Privacy Policy

Breathe India Advisors Private limited ("Bigfish") (www.bigfishbenefits.com) ( "Web sites" or "Platforms" aim to protect your personal information and ensure that you continue to trust us with your personal data. When you interact with us, you may share your personal information with us which allows us to determine your identity as an individual (e.g. name, email, address, telephone number, login user names, passwords etc.). This policy applies to the personal data that we collect for the purposes of providing you our valuable services and an enhanced user experience on our Platforms ("Policy").

Bigfish reserves the right to make changes to this Policy at any time, which shall be duly informed to you via notification on the Platforms. We encourage you to regularly review this Policy to ensure that you are aware of changes made to it from time to time.

1. What data we collect

Bigfish collects your personal data, including, inter alia, name, age, sex, date of birth, email, delivery address, telephone number, marital status, login user names, passwords, and your "Official Data", including, inter alia, department, designation, location, country, reporting manager, business unit, business/location human resource contact, date of joining, grade or level, legal entity name, details of employer (collectively, "Personal Data") from the following sources:

a) Documents and information submitted by your employer to Bigfish;

b) Your interactions with us through website, mobile applications or text messaging programs;

c) Our communications with your employer.

Further, Bigfish may use certain technical information that does not permit the identification of an individual and which may be collected during your access or use of the Web sites, such as, log data, analytics code, IP address, version and identification number of the device, browser type, browser language, date and time of your requests, your profile, web sites / links visited by you, search terms used (collectively, "Anonymous Data" ).

2. How we store your Personal Data

Your Personal Data shall be securely stored on servers hosted by reputed Cloud Service Provider ("CSP"). Such CSP shall be liable to keep your Personal Data secure at all times and adopt such technical measures as may be required to meet your reasonable expectation of privacy.

3. Why we collect your Personal Data

Bigfish collects and uses your Personal Data to help your employer engage its employees through various initiatives at work such as learning, recognition and rewards, wellness, collaboration, communication, social causes and such other initiatives that support / further the mission, goals, values and initiatives of your organization and provide other related services. For the above purpose, Bigfish may use your Personal Data:

a) to notify you regarding activities on the Platforms, updates related to various programmes or initiatives that your employer may consider beneficial to its employees and matters incidental thereto.

b) to notify you about functionality and changes on our Web sites, new services and special offers that you may find of value.

c) to create and maintain your accounts with Bigfish, including your transaction details on the Platforms that are associated with your account.

4. Whether we make marketing communications

Except as otherwise consented by you, Bigfish does not sell or otherwise release your Personal Data to third parties to allow them to direct market their products and services to you, identify who you are or remember where you’ve been on the internet. However, Bigfish may use your Personal Data and / or Anonymous Data to provide you with relevant marketing communications such as information about Bigfish, its products and services, competitions and promotions based on your activities on our Platforms. In case you do not wish to receive such marketing information, please email us at support@bigfishbenefits.com.

5. When we can disclose / share your Personal Data

Bigfish shall not disclose your Personal Data to any third party for any reason whatsoever, without your express consent to that effect. However, your Personal Data may be disclosed to or shared with a third party without your consent under the following circumstances:

a) pursuant to a valid and subsisting order of a court or other judicial, quasi judicial or government body under applicable laws or if, in Bigfish’s good faith judgment, such legal disclosure is reasonably necessary to comply with legal processes or respond to any claims

b) change in control or management of Bigfish, a full or partial merger with, or acquisition of all or part of Bigfish by another company.

Further, Bigfish may share your Personal Data with its trusted affiliates or related companies for the limited purposes of providing services on the Platforms, processing of your Personal Data, on need to know basis and subject to confidentiality obligations as may be contractually agreed to between such third party and Bigfish.

6. How we use and process your Personal Data

Bigfish takes all reasonable steps to ensure fair, lawful and transparent processing of your Personal Data. In furtherance of this objective, Bigfish will:

a) notify you in case of usage of your Personal Data for any purpose other than the purposes consented for or stated in this Policy;

b) retain Personal Data only as long as it is necessary for rendering the services on the Platforms except when otherwise required under applicable laws;

c) meet your reasonable expectations of data privacy while processing your Personal Data;

d) use reasonable efforts and security measures, including, a variety of security technologies and procedures to protect your Personal Data from any unauthorized access, use or disclosure;

e) ensure that the data processor maintains written records of the data processing activities carried out on behalf of Bigfish;

f) provide you all information related to processing of your Personal Data, for instance whether or not your Personal Data is being processed, where it is processed and for what purpose it is processed, upon receipt of a written request from you.

7. What rights you can exercise

a) Right of Access: You can access your Personal Data at all times during the subsistence of your account with Bigfish. You are free to review and modify your Personal Data and correct inaccuracies, if any, in your Personal Data, from time to time, after you login to the Web sites. In case you are unable to access, correct, or update any of your Personal Data, you may send us a request at support@bigfishbenefits.com. You can also request us to provide your Personal Data collected by us in a structured and commonly used format. Upon receipt of such request, Bigfish will provide your Personal Data request free of charge within one month from the date of such request, unless such request is manifestly unfounded or excessive. However, Bigfish shall not be liable to retain or provide access to your Personal Data after three (3) months from the date of deactivation of your account with Bigfish.

b) Right to withdraw consent: In the event you wish to withdraw your consent for usage of your Personal Data for any particular activity of Bigfish and its affiliates at any time during the subsistence of your account with us, you can notify us in writing. Upon receipt of such notification, Bigfish shall not use or allow further dissemination of your Personal Data or part thereof, for the purpose mentioned therein.

c) Right of Erasure: If you wish to remove all or any part of your Personal Data collected by Bigfish, its affiliates or any of the related parties, you can raise a request by sending an email to support@bigfishbenefits.com. Your Personal Data will be erased by Bigfish in consultation with your employer: (a) upon receipt of such request for erasure; (b) deactivation of your account with Bigfish.

8. Third Party Links/ External Links

Our Web sites may contain links to content or other functionality provided by third parties which are outside our control and are not covered by this Policy. Accordingly, Bigfish shall not be liable for any breach of your Personal Data which is attributable to the acts or omissions of such third parties.

9. Breach Notification

Bigfish shall intimate any instances of data breach to you without any undue delay and, where feasible, within 72 hours of becoming aware of such breach, failing which Bigfish shall provide reasoned justification for the delay. However, Bigfish shall not be liable to notify you about any minor breach which is unlikely to result in a risk to your rights and freedoms related to your Personal Data. Further, Bigfish shall take all reasonable steps to curve such instances and take all corrective measure to minimize the impact of such data breach.

10. Whether we use cookies

a) What are cookies: Cookies are small text files that are placed on your web browser by Web sites that you visit, in order to make Web sites work more efficiently and generate user specific content and tools.

b) Why we use cookies: We use cookies and other tracking technologies to improve the usage and functionality of the Web sites and to gain a better understanding of how visitors use the Web sites and utilize the tools and services offered to them. Cookies help us tailor the Web sites to your specific needs and preferences and improve various functionalities and user interface, resulting in greater customer satisfaction.

c) What types of cookies we may use

i) Persistent Cookies: It helps recognise you as an existing user, and use our services without signing in again. After you sign in, it stays in your browser and will be read by Bigfish when you return to our Web sites after navigating to other web sites or tabs.

ii)Session Cookies: The technical information stored by session cookies lasts as long as the current web session (usually your current visit to a web sites or a browser session) persists.

iii)Analytics Cookies: These cookies track information about how a user uses the Platforms. Analytics cookies may either be first party cookies or third party cookies. These cookies allow our Web sites to provide you a more personalised online experience.

d) Whether you can opt out of cookies: With most Internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your web browser instructions or help screen to learn more about these functions. However, if you reject cookies, the functionality of our offerings may be restricted.

11. Whether we use any other tracking technologies?

Bigfish uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses analytics cookies, which generate information about your use of the Web sites (including your IP address). Google will only use Anonymous Data and other related information stored during your use of the Web sites, in Google servers, for the purpose of evaluating your use of the Platforms, compiling reports of your activities on the Web sites, and providing other related services. You may refuse the use of the Google Analytics cookies by selecting the appropriate settings on your web browser as mentioned earlier. However, please note that in case you opt out of use of cookies, you may not be able to use the full functionality of the Web sites.

11.1 Privacy-relevant Android permissions requested by Bigfish app Camera

Used for permissions that are associated with accessing camera or capturing images/video from the device. This permission allows this application to capture the users selfies in order for them to be viewed in a timeline within this application.

12. International Transfer of Data

In the process of providing access to the Web sites and processing your Personal Data, Bigfish may transfer your Personal Data to affiliated entities or other third parties across countries or jurisdictions in the following circumstances: (a) where you have given your explicit consent for such transfer; (b) where the transfer is occasional and necessary in relation to a contract or a legal claim, judicial or administrative procedure; or (c) where such transfer is on the legitimate ground of public interest under applicable laws.

13. Communication & Grievances

We will make all attempts to contact you only through email and ensure that your telephone number is used only for the limited purposes of providing the relevant services on the Platforms. In case you have any grievances regarding usages of your Personal Data, you can contact our Grievance Officer at support@bigfishbenefits.com. Upon receipt of such complaint, Bigfish will make all the reasonable efforts to address your concerns at the earliest.

14. Consent

On signing up with Bigfish , you hereby acknowledge and confirm that:

a) you have read, reviewed and understood all the terms of this Policy and its implications and voluntarily agreed to provide your explicit consent for access and usages of your Personal Data for the purpose specified under this Policy;

b) you have been apprised of your right to withdraw your consent at all times during the subsistence of your account with Bigfish without detriment.("Policy").Bigfish reserves the right to make changes to this Policy at any time, which shall be duly informed to you via notification on thePlatforms. We encourage you to regularly review this Policy to ensure that you are aware of changes made to it from time to time.

1. What data we collectBigfishcollectsyour personal data, including, inter alia, name, age, sex, date of birth, email,delivery address, telephone number,marital status,login user names, passwords, and your "Official Data", including, inter alia, department, designation, location, country, reporting manager, business unit, business/location human resource contact, date of joining, grade or level, legal entity name, details of employer (collectively,"Personal Data") from the following sources:a) Documents and information submitted by your employer toBigfish;b) Your interactions with us through website, mobile applications or text messaging programs;c) Our communications with your employer.Further, Bigfishmay use certain technical information that does not permit the identification of an individual and which may be collected during your access or use of the Web sites, such as, log data, analytics code, IP address, version and identification number of the device, browser type, browser language, date and time of your requests, your profile, web sites/ links visited by you, search terms used (collectively,"Anonymous Data").

2. How we store your Personal DataYour Personal Data shall be securely stored on servers hosted by reputed Cloud Service Provider ("CSP"). SuchCSP shall be liable to keep your Personal Data secure at all times and adopt such technical measures as may be required to meet your reasonable expectation of privacy.3. Why we collect your Personal Data