PATS Literary Solutions (“we”, “our”, “us”, “Gaatha” or “PLS”) values the trust placed in us by data subject (“you”, “your”, “user”, “subscriber”) and therefore, we follow the highest standards of privacy guidelines to protect the information shared by you with us.
This Privacy Policy (“Policy”) describes the information which Gaatha collects from you when you download, access, or use the audio streaming services made available by us through our mobile application – our Website – www.gaathaonair.com ‘Website’.
This Privacy Policy should be read in conjunction with the Terms of Use applicable to the PLS services you are using.
Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications like social media login the information we collect is through those third-party sites linked with our applications is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in observance that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.
All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Use.
What happens to your data collected by us prior to May 25, 2018?
If our systems can identify from the information we possess that such information belongs to a user from the EU region, then we shall drop you an email informing you about the data we possess and seek your consent to continue storing and processing the information. If you have any query, then you can contact our Grievance Officer at the email address provided below.
Ms. Amit Tiwari
India
amittiwari@gaathaonair.com
In case you choose to withdraw your consent, we will delete your information but we may choose to archive and retain some information for legal purposes. Once such information is archived, we will not use it for any purpose and shall disclose it only to comply with any applicable law, court order, or request from governmental authority or law enforcement agencies.
In some cases, Website may have stored some of your information in your device (computer, mobile, tablet). You will have to delete such information from your device manually. If you have accessed Website and PLS Services from multiple devices, then you will have to delete the information stored in each of such device manually.
User consent
By using Gaatha Services (for example, when you register for an account, purchase a service, communicate with us, on our sites or applications), 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 for further operations. In case of any roaming user profile or if you are a traveller visiting various countries around the world and avail Gaatha’s services, then we will consider the country of registration as your primary country and the consents obtained at the time of registration will be valid for your processing of personal information.
Accessing Website and PLS Services through VPN
You should not access or use the Website or PLS Services by means of any mechanism or technology which conceals your actual geo-location or provides incorrect details of your location (for example, use a virtual private network (VPN) to access PLS Services).
We will not be responsible or liable for any collection, storage or processing of your personal information or data if you use any mechanism or technology to access or use Website or PLS Services which conceals your actual geo-location.
Collection and Use of Personal Information
‘Personal 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, and mobile number indicating to that particular person or is identifiable. 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
We may ask for and collect the following personal information, including but not limited to, about you when you use the Gaatha Services and without this information we may not be able to provide you with all the requested services;
- E-mail id
- Mobile Number
- Name
- Date of Birth
- Gender
Information collected when you use our Mobile Application
When you use the Gaatha Services, we may also collect information from your device. This information includes the following, including but not limited to:
- Photos, Media and files
- the make and model of your device,
- the operating system of the device,
- software details,
- device IDs,
- IP address/MAC address,
- GPS location accurate to 300 meters,
- information about your telecom network
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, e-mail id, mobile number, location, etc.
B. Information automatically collected while browsing/navigating through the Website
Cookies
The Website uses cookies and other similar technologies which are necessary to its functioning and to provide PLS Services. Some of these cookies are essential for us to provide you with the PLS services.
We do not collect your personal data through these cookies.
Do Not Track
The Website and PLS Services currently do not process or respond to “Do Not Track” requests/signals which some internet browsers have the ability to send out.
C. Inferred Information through usage and log data
We may track certain information about you based upon your behaviour on the ET Services. We use this information for conducting 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:
- To evaluate your interest for various genres of content, services, offers;
- To perform analytics and conduct customer research, to determine your interest, for identifying content that generate sales and to 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
a) 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 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.
b) Information obtained from Third party websites
If you link, connect or login to the Gaana Services account through a third party service i.e. Google and Facebook they may send us information such as your registration and profile information from the service. Below mentioned are the information getting collected through social platforms such as:
- Facebook – Public information, Name, Email id, friend list, Date of birth, Likes
- Google – Email id
c) Demographic and other information
We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use various third party analytics service providers, among others, to track the user behaviour on our website. They are used to support display advertising towards helping us gain 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 giving a consent at to serve you advertisements when you visit our website or applications.
d) Subscription or Paid service data
When you chose 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 etc. The subscriptions or paid Services may be on auto renewal mode unless cancelled. If at any point you do not wish to auto-renew your subscription, you may cancel your subscription before the end of the subscription term or contact us on our support e-mail.
e) Transactional/ 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. This information is stored by the payment gateway partner. 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; such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to 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 (for e.g., transaction ID, etc.) from third party vendors in case of payments, for reconciliation and validation of transactions and also for the purpose of resolutions of complaints (in case of failed transactions and refunds).
Disclosure to Third parties
a) Service Providers
The Application may include links to other websites or applications (for e.g., links to payment gateways for payment of subscription fees). Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the application, website you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these sites via a link from the application’s/website homepage, you should contact the application/website owners directly for more information.
b) Promotional Offers
We may share or disclose your personal information outside of gaatha when we have your consent. For example, providing SMS and E-mail related services such as marketing newsletters, promotions and offers.
c) Advertisers
When we present information to our advertisers — to help them understand our audience and confirm the value of advertising on our websites or Applications — it is usually in the form of aggregated statistics on traffic to various pages / content within our websites or Applications. We use third-party advertising companies to serve ads when you visit our websites or Applications. These companies may use information (not including your name, address, email address or telephone number or any other personally identifiable information) about your visits to this and other websites or application, in order to provide advertisements about goods and services of interest to you. We do not provide any personally identifiable information to third party websites / advertisers / ad-servers without your explicit consent.
d) Legal
We may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, and change of control, transfer of assets or reorganisation of our business.
e) Business transfers
We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we may use service providers to help us with customer support.
We may also share your personal information such as Name, E-Mail ID, Mobile No and other such generic information with our group companies/affiliates as a part of the SSO login functionality after you have provided your consent while registering with us. We may also share information about your interests and choices without group companies/affiliates to provide you with personalized recommendations and advertisements on our platform gaathaonair.com.
Purposes and lawfulness of processing
We will only collect and process personal data about you where we have lawful basis. Lawful basis on which we would process our 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 customer support or process your data for providing subscription services (For e.g. processing your information by our payment gateway service providers).The information collected from you is used by us to develop and improve Gaatha Services and also to provide you a personalised experience while using Gaatha Services.
We use information to provide, analyse, administer, enhance and personalize our service and marketing efforts, to process your registration, to provide you services, and to communicate with you related to below mentioned points. For example, we use information to:
- To provide you our services
- To provide you information about our services and products
- To provide you personalised services and products
- To show you personalised advertisements and other contents
- To show you personalised advertisements and other contents on our group companies’ website and mobile applications
- To show you personalised music recommendations
- To improve our and our group companies’ products and services
- To provide you a tailored and consistent experience across products and services offered by us and our group companies
- For statistical analysis- Analyze and understand our audience, 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 send you marketing and promotional materials
- To communicate with you in relation to your account or service, service updates or other non-marketing communications
- For you to participate in interactive features of the websites (such as Gaatha rewards, feedback, etc.)
Information use by the company
The Information as supplied by the users enables us to improve the Services and provide you the most user-friendly experience. All required information is service dependent and the Company may use the above said user Information to, maintain, protect, and improve the Services (including advertising on the “Application”) and for developing 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 subscribe / unsubscribe (where feasible)]. We may, however, use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, billing, notifying you in case of breach incidents, etc.)
Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and / or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, twitter etc. Any posted/uploaded/conveyed/communicated by users on the public sections of the “Application” becomes published content and is not considered personally identifiable information subject to this Privacy Policy. In case you choose to decline to submit personally identifiable information on the Application, we may not be able to provide certain services on the Application to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.
When you register with the Application or Services, we contact you from time to time about updating of your personal information to provide the users such features that we believe may benefit / interest you.
How do we share your information
We do not share your information with any third party without obtaining your prior consent, with the exception of the following limited circumstances:
| Entity | Purpose of Sharing |
|---|---|
| Court of law, governmental agency, law enforcement agency | 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 for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing these Terms or for complying with the applicable laws and regulations |
| Third Party Advertisers | We may provide third party advertisers with reports containing aggregate statistical data about how our users are interacting with our websites and app and to determine the kinds of people viewing their ads and how they are performing. This aggregated information may include demographic data such as age range and/or geographic location of groups of our customers. This aggregated data does not include contact details (such as names, addresses or email addresses) that can be used to personally identify you or contact you.In case we show you, promotions or offers on the Gaatha Services which is sponsored by third parties and if you enter such promotions or claims such offer and you choose to submit your information |
| Our group companies | For the purposes of processing your information in order to provide you servicesFor the purpose of providing you a customised and tailor-made user experience on our and our group companies’ products and services.For the purpose of showing you personalised advertisement and content on Gaatha Services and on the products and services of our group companies |
| Third Parties | To enforce applicable terms of use of Gaatha Services, including investigation of potential violations.To detect, prevent, or otherwise address fraud, security or technical issues.To comply with any applicable law, court order, or request from governmental authority or law enforcement agencies |
We also ensure that the recipients of information collected and shared by us agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
How long do we store and use your information
We retain the information which we have collected no longer than is necessary. This 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 Gaatha 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
For any of the below request you may send us an e-mail to our support team
A. Accessing and rectifying your personal information
When you use the Services Website/application (or any of its sub sites), we make good 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 requests that are unreasonably repetitive or systematic, requiring disproportionate technical effort, jeopardizing 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 e-mail to our Grievance officer. You will get a link on your registered Email address through which you can access all the data Gaatha collects and stores about you.
Ms. Amit Tiwari -CEO
India
amittiwari@gaathaonair.com
You can ask us to correct inaccurate or incomplete personal information
- Concerning your login credentials by editing the same through My Accounts section, through the SSO portal. The same shall be reflected across all properties.
- Concerning details that are separately collected and maintained by Gaatha by sending an e-mail 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. If you are registered on the Gaatha Services, then you can download the information which we have collected and stored by using the Download functionality through the link for download functionality. Through this, a copy of your information that we have collected and stored will be downloaded on your machine.
C. Data Retention and Erasure
We retain your personal information as long as necessary for us to provide services to you or you ask us to not retain your data. If you no longer want us to use your information then you can request that we erase your personal information and close your Gaatha Services account. Please note that if you request for the erasure of your personal information;
- The personal information (Name, E-mail, 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, if we suspend a Gaatha account for fraud or safety reasons, 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., Comments, Reviews, etc.) may continue to be publicly visible on the Gaatha, even after your account is cancelled. However, 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.
Your request will be processed and you will receive confirmation of the same via email. Please note that this will only perform a deletion of the information that has been collected by Gaatha and will disable your SSO information for Gaatha. You will still exist as a user across all the other PLS platforms. In case you also wish to delete your SSO related information, kindly follow the instructions displayed on the screen or please read the SSO privacy policy to understand how to invoke your rights.While we will delete the information which we have collected and stored, You may also be required to delete some information which is stored on the device you use to access Gaatha Services (mobile phone, computer, tablet) manually. If you are accessing and using Gaatha Services on multiple devices (as a log-in user or otherwise), you may be required to manually delete certain information which has been collected by us and stored on your device.
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 e-mail. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you and stop any further processing of your personal information.
E. Objection to Processing
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail 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, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate.
We may take 30 days from the date of receipt of request to complete your requests. However, if the nature of the requests are excessive in nature or would require significant effort then may ask for an extension of 60 days by giving a 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, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize 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.
F. Complaints
You can write to our data protection officer in case of any grievance or compliant. You have the right to complaint about the data processing activities carried out by Gaatha before the competent data protection authorities.
Children’s privacy
Gaatha Services is not aimed or targeted towards children under the age of 18. We do not intend to or target to collect any information about children under the age of 18. If you are a parent or guardian of a child under the age of 18, and if you are aware that your child has used Gaatha Services and provided his/her information to us without your consent, then please contact us on our support e-mail id. We will delete or otherwise cease processing your child’s information within a reasonable time. Children below the age of 18 must access or use Gaatha Services only with the approval of and under the supervision of their parent or legal guardian.
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 18 years of age or offer to send any promotional materials to persons in that category. Gaatha 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 Gaatha with personal information without their prior consent, please contact our customer support team to ensure that the personal information is removed from the Gaatha Services.
DATA TRANSFER, STORAGE AND PROCESSING GLOBALLY
We operate globally and may transfer your personal information to individual companies of Gaatha and its affiliated companies or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards.
Security measures
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of your information. 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 unauthorized access to systems where we store personal data.
All information gathered on the Gaatha Services is securely stored within our controlled database. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. If you know or have reason to believe that your Gaatha Services account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.
Updates and changes
This Privacy Policy is subject to change from time to time. We reserve the right, at our sole discretion, to modify the terms of this Privacy Policy from time to time in order to ensure compliance with applicable laws (“Updated Terms”). The Updated Terms shall be effective immediately and shall supersede these the terms of this Privacy Policy. We will not be under an obligation to notify you of any changes to this privacy policy except if the changes made to the policy significantly affects your rights or as may be required by law. You shall be solely responsible for reviewing the Privacy Policy from time to time for any modifications. By continuing to use Gaathaonair.com after the updated Terms have been published, you affirm your agreement to the updated terms.
