POOJA POINTS LIMITED

PRIVACY POLICY

This Privacy Policy explains how Pooja Points Limited (“POOJA’) collects, uses, store, transfers, erases and destroys Personal Data that we collect from our customers who have enrolled in the Pooja Online Program (“Program”) via the Software in order to utilize the Pooja Services.

  1. Definitions
    1. ‘Personal Data’ means:-
      1. any data (whether stored in an electronic or printed form) relating to a living individual who can be identified
        1. from the data; or
        2. from the data and other information in the possession of, or likely to come into the possession of the Company; or
        3. any data (whether stored in an electronic or printed form) pertaining to the financial record of a living individual.
      2. ‘Services’ mean financial related services which include but are not limited to the following:-
        1. Creation of an online account via a mobile application software or a web login;
        2. Provision of electronic consumption record services which include uploading, storing, and accessing records electronically;
        3. The transmission of records electronically between authorized representatives;
        4. Generation of anonymous statistical reports.
    2. ‘Software’ means the mobile application, website, platform or systems developed and maintained by POOJA for the purposes of carrying out the Services;
    3. ‘Third-Party Service Provider’ means any person i.e. individual or entity who has entered into an agreement with POOJA to provide the Services; and
    4. ‘Third-Party Supplier’ means any person i.e. individual or entity who POOJA has engaged to provide the Services;
  2. Types of Personal DATA

    This Privacy Policy explains our practices with regard to Personal Data collected by POOJA for its own business purposes. We may collect the following types of Personal Data:

    • Contact Information that allows us to communicate with you, such as your name, D.O.B., username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.
    • Relationship Information that helps us do business with you, such as the types of products and services that may interest you.
    • Transaction Information about how you interact with POOJA including inquiries, online account information, and information about how you use the Software.
  3. How POOJA collects Personal DATA
    1. In many cases, we collect Personal Data directly from you. We will ask you for Personal Data (including Contact Information and Relationship Information) when you interact with us, such as when you create an online account and enroll in the Program via the Software. We may collect additional Relationship Information from third party data suppliers who enhance our files and help us better understand our customers. We will also collect Transaction Information when you interact with us, such as when you create an online account and enroll in the Program via the Software.
    2. We will use cookies and other technological tools to collect information about your use of the Software.
  4. How POOJA uses Personal Data

    POOJA will use your Personal Data to:

    • Create an online account for the purposes of enrolling you in the Program and facilitating the use of the Services by you;
    • Provide you with marketing communications and offers for additional products and services from POOJA;
    • Administer surveys and other promotional events;
    • Generate anonymous statistical reports; and
    • Manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance, and business continuity.
  5. Why Personal Data is disclosed by Pooja

    POOJA understands that you do not want us to provide your Personal Data to third parties for their own marketing purposes. We will limit our sharing of your Personal Data as follows:-

    • We may share your Personal Data with an affiliate or associated entity of POOJA, which may only use your Personal Data for the purposes listed above.
    • We may also share your Personal Data with a Third-Party Service Provider or a Third-Party Supplier, who will be bound by law or contract to protect your Personal Data and only use your Personal Data in accordance with our instructions PROVIDED HOWEVER THAT in circumstances where your Personal Data is transferred to a territory outside of Jamaica, such territory may not provide for an adequate level of data protection as granted in Jamaica.
    • We may also disclose Personal Data where needed to enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will also always disclose Personal Data when required to do so by law.
    • Please note that we may also use and disclose information about you that is not personally identifiable. For example, to generate reports that contain aggregated and statistical data about our clients. These reports do not contain any information that would enable the recipient to contact, locate or identify you.
  6. Cookies and Other Data Collection Technologies
    1. When you use our Software, we will collect certain Transaction Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. For example, when you visit our website, we will place cookies on your computer. Cookies are small text files that websites send to your computer or other internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available.
    2. We may collect many different types of information from cookies and other technologies. For example, we may collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the internet. An IP address is a unique number that devices use to identify and communicate with each other on the internet. In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Data. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.
    3. In some cases, we do associate the information we collect using cookies and other technology with your Personal Data. This Privacy Policy applies to the information when we associate it with your Personal Data.
    4. POOJA has relationships with third party advertising companies to place advertisements on this website and other websites, and to perform tracking and reporting functions for this website and other websites. These third party advertising companies may place cookies on your computer when you visit our website or other websites so they can display targeted advertisements to you. These third party advertising companies do not collect Personal Data in this process, and we do not give any Personal Information to them as part of this process. However, this Privacy Policy does not cover the collection methods or use of the information collected by these vendors. You can opt out of being targeted by many third party advertising companies. [ ].
  7. Mobile Application

    POOJA’s mobile application will allow you to access your online account, utilize the Services, interact with us online and receive other information via your smartphone. All Personal Data collected by POOJA via our mobile application is protected by the terms of this Privacy Policy.

  8. Choices

    You can always limit the information you provide to POOJA. You can also limit the communications, if any, that POOJA sends to you. To opt-out of commercial emails, if any, simply click the link labeled “unsubscribe” at the bottom of any email we send you. Please note that even if you opt-out of promotional emails, we may still need to contact you with important Transactional Information about your online account. For example, even if you opt-out of emails, we may still send you activity confirmations. If you have any questions about your choices or if you need any assistance with opting-out, please contact us via email at [info@daisy-health.com] or by telephone at [1-888-429-5765].

  9. Access and Rectification

    POOJA respects your right to access and rectify your Personal Data. You can log into your online account at any time to access and update the information you have provided to us. Additionally, POOJA complies will all local data protection laws or regulations regarding access and rectification. If you need assistance updating your Personal Data, please contact us via email at [info@daisy-health.com] or by telephone at [1-888-429-5765].

  10. Information Security

    POOJA has implemented an information security program that contains administrative, technical and physical controls that are designed to safeguard your Personal Data. For example, we use industry standard encryption technology to secure sensitive Personal Data when it is being collected and transmitted over the internet as well as firewalls, site monitoring and intrusion detection software. Please note that you should also take steps to protect your Personal Data. POOJA, however, does not make any representations or warrants that your Personal Data may not be accessed, disclosed, altered, or destroyed by breach of such safeguards. POOJA will notify you immediately in the event of a security breach and will maintain an incident response policy that includes notifications consistent with applicable law.

  11. Changes to this Privacy Statement

    From time to time, we may update this Privacy Policy to reflect new or different privacy practices. We will place a notice online when we make material changes to this Privacy Policy. Additionally, if the changes will materially affect the way we use or disclose previously collected Personal Data, we will notify you about the change by sending a notice to the primary email address associated with your online account.

  12. Retention Of Personal Data

    POOJA will retain your Personal Data only for as long as we have a valid business purpose and in accordance with applicable laws.

  13. Applicable Law

    This Privacy Policy shall be governed by and construed in accordance with the laws of Jamaica.

  14. Variation

    POOJA reserves the right at any time without notice to revise the content of the Software and the Terms and Conditions of this Privacy Policy. Any changes to this policy will be posted on the Company’s website and by continuing to use our Software following any such change you hereby agree to be bound by the revised terms and conditions.

  15. How to Contact Us

    Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can always reach us via email at [info@poojapoints.com] or by telephone at [1-888-429-5765].