1.1 The website http://www.groupon.co.in (the “Website”) is operated by Friday Media Private Limited (“FMPL”, “we”, “us”, “our”). We are committed to protecting your privacy and we will only use the information we collect about you lawfully and in accordance with the Information Technology Act, 2011, the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 and other applicable laws of the Republic of India
1.3 Your use of this Website indicates to us that you have read and accept our privacy practices, as outlined in this Policy.
2. Types of Information Collected
2.1 We collect two types of information about our Website Users: Personally Identifiable Information and Non-Personally Identifiable Information.
2.2 Our Policy ensures that any information you provide us remains private and secure. To reassure you, below we provide details of the information you provide to us, how it will be used and more importantly, will not be used. We will never collect sensitive information about you without your explicit consent. The information we hold will be accurate and up to date. You shall also have the right to review the information you have provided and ensure that that any personal information or sensitive personal data or information is accurate. In the event, you find the personal information or sensitive personal data to be inaccurate or deficient, you shall bring such inaccuracy or deficiency to our attention and we will carry out such corrections or amendments as feasible. However, we shall not be responsible for the authenticity of the personal information or sensitive personal data supplied by you.
3. Personally Identifiable Information
3.1 Personally Identifiable Information (“PII”) is information that identifies a specific end user. When you engage in certain activities on the Website, such as creating an account, ordering a product or service from the Institutions, submitting content and / or posting content in discussion forums, entering a promotion sponsored by the Institution, filling out a survey, posting a review, sending feedback to us or the Institutions, requesting information about our services or applying for a job (collectively, “Identification Activities”), we may ask you to provide certain information about yourself. It is optional for you to engage in an Identification Activity.
3.2 If you elect to engage in an Identification Activity, we may ask you to provide us with certain personal information about yourself, such as your first and last name, mailing address, email address, cell number, telephone number and date of birth.
3.3 When you order products or services, we may also ask you to provide us with financial information, including but not limited to, your credit card or debit card number, expiration date and authentication codes or related information.
3.4 Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity.
3.6 In the event there is any change in your PII like your address, phone number or email ID, you may send us intimation about the changes and we will make the necessary amendment in our records.
3.7 You may also withdraw your consent, authorizing FMPL to use and collect, disseminate and analyze your PII. Such withdrawal of consent must be sent to FMPL in writing. However, once such consent is withdrawn, FMPL will no longer provide the Services to the User.
4. Non-Personally Identifiable Information
4.1 Non-Personally Identifiable Information (“NPII”) is information that does not identify a specific end user. This type of information may include things like the Uniform Resource Locator (“URL”) of the website you visited before coming to our Website, the URL of the website you visit after leaving our Website, the type of browser you are using and your Internet Protocol (“IP”) address.
4.2 We, and/or our authorized Third Party Service Providers that perform function on our behalf like sending out and distributing our administrative and promotional emails and authorized Third Party Advertisers that provide advertising services to FMPL, may automatically collect this information when you visit our Website through the use of electronic tools like Cookies and Web beacons or Pixel tags, as described elsewhere in this Policy.
4.3 We use NPII to troubleshoot, administer the Website, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with Third Party Service Providers and Third Party Advertisers to measure the overall effectiveness of our online advertising, content, and programming.
5. Sources of Information
5.1 If you choose to become a registered member of this Website, you must provide your name, address, telephone or cell phone number, e-mail address, a unique login name, password, and password validation, and a password hint to help you remember your password. This information is collected on the registration form for several reasons including but not limited to the following:
(i) Personal identification purposes.
(ii) Completing purchases.
(iii) Allowing us to contact you for customer service purposes.
(iv) If necessary, customizing the content of this Website to strive to meet your specific needs.
(v) For making product or other improvements to our site.
5.2 In addition, we need your e-mail address to confirm your new member registration and each transaction you conduct on our site. As a registered member of this Website, you will be entitled to savings and benefits on deals including, but not limited to restaurants, hotels, holiday packages, etc. You could, in addition, look forward to receiving by e-mail monthly newsletters, daily promotions offering special deals, updates for new services, and other noteworthy items. However, you may choose at any time to no longer receive these types of e-mail messages. Please see our Opt-Out Policy described below for details.
6. Member Profile
6.1 As a registered member of this Website, you can choose to complete your online profile by providing us with personal preferences and other personal information. This information is primarily used to assist you in making purchases quickly without having to type in the same information repeatedly. Further, please note that the website not FMPL stores any of your credit / debit card or billing information.
7. Online Surveys
7.1 We value opinions and comments from members, so we frequently conduct online surveys. Participation in these surveys is entirely optional. Typically, the information is aggregated, and used to make improvements to our Website and the Services and to develop appealing content, features and promotions for our Website members. Survey participants are anonymous unless otherwise stated in the survey.
8.1 We may sponsor promotions to give our Website members the opportunity to win prizes. Information collected by us for such activities may include contact information and survey questions. We use contact information to notify the winners and survey information to develop promotions and product improvements to our Website.
9. Automatic Logging of Session Data
9.1 We automatically log generic information about your computer’s connection to the Internet, which we call “session data”, that is anonymous and not linked to any personal information. Session data consists of things such as the IP address, operating system and type of browser software being used and the activities conducted by the user while on our Website.
9.2 We collect session data because it helps us analyze such things as what items visitors are likely to click on most, the way visitors are clicking through the Website, how many visitors are surfing to various pages on the Website, how long visitors to the Website are staying and how often they are visiting. It also helps us diagnose problems with our servers and lets us better administer our systems. Although such information does not identify any visitor personally, it is possible to determine from an IP address a visitor’s Internet Service Provider (ISP), and the approximate geographic location of his or her point of connectivity.
10.3 A cookie may also be placed by our advertising server. Such cookies are used only for purposes of tracking the effectiveness of advertising served by us on our Website and no PII is gathered from you by the use of these cookies, nor is this information shared with any third party. Similarly, a cookie may be placed by our Third Party Advertisers. These entities may use aggregated statistics about your visits to this and other web sites in order to provide advertisements. The information they collect does not include your PII.
10.3 Our Website supports your right to block any unwanted internet activity, especially that of unscrupulous websites. However, blocking our Website’s cookies may disable certain features on the Website, and may make it impossible to purchase or use certain services available on the Website. Please note that it is possible to block cookie activity from certain websites while permitting cookies from sites you trust.
11. Access by Third Party Advertisers
11.1 The Third Party Advertisers may also employ technology that is used to measure the effectiveness of advertisements. Any such information is anonymous. They may use this anonymous information about your visits to this and other sites in order to provide advertisements. No PII is collected during this process. The information is anonymous, and does not link online actions to an identifiable person.
12. Personalized Services
12.1 From time to time we may add or enhance services available on the Website. To the extent these services are provided, and used by you, we will use the information you provide to facilitate the service requested. For example, if you email us with a question, we will use your email address, name, nature of the question, etc. to respond to your question. We may also store such information to assist us in making the site the better and easier to use.
13. Compliance with law
13.1 In addition to the circumstances described above, we may disclose our Website member information if required to do so by law, court order, as requested by other government or law enforcement authority, or in the good faith belief that disclosure is otherwise necessary or advisable including, without limitation, to protect the rights or properties of FMPL or any or all of its subsidiaries and associates, and its employees, directors or officers, or when we have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities. In addition, if FMPL or substantially all of its assets are acquired, our customer information will most likely also be transferred in connection with such acquisition.
13.2 Apart from the above, we may collect information from you for providing our complete range of services like issuing vouchers for products and/or services, maintaining discussion forums, interacting with Website Users for customer feedback and resolving customer queries and issues, processing requests for signing up for special offers and maintenance of Website.
14. Sharing of PII
We will not share your Personally Identifiable Information with other parties except as provided below:
14.1 We issue vouchers for products or services to be provided by Institutions (both restaurant and non-restaurant merchants with whom we have an association for providing you with value deals at discounted price). We share some of your PII with Institutions in order to help them provide you with better service and track the value of our program. Sharing this information will allow an Institution to market directly to you should they choose to do so. However, we will only share PII with an Institution if you engage in an Identification Activity, and then only to the Institution involved in that Identification Activity.
14.2 We provide some of our services through third parties. Third Party Service Providers perform functions on our behalf, like sending out and distributing our administrative and promotional emails and text messages.
14.3 We may share your PII with Third Party Service Providers to fulfill orders, deliver packages, send post, text messages or email, administer promotions, remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit / debit card payments, operate the Website, troubleshoot, and provide customer service.
14.4 Please note that as part of any PII sharing which we list above, we may send your information internationally. Some places outside of India may not have adequate data protection laws at all or may offer differing levels of protection of personal information which are not as high as in India.
14.5 We may also collect personal information from individuals and entities with whom we have business relationships (“Business Associates”) and may have to also share their information with Third Party Service Providers to accomplish our administrative tasks. For example, when you order a service, we release your financial (credit card, debit card, net banking, mobile payment, etc) information to the card-issuing bank / provider to confirm payment for the service and, if applicable, release your address to the delivery service to deliver the service. We encourage Institutions and Third Party Service Providers to adopt and post privacy policies. Nonetheless, any, Institution, Third Party Service Provider, Third Party Advertiser or Business associate receiving the PII from us will not disclose it further.
15. Sharing of NPII
15.1 We may disclose or share NPII with Business Associates and Third Party Advertisers. For example, we may share aggregated demographic information (which does not include any PII) with Third Party Advertisers and other parties. We may use Third Party Advertisers to serve advertisements when you visit our Website. These companies may use NPII about your visits to this and other websites in order to provide, through the use of network tags, advertisements about goods and services that may be of interest to you. We also use Third Party Service Providers to track and analyze NPII usage and volume statistical information from our Users to administer our Website and constantly improve its quality. We may also publish this information for promotional purposes or as a representative audience for Third Party Advertisers. Please note that this is not PII, only general summaries of the activities of our Users. Such data is collected on our behalf, and is owned and used by us.
16. Opt-Out policy
16.1 At any time, you may unsubscribe from our alert email or text message or other newsletter or similar services through the link on our Website. As a member, you will occasionally receive e-mail updates from us about special offers, new services, and other noteworthy items. If you do not wish to receive them, please click on the “unsubscribe” link or follow the instructions in each email message. We reserve the right to limit membership to those who will accept such emails. Members will be notified via email prior to any actions taken.
17. Data Security
17.1 We take reasonable steps to maintain the security of the PII that we collect, including limiting the number of people who have physical access to our database servers, as well as installing electronic security systems that guard against unauthorized access. We have a comprehensive document information security program and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with the information assets being protected. However, no data transmission over the Internet can be guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security of any information that you transmit to us, so you do so at your own risk.
17.2 The Website and Minisites comply with the IS/ISO/IEC 27001 code.
17.3 The PII we hold will be held within our systems in accordance with our internal security policy and the law. We hold data until 3 years after it is last accessed or used by us.
18. Payment Security
18.1 All payments on our Website are secured. This means all personal information you provide on the Website is transmitted using SSL (Secure Socket Layer) encryption. SSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. The same process is replicated when you make purchases on our Website.
19.1 Our Website contains links to other web sites. Please note that when you click on one of these links, you are entering another web site for which we have no responsibility. We encourage you to read the privacy statements of all such sites as their policies may be materially different from this Policy. Of course, you are solely responsible for maintaining the secrecy of your passwords, and your Website membership account information.
19.2 This Policy is effective as of August 4, 2011. Any material changes in the way we use personal information will be described in future versions of this Policy. Of course, you may always submit concerns regarding our Policy or our privacy practices via email to firstname.lastname@example.org. Please reference the policy in your subject line. We will attempt to respond to all of your reasonable concerns or inquiries within [·] business days of receipt of your email.