Privacy Policy Of Octagona India Private Limited

I.   Introduction

Our Company, Octagona India Private Limited (“OIPL”, “Company”, “we”, “us”, or “our”) is a private limited company registered under the Companies Act, 1956, holding CIN: U74140DL2007PTC172026, having its registered office in New Delhi, India. As a responsible Company, we value the significance of safeguarding your Data and respecting your privacy rights. This Privacy Policy outlines how we, as Data controllers/fiduciary, handle and protect your information during OIPL's business activities. Our commitment is to ensure that any Data that can identify you as an individual person is treated with the utmost care and security.

This Privacy Policy of our www.octagona.co (“Site") is compliant with General Data Protection Regulation (“GDPR”) and the Digital Personal Data Protection Act, 2023 (“DPDP”). Please take a moment to read our Privacy Policy carefully.

If you do not agree with the terms of this Policy, kindly refrain from accessing our Site.

II.   What Information Do We Collect?

Your information is divided into 3 (three) distinct categories: Personal Information (“PI”), Pseudonymised Data (“PD”), and Sensitive Personal Data or Information (“SPDI”), (PI, PD and SPDI hereinafter collectively referred to as “Data”) (Only PI & SPDI to be collectively referred as “PSD”).

Definition of PI, PD and SPDI are given below: -

1.   PI : Information which helps in identifying a person, such as name, address, IP address, mobile number etc.

2.   PD : Pseudonymised Data is Personal Information that's been altered by giving an anonymous tag to it, so that it can't be directly linked to an individual without additional information. It helps protect your privacy while allowing us to analyse and research.

3.   SPDI : Personal Information which is more sensitive and requires higher degree of protection, such as password, financial information (such as bank account, credit card, debit card, payment instrument details), physical, physiological, and mental health condition, sexual orientation, medical records and history and biometric information, and all such information mentioned in the CV (curriculum vitae).

III.   How Do We Obtain Your Consent?

The collection of Data starts only after acquiring your consent, through the displayed disclaimer upon your entry to our Site. This step assures us that you have read and comprehended this Policy, alleviating any doubts about your choice to grant consent.

You must only provide you consent if you are aged 18 (eighteen) or older, as the Data collected is processed for the purposes which is appropriate for visitors aged 18 or older.

Once you provide your consent, the next step involves collection of your Data only under the specific circumstances as mentioned in this Policy. This is to ensures that you are aware of the different ways in which you may have provided your information to us. It helps you to understand how the Data will be processed by us.

We ensure your Data is secure using the Company's best practices, as elaborated in this Policy.

IV.   How Do We Collect Your PSD?

Circumstances	PI Collection	SPDI Collection
When you visit, browse, and use our Site.	Your unique device identity (UDI) The internet protocol (IP) address of your device Location	No SPDI is collected
When you fill the Inquiry Form on our Site.	Your name (first and last) E-mail ID Mobile number Company's name, if any	Comment Additional information provided by you in the Contact Us section
When you apply for Newsletter through our Site.	E-mail ID Your Name	No SPDI is collected
When you reach us through WhatsApp or LinkedIn (collectively to be referred as “WL”) as from our Site.	Mobile number WhatsApp’s About Section Your profile picture from WhatsApp.	Any information that you share with us through text/chats from WhatsApp or LinkedIn.
When you accept our cookies	Remembering your personal preference in Site. Targeted advertisement through third party. (Ex: Google AdSense)	No SPDI is collected

V.   How Do We Collect Your PD?

When you follow our social media accounts through our links available in our Site, the information we receive will be pseudonymised. Our Site only includes WL as our social media platforms, the pseudonymised information that we receive includes:

(i) The number of clicks on the specific social media platforms on our Site.
(ii) Data on how many persons followed our WL Page/account. Please be assured that this pseudonymised data does not reveal any PSD.

With your prior consent, PD collected through cookies is solely used to track your preferences and analyse your activity on our Site. This enables us to improve your future visits by providing a more personalized and enhanced user experience. Rest assured, we respect your privacy and ensure that the PD is only used for these specific purposes with your permission.

We, at OIPL, are fully committed complying with security measures, ensuring that all information we receive in this aspect remains in a pseudonymised/anonymous format.

VI.   Is SPDI Our Responsibility When Received Through Third Party?

We have the capacity to receive your SPDI through third-party platforms, namely WL.

We, at OIPL, value your privacy and want to inform you about our policy regarding WL communication and handling of SPDI. One of the ways we receive SPDI is through WL conversations. Please note that securing your chats during interactions with our executives is beyond our responsibility.

To initiate any conversation regarding our business, your explicit consent is required. By providing consent, you acknowledge and understand that it is a third-party platform, and we encourage you to review WL’s privacy policy for detailed information on how they regulate and protect your Data.

As part of these conversations, we will collect your phone number and other relevant information necessary for our business dealings with your consent. But we do not assure you the protection of the conversations on these platforms, as it’s regulated by the privacy policy of WL, we encourage you to carefully read and comprehend WL’s privacy practices to make informed decisions regarding your communication with us on the platform.

VII.   How Will We Use Your Data

We collect and process your Data through,

(i) Either with your express consent; and/or
(ii) To serve legitimate usage.

We do not store or process your Data any longer than is necessary in relation to the purposes for which they were collected or ensuring compliance with applicable laws. We process information under the followings:

• Provide you with the information/services that you request from us;

• Communicate with you and respond to your inquiries;

• Inform you about our services and foreseen changes in our services;

• Resolve consumer issues;

• Improve your experience on our Platform based on the feedback and information we receive from you;

• Use analytics software to predict the jurisdiction, trend change and services to make our Site more user friendly with time;

• Help us to onboard employees and conducting interviews with them;

• Any other processing mechanism which lies under the purpose of legitimate interest for the Company (such as: direct marketing).

The above information will only be processed if you provide us your prior consent, without that we at OIPL will never process your Data in any scenario. By giving your consent, you hereby authorize us to contact you via calls, mails and/or text messages on the contact details so provided, to furnish you details regarding the services of OIPL.

VIII.   How Safe Is Your Information With Us

Your PSD is our responsibility, and it will be stored and secured by OIPL with full and absolute integrity and honesty. We at OIPL know the value of an individual’s privacy and why it must be secured at all costs in todays interconnected and digital world, for which we have formulated a methodology in our Company, which is unique to the global standards that assures your PSD is fully secured and no breach takes place at any given time, under any circumstances.

We have formulated a system to secure your PSD, for which we have dedicated a Data Protection Officer (“DPO”), Vishnu Krishna Gaurav (Email: v.krishna@octagona.com), responsible for securely managing your PSD. The term of the DPO will be 5 (Five) years, as amicably decided by OIPL's management, with the possibility for re-appointment upon the expiration of the term. The DPO will organize all information related to PSD into reasonable categories. This PSD will be stored in a Google Drive Folder (“GDF”) protected by a unique password, ensuring that only the DPO can access and handle your PSD. Rest assured, your PSD is in safe hands and not accessible to anyone else as per our Privacy Policy.

To enhance PSD security in the GDF we consider these following measures:

• Enable Two-Factor Authentication (2FA): To access the GDF, it will require an additional verification step, like a one-time code sent to the DPO's mobile device to access the GDF.

• Regular Password Updates: DPO will regularly update the GDF password on monthly basis to minimise the risk of unauthorized access due to compromised passwords.

• Access Controls: GDF will have limited access to only essential personnel, granting permissions on a legitimate interest; need-to-know basis.

• Audit Logs: DPO will regularly monitor the GDF’s PSD to detect any suspicious activities.

• Secure Devices: We ensure that the devices used to access the GDF are protected with strong passwords, and up-to-date security software.

• Data Retention Policy: Data will only be retained by us for a specific reasonable period, after which the PSD will be removed to minimise the potential risks.

• Regular Security Training: Conduct regular security awareness training for the DPO and to educate him and equip him about potential threats and best practices.

IX.   Will Your Receive Any Marketing Information?

Yes, with your consent, we are authorized to share updates about our business with you. We will provide you with our latest blogs, client testimonials, and information about services that are relevant to our business. Additionally, we may share information about our group companies. Your acceptance/consent to this will enable us to maintain a transparent and mutually beneficial relationship with you.

Our group companies are:-

1. Octagona Srl
2. Bonfiglioli Consulting Srl

With your consent, we will solely share updates regarding our group companies with you. We want to clarify that we don’t share your PSD to the above companies without your consent.

X.   What Are Your Data Protection Rights?

OIPL will like to educate you on your rights with respect to your Data protection and how can you use them whenever the need arises. Every user is entitled to the followings:

1.   Right to access

At OIPL, we believe in protecting your privacy and ensuring that your PSD is handled with utmost care and transparency. We understand the importance of providing you with the necessary information about how your PSD is being processed and your rights as a user. You have the right to request confirmation from us about where and how we are processing any of your PSD. If that is the case, you can access the PSD and obtain the following information:

• The purposes for which we are processing your PSD.
• What sort of PSD we are collecting from you.
• The expected duration for which your PSD will be stored.
• Your right to request rectification, erasure, or restriction respectively.

2.   Right to rectification

At OIPL, we believe that your PSD must have the capacity to get altered and rectify, and with this changing digital world of internet, it gets even more crucial for you to be keep your information updated all the time. You have the right to request that our Company shall correct any PSD you believe to be is inaccurate. You have the right to request us to complete the PSD you believe is incomplete.

3.   Right to erasure

As a user, you have the right to request the erasure of your PSD from our records. We will comply with this request, provided there are no legal or legitimate reasons for us to retain the PSD. To exercise this right, please contact our DPO.

4.   Right to object to processing

You have the right to object to the processing of your Data by us. This includes any processing activities based on legitimate interests or for direct marketing purposes. We will cease processing your Data unless we have compelling legitimate grounds to continue or if required by law.

5.   Right of grievance redressal

You have the right to approach us for any issues regarding how OIPL is performing its obligation in securing your PSD. For any inquiries you can e-mail us on v.krishna@octagona.com, your issue will be resolved within 10 (ten) working days. The subject of the email should be “Grievance Redressal” regarding PSD.

6.   Right to data portability

You have the right to request the portability of your PSD held by us. Upon your request, we will provide you with a copy of your PSD in a commonly used and machine-readable format. This enables you to transfer your PSD to another fiduciary.

7.   Right to Nomination

You possess the right to nominate a third party, who will have the absolute ownership of, and rights related to your PSD in the event of your death or you become of unsound mind while acting as the owner of the PSD which we retain.

XI.   How Can You Withdraw Your Consent?

Among the various rights you possess, you also have the option to withdraw your consent. Our commitment to ethical conduct ensures that we only process information within the boundaries of your consent.

To facilitate this, we've established a user-friendly procedure for withdrawing consent.

The steps for withdrawing consent are as follows:-

1. If you decide to withdraw your consent, you can easily do so by filling the 'Opt-Out Form,' which is available at the bottom of every page on the Site.


2. If you wish to, you can insert your comments in the ‘Reason for Opt-Out’ section, elaborating the reason for your withdrawal. This information will be submitted voluntarily by you. We would like to offer you the option to explain your reason for the withdrawal.


3. The withdrawal request is directly sent to the DPO, who will subsequently initiate the necessary action to your request.


4. Once DPO receives your withdrawal request, we will promptly erase your Data from our system and cease any further processing within the subsequent 10 (ten) working days.

XII.   What Are Cookies?

A cookie is a small piece of text that are stored on your device by the Site, typically within your web browser. It's used to remember information about your interactions with the Site, such as preferences, login credentials. Cookies enable Site to provide you a more personalized and smoother browsing experience by retaining certain information across different pages or visits. They are also used for tracking and analytics purposes, helping us understand how you engage with our Site.

XIII.   Cookies We Use And Why?

• Performance Cookies: A performance cookie is for enhancing your site experience. It ensures speedy page loads and seamless navigation. By focusing on data like page load times and server responses, it optimizes the overall user experience. Your experience matters, and this cookie is dedicated to making it the best it can be.


• Functional Cookies: These cookies enable to contribute a user-friendly online experience by storing and recalling user choices, ultimately optimizing the functionality of a site. It which allow site to remember your respective site preferences and choices.


• Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts. They do not store directly personal information but are based on the identification of your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.


• Strictly Necessary Cookies: These cookies are necessary for the site to function properly and cannot be switched off in our systems. These cookies are necessary to provide requested services and enable core functionalities, such as authenticating users, managing sessions, and maintaining the overall usability of the platform.

XIV.   What Type Of Data We Receive?

When you agree to accept cookies, you grant consent to provide your Data. The Data we gather includes Pseudonymised Data (PD), (PI) Personal Information. In certain situations, various cookies collect different types of information, according to its own functionality. PI is processed through the third party for the legitimate usage.

XV.   How Can You Control Cookies?

When you visit our Site for the first time, you are given a choice to either “Accept All Cookies” or “Manage My preferences”. When you desire to remove these cookies, you can control them by adjusting the settings in your browser. However, you cannot disable essential cookies, as this would not allow our Site to function as intended. If you choose to block/remove some/all cookies, some features of the Site may not work as intended.

XVI.   Do We Share Your Information With Third Party?

At our Company, we prioritize operating with the utmost integrity, ensuring that our users never feel insecure about their Data. We want to emphasize that any information we collect is done so with your absolute consent and is strictly kept confidential between you and our Company. Rest assured, we have no intentions of processing this information for any activities outside the scope mentioned in this Privacy Policy, and under the legitimate usage.

XVII.   Privacy Policy Of Third Parties

It is important to note that while we may receive certain information through third-party sources, we assume that you have taken the time to read and understand the third party's privacy policy.

Please note that certain information we receive through third-party sources, such as WL chats, LinkedIn followers, YouTube subscribers, and business/job related emails, may include Data. Although these links are available on our Site, using these platforms implies that you understand and agree to the privacy policies of those companies. It's essential to note that we are not responsible for any breaches that may occur in such situations. Your Data security remains a top priority for us, and we encourage you to stay informed about the privacy practices of those platforms you use to interact with us.

XVIII.   Changes In Our Privacy Policy

By using the Site, you consent to the collection, use, and storage of your PSD by us in the manner described in this Privacy Policy and elsewhere on the Site. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes. If we make material changes to this Privacy Policy that increase our rights to use your Data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Site.

This Privacy Policy was last updated on 13th August, 2023.

XIX.   How Can You Contact Us?

If you have questions or comments about this Privacy Policy, you may email us at octagona.india@octagona.com or by post to:

Octagona India Private Limited

411, 4th Floor, DLF Tower B, Jasola

District Centre, New Delhi,

Delhi 110076, India