the United States, or other regions of the world with laws governing data collection and use that differ from the Indian law, then you acknowledge that we will transfer your personal information to India for the purpose of performing the Services according to our Terms and for any other purpose for which you provide explicit and informed consent.

13. Service Providers

13.1  We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

13.2  These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

14. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

In the event, our partners and such third parties distribute Personal Data outside the scope of our agreement with such partners or third parties, we cannot be held liable for the confidentiality. Further, in case breach of security or actions including without limitation, computer hacking, unauthorized access to computer data and storage device, computer crashes etc., we will not be held responsible.

15. Advertising

15.1  We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

15.2  Please note that when you click on one of these links, you are entering another website over which we have no control and for which we will bear no responsibility. Often these websites require you to enter your Personal Data. We encourage you to read the privacy policies of all such websites as their policies may differ from our Privacy Policy. You agree that we shall not be liable for any breach of your privacy of Personal Data or loss incurred by their use of such websites or services. The inclusions or exclusions are not suggestive of any endorsement by us of the website or contents of the website. You may visit any third party website linked to the Service at your risk. We strongly recommend you to read the privacy policies of third party websites.

16. Behavioral Remarketing

We and our third-party vendors may use cookies to inform, optimise and serve ads based on your past visits to our Service and that such Personal Data may then be used for remarketing services to advertise third-party websites/services to you

17. Payments

17.1  We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

17.2  We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy.

18. Links to Other Sites

18.1  Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

18.2  We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

19. Minor's Privacy

19.1  Our Service is designed to support families and children of all ages but we do not knowingly collect personally identifiable information from anyone under the age of 18 (“Minors”). Minors shall not be allowed to avail our Services without the consent of their parent or a legal guardian.

19.2  We do not permit Minors to create an account and do not knowingly collect personal information from children under the age of 18without the consent and at the direction of a parent or teacher. Please contact us if you believe we have inadvertently collected information from a child under 18 without parental consent so that we may delete the information as soon as possible.

19.3  If you are a parent or guardian who allows your Minor to use the Service through your account, you accept the Privacy Policy on behalf of your Minor child and are responsible for your child’s activity on the Service. Parents who create an account or purchase a subscription to the Service may set up a child profile associated with the parent’s account so that children under 18 may access the Service under the parent’s supervision.

19.4  If we become aware that we have collected Personal Data from Minors without verification of parental consent, we take steps to remove that information from our servers.

20. Changes to This Privacy Policy

20.1  We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

20.2  We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

20.3  You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

21. Governing Law

This Agreement has been executed and delivered in India, and its interpretations, validity and performance shall be construed and enforced in accordance with the laws of India, and shall be subject to the jurisdiction of the courts in Mumbai.

22. Contact Us

You may contact us by email or postal mail on the following address of the designated Grievance Officer:

Grievance Officer: Shailesh Prithani

Email ID: support@jumbaya.com

Contact Number: +91 22 4120 2509