PRIVACY POLICY

We welcome you to My-BagTags, our website and web application at www.my-bagtags.com/htr and/or our iOS and Android Mobile application (collectively our “Platform”). We are committed to protecting your Personal Data and to providing clear and transparent disclosures about the types of information we collect and how we use it.

For your further visits to our Platform, we would like to inform you about data collection, processing and use when visiting and using our website. As well as objection, revocation, and other rights to which you are entitled as a person affected by data collection and use.

We would like to ask you to read this Policy along with our Cookie Policy and if you are a user of our services, please also refer to our Data Processing Agreement.

In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular India`s Information Technology Act, 2000 (“IT Act”) and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”) and the General Data Protection Regulation (“GDPR”), and only as described in this Privacy Policy.

General Information

a) What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.

b) What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

c) Responsible for data processing

Responsible for data processing is Dahlia Technologies Pvt. Ltd of # 912 / 913, Shivalik Shilp 2, Opp. ITC Narmada, Mansi Road, Vastrapur, Ahmedabad, India (“Dahlia Technologies”, “we”, “us” or “our”). If you have any questions about this policy or our data protection practices, please contact us using our Contact Form, email contact@my-bagtags.com, call +91 9920 79 7777 or write to us at the above address.

d) The Legal Bases for processing Personal Data

In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data:

• you have given your consent,
• the data is necessary for the fulfilment of a contract / pre-contractual measures,
• the data is necessary for the fulfilment of a legal obligation or
• the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

General Principles

a) Security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send us.

You can recognise an encrypted connection if the address line of your browser contains a "https://" instead of a "http://" and has a lock symbol. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need-to-know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, Internet-based data transmissions can always have security gaps, so absolute protection cannot be guaranteed. Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.

Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

b) Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

c) Automated decision-making

Automated decision-making is the process of deciding by automated means without any human involvement. Automated decision-making including profiling does not take place.

d) Do Not Sell

We do not sell your Personal Data.

e) Special Category Data

Unless specifically required when using our services and consent is obtained for that particular service, we do not process special category data.

f) Social Media

We are present on social media based on our legitimate interests. If you contact us (or log in/connect with us) via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.

g) International Transfer

We may transfer your Personal Data to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your Data may be transferred to so-called third countries. To provide adequate protection for your Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

h) How long is your data stored?

We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists (in particular India`s commercial and tax law for up to 10 years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

i) Sharing and Disclosure

We will not disclose or otherwise distribute your Data to third parties unless this is a) necessary for the performance of our services for example with our web host or with our logistic partners to deliver your order, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; as required by law or regulation; if Dahlia Technologies (or a part of Dahlia Technologies) is sold to or merged with another company; or proceedings at home or abroad or to fulfil our legitimate interests.

Data we collect automatically

a) Collection of access data and log files

We also collect data on every access to our platform. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider

Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing platform.

c) Hosting

The website hosting service provider used is Azure by Microsoft, One Microsoft Way, Redmond, WA 98052, United States and One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521, Ireland. In doing so, Azure processes, based on our legitimate interests in an efficient and secure provision of the website, inventory data, contact data, content data, usage data, metadata and communication data of interested parties and visitors to my website.

d) Use of cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies:
a) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and
b) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies). For further information on the Cookies we use, please refer to our Cookie Policy.

e) Third-party services and content

We use content or service offers of third-party providers based on our legitimate interests to integrate their content and services ("services").

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser or place cookies in your browser to serve targeted advertising and for measurement and analytics purposes. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,

• Analytics: Google Analytics by Google LLC,
• Fonts: Google Fonts by Google LLC,
• Translate: Google Translate by Google LLC,
• Maps: Google Maps by Google LLC,
• Spam protection: reCAPTCHA by Google LLC, and
• Tag Management: Google Tag Manager and Google Site Tag by Google LLC,

f) Downloading the APP

The APP can be downloaded from the "Google Playstore" a service offered by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, US, if you are resident outside the EU and Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland if you are a resident within the EU, or the Apple App service "App Store" a service of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US, if you are resident outside the EU and Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill Ln, Knocknaheeney, Cork, Ireland, if you are a resident within the EU, to install our APP. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

g) Installing the APP

As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which Personal Data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which Personal Data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.

h) Device information

Google and Apple may collect information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.

i) Firebase

We use the Google Firebase developer platform and related features and services provided by Google LLC and Google Ireland Limited for push notifications only. Google Firebase is a platform for developers of apps for mobile devices. The Google Firebase developer platform offers a variety of features. A list of these features can be found at: https://firebase.google.com/terms/. Firebase's key security and privacy information can be found here: https://firebase.google.com/support/privacy

Data we collect directly

a) General

We may ask you for Personal Data when you:

• use our platform,
• request services, support, or information,
• participate online or otherwise in marketing activities,
• subscribe to our marketing and promotional emails or other materials,
• interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
• contact us.

b) Contacting us

Personal Data is processed depending on the contact method. In addition to your name and e-mail address, IP address or telephone number, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and Contract.

We also offer to contact us via the messaging services of WhatsApp, Meta Platforms, Inc, 1601 Willow Road Menlo Park California 94025 and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. If you contact us via WhatsApp we store and use the mobile phone number, you use and - if provided - your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request.

c) Account Registration

If you register on our Platform, we will request mandatory and, where applicable, non-mandatory data following our registration form (Company/Subscription ID, Email/User ID, Password) and other data depending on if you are a User or Admin. The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this storage is our legitimate interest in communicating with registered users and, in the case of contracts, also the storage of contract data.

d) When using our services

We process the data of our registered users to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop them further. This includes in particular our support, correspondence with you, invoicing, and fulfilment of our accounting and tax obligations. Your data will not be used by us for automated decision-making or profiling, nor will it be shared with third parties. Accordingly, the data is processed based on fulfilling our contractual obligations as well as fulfilling our legal obligations. The legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as your consent.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

Please note when using our services, you become the data controller and we become the data processor under Chapter 4 of the GDPR. Where we process your Personal Data as a data intermediary on behalf of you, we will process the Personal Data involved under your instructions and shall use it only for the purposes agreed between you and us, for further information please refer to our Data Processing Agreement.

e) Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks as well as the organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interests.

f) Payments

Payment by credit card and debit card is made via the payment service provider Chargebee Inc 340 South Lemon Avenue Suite 1537 Los Angeles, CA 91789 United States to which you pass on your payment details during the checkout, for payment processing. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.

g) Authorisations and Access

We may request permission to store your APP data including your Internet Connection and Network, Location, Push Notifications, Camera, Gallery, Calendar, Biometrics and Send Email & Call, and file storage of your device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our APP may not function as intended.

h) Push messages

When you use the APP, you will receive so-called push messages from us, even if you are not currently using the APP. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device. Insofar as you consent to the use of push messages, consent is the legal basis for the processing.

Google Analytics

We use Google Analytics which means that the data collected can in principle be transmitted to a Google server in the USA, whereby the IP addresses are anonymised using IP anonymisation so that an allocation is not possible. Google Analytics places cookies. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can object to the collection and processing of this data by Google Analytics by setting an opt-out cookie that prevents the future collection of your data when you visit this website: http://tools.google.com/dlpage/gaoptout?hl=en. The legal basis for the use of Google Analytics is based on your consent.

Data from third party sources

We may obtain data about you from third-party sources, such as our marketing partners, social networks, and other third parties. We may use this data to better analyse your user behaviour to improve our ability to provide you with relevant marketing information and services and to prevent and combat fraud.

Insofar as you have also given us your consent to process your Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

Your Rights and Privileges

a) Privacy rights

Under the IT Act and SPDI Rules, you have the following rights:

• Right to be informed
• Right to access
• Right to rectification
• Right to erasure
• Right to object/opt-out

Under the DPA and the GDPR, you can exercise the following rights:

• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right of objection
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

If you have any questions, please contact us.

b) Updating your information

If you believe that the information, we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.

c) Withdrawing your consent

You can withdraw the consent you have given at any time by contacting us.

d) Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

e) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection.

Changes and Questions

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise this Privacy Policy accordingly and change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Data. If you would like to speak to us regarding our privacy practices for any reason, please contact us using the details provided above.

Effective Date

Thursday, 17 May 2024