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Privacy

Your privacy is important to us, and the Cactus Communications Group (“CACTUS,” “the Company,” “we,” “our,” or “us”) is committed to protecting your privacy whilst providing a personalized and valuable service.

Here at CACTUS, we are committed to safeguarding your data while rendering our professional services. PubSURE is a brand and division of CACTUS India that operates through various group entities including, but not limited to, entities located in Singapore, Japan, China, Korea, the United Kingdom, and the United States.

This Privacy Policy governs our data collection, processing, and usage practices. It is designed to allow the Data Subject (“you”) to make an informed choice regarding use, access, and correction of your Personal Information.

If you have any requests concerning your Personal Information or any queries about these practices, please contact us by e-mail on privacy@cactusglobal.com or you can contact us by writing to Cactus Communications Private Limited, 510, Shalimar Morya Park, Off Link Road, Andheri (West), Mumbai 400053, Maharashtra, India.

1. Personal Data That We Collect

We collect from Personal Information from you including full name, gender, date of birth, address, job title, company information, e-mail addresses, telephone numbers, identification details, and referral source. If you are a Service Provider we will also collect payment information (including bank, credit/debit card details, and electronic payment ids) billing address, and work and education profile. This data may include IP Address, operating system, and browser type.

We may also have acquired your Personal Information from a third-party Service Provider or publicly available data source/s.

2. How We Use Your Personal Data

As Data Controller:

We use the information we collect only in compliance with this Privacy Policy. We will never sell your Personal Information to any third party without your explicit consent. In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to (a) assist you with service, partnership, or employment request; (b) send to you information that we think may be of interest to you by post, email, or other means; (c) send you marketing communications relating to our business (including any profiling we engage in that is related to such direct marketing); (d) respond to an enquiry, question, or concern that you may have raised; or (e) perform analytics and create a database to improve your browsing experience and enhance the functionality of our services.

We may share Personal Information with trusted Service Providers or our group companies for payment processing, supplementing the information you provide us in order to provide you with better service, perform statistical analysis, provide marketing assistance, host the site and index user profile pages and usernames as part of the URL and customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. If you do not want us to share your Personal Information with these third parties, contact us at privacy@cactusglobal.com.

To facilitate our global operations, we may transfer and access Personal Information from around the world. This Privacy Policy shall apply even if we transfer Personal Information to countries outside the European Union.

After you place an order on our Website, you will need to make payment for the services you have ordered. In order to process your payment, we use a number of third-party payment processors. Your payment will be processed by the payment provider you choose to process your payment via a payment gateway. If you give us banking, debit card, credit card, or other payment mode details, we solely use such details to process refund of payment to you. The third-party payment processors we use also collect, use, and process your information, including payment information, in accordance with their privacy policies. To ensure that the security and integrity of the Site is safeguarded, CACTUS may monitor your Personal Information. CACTUS may under certain circumstances engage a trusted third-party

Service Provider for the purpose of managing the technical operations involved in hosting the Site. Information you submit to us via the contact form on our Website will be stored outside the European Economic Area on our third-party hosting provider’s servers in Singapore. To the extent that it may be necessary, and solely for the purposes of providing the service available on the Site to you, we may disclose to such third party any of your Personal Information that may be necessary for the procurement of services from the third party.

2. How We Use Your Personal Data

We shall use and process the information or data we collect through Data Controllers/Controllers (“Business Partner”) as per the instructions given by Controllers and in compliance with the terms and conditions applicable to Processors under Controller/Processor Binding Agreement entered with the Controllers and applicable Regulation. We agree not to process such information to sub-processors (Sub-contractor), unless prior written consent is sought from the Controller, and in the event where general consent has been given by the Controller, we shall inform the Controller of any new sub-processor. We shall have the same contractual obligations reflected with the sub-processors as agreed with the Controller and assume complete responsibility for the actions and inactions of such sub-processors.

Upon written request from the Controller, we agree to delete or return all the Personal Information or data to the Controller after the end of the provision of services relating to processing, unless there is a legal obligation or basis for us to retain a copy of such information or data for further processing. The information or data collected through the Controller will be stored outside the European Economic Area on our third-party hosting provider’s servers.

In addition to implementation of appropriate technical and organizational measures to ensure an appropriate level of security, we shall make available to the Controller all information necessary to demonstrate compliance with our obligations, and allow the Controller or another auditor appointed by the Controller for conducting audits, including inspections, to demonstrate that processing meets the requirements of the Regulation, and ensure the protection of the rights of the data subject.

3. Children’s Personal Information

CACTUS does not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through our Websites or Service(s). We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Service(s) or Websites without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our Websites or Service(s), please contact us at privacy@cactusglobal.com, and we will endeavor to delete that information and terminate the child’s account from our databases.

4. Retention of Personal Information

We retain Personal Information that you provide us as long as an Account is active or as needed to provide the Service(s) or as necessary to comply with our legal obligations, maintain accurate financial and other records, resolve disputes, and enforce our agreements. If you wish to terminate your Account or request that we no longer use Your Personal Information, please contact us at privacy@cactusglobal.com.

Criteria for determining retention periods In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

5. Use of Cookies & Similar Technologies

Cookies are data files that are sent from a website to a browser to record information about users for various purposes. We use cookies, including essential, functional, and analytical cookies. For further information on how we use cookies, please take a look at our cookies policy below:-

Cookie Policy

CACTUS uses cookies (small text files placed on your device) and similar technologies to help you personalize your online experience. Cookies allow us to store your preferences and settings (so that you do not have to fill in your details every time you visit one of our Company websites / online platform); enable you to sign-in; provide interest-based advertising; and analyse how our websites and online services are performing. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time.

We and our third-party service provider use technologies such as Web Beacons for analysing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We use such information for Site traffic analysis. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

We gather certain demographic information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This information is used by CACTUS to maintain quality of the Services and to provide general statistics regarding use of the Website.

You have ability and variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies. If you choose to decline cookies, you may not be able to fully experience the interactive features of the CACTUS Service or Websites you visit. Do Not Track. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you targeted advertising based upon your interests.

What are our cookies used for?

CATEGORY DESCRIPTION
Necessary

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Cookie list: cfduid [x15] PHPSESSID [x8] __jid CookieConsent has_js [x2]SESS# [x3] AWSELB [x4] JSESSIONID [x2] language FormSpringFormSession#

Preferences

Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.

Cookie list: lang [x2] uid [x4] FormSpringFormView#

Statistics

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Cookie list: _ga [x6] _gat [x5] _gid [x6] __utma [x5]__utmb [x5] __utmc [x5] __utmt [x5] __utmz [x5] disqus_unique _at.hist.# _ceg.s _ceg.u _vis_opt_exp_#_combi _vis_opt_s _vis_opt_test_cookie _vwo_uuid _uv_id e.gif v.gif

Marketing

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Cookie list: IDSYNC __hssc [x2] __hssrc [x2] __hstc [x2] hubspotutk [x2] bt2 loc uvc vc xtc sess uuid2 TDCPM TDID OAID U [x2] c [x2] tuuid [x5] MUID CMDD CMID CMPS CMRUM3 CMSC CMST pb_rtb_ev sto-id-20480-bh V _cc_aud _cc_cc _cc_dc _cc_id __adroll demdex IDE test_cookie __ar_v4 __atuvc __atuvs __unam __zlcmid _at.cww _hjIncludedInSample _te_ at-lojson-cache-# at-rand zte# everest_g_v2 fr ads/ga-audiences NID visit uuid __ptq.gif _kuid_ bcookie [x2] bscookie leo_auth_token lidc uuidc i KADUSERCOOKIE KRTBCOOKIE_# PUBMDCID ck1 drtn# rlas3 khaos put_# rpb UID UIDR SEUNCY __stid SomaCookieUserId TapAd_DID TapAd_TS wfivefivec AFFICHE_W B PREF VISITOR_INFO1_LIVE YSC tuuid_last_update [x3] um umeh bsw_uid cw_id di2 mus BizoID UserMatchHistory _ansscnt _uuid cm.gif APID advst_uid_11 DISPATCHER __upin __upints livinreff reffsync tuuid_lu MUIDB GLOBALID CMPRO rum voluum_dsp_user dpm G_ENABLED_IDPS vglnk.Agent.pvglnk.PartnerRfsh.p user_id [x2] tr ads/user-lists/# usersync BSWtracker [x2] _li_ss lidid LIG_# pi io.narrative.guid.v2 w/1.0/sd adrl obuid did didts nnls pxrc [x2] has_data status suid/1011 visitor dsps:# PugT ruid #.gif rtn1-z rpx tap.php stx_user_id sync/v1 __uin_bw __uir_bw __uis sa-user-id sa-user-id-v2 t_gid taboola_usg bt3 btv3.Xebcych personalization_id 0123456789 UID{32} ul_cb/sync um2 matchliveramp wistia-http2-push-disabled yandexuid zuid

Others

Others cookies are cookies that we are in the process of classifying, together with the providers of individual

Cookie list: trendmd-track-cookie bidswitch_id device_view [x2] buid_# cookie_id __ivc [x2] caltat coull_bsw avlcnt avlukey DigiTrust.v1.Identity __distillery __lotl __zlcstore _gd# _lo_u _lo_uid _lo_v _lorid _ncf _s _shopify_fs _shopify_s _shopify_y _vwo_ds _vwo_sn _vwo_uuid_v2 _WE_11b563b44 _y at_cm counter counterExp d5d9cba05c041850849f94fa23c96316.shop-and-learn.myshopify.com fcspersistslider-in2 FlyCookie FSAC FSAV fsFonts lo::behaviorTags lo_session lo_session_in login loglevel muxData time timezone ub-emb-33b93354-d6f9-47ad-8811-c43e21f11066 ub-emb-f0d67e38-0eeb-4dff-b614-267d1b6fd7d4 ub-emb-id wistia wooTracker amplitude_cookie_test tracking_session_id guest theme userReferer sd-session-id VID AWSALB [x2] __pdvt pd_test zync-uuid RT SERVERID __tld__ ajs 3Acookies ajs_group_id ajs_user_id amplitude_id_5c62c1c25b9e0178aec337afbd6e86e5typeform.com amplitude_idundefinedtypeform.com amplitude_testtypeform.com first_interaction dspuids

You can reject some or all of the cookies we use on or via our Website by changing your browser settings, but doing so can impair your ability to use our Website or some or all of its features. For further information about cookies, including how to change your browser settings and other ways in which you can reject cookies, please visit www.allaboutcookies.org or see our cookies policy.

6. Security of Your Personal Information

a) We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure

b) All our Information security processes are ISO/IEC 27001:2013 compliant.

c) All our employees and Service Providers have signed confidentiality agreements where they have undertaken that they will not make any Personal Information available to anyone, unless authorized in writing by the user.

d) Personal Information will not be made available to any third party, except as provided herein or by obtaining your prior written consent.

e) All documents submitted are managed through a secure online job management system; the documents that are sent to us can only be viewed by service professionals working on your assignment.

f) Payment-related Personal Information:

CACTUS has put in place the following security practices and procedures to protect your Personal Information from unauthorized access, use, or disclosure:

i. The Site uses Secure Socket Layer (SSL) encryption when accepting paymentrelated Personal Information, to ensure that your payment-related Personal Information is secure.

ii. In order to protect your credit card information, all online transactions are conducted using a secure 256-bit SSL encryption signed by VeriSign. Encryption ensures that no information is accessible to unknown parties. CACTUS hereby undertakes not to store your credit card information, thereby reducing the possibility of fraudulent charges being made by CACTUS.

7. Hyperlinks

Our Company Websites contain links to other websites, including without limitation those websites of other companies within the CACTUS group. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the said websites. We are not responsible for the privacy practices nor do we accept any liability about the content of such websites including those of our group companies that have their own privacy policies tailored for the business practices and sectors in which they operate.

8. Testimonials & Public Forums

8.1. We post on our Websites customer testimonials/comments/reviews that may contain Personal Information. Prior to posting the testimonial, we obtain the customer’s consent to post their name along with their testimonial. If you want your testimonial removed, please contact us at privacy@cactusglobal.com.

8.2. Our Websites offer publicly accessible blogs, community forums, or discussion board posts. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You agree and acknowledge that the use of such information is not confidential, does not constitute Personal Information, and is not subject to protection under CACTUS’s Privacy Policy.

9. Corporate Events

In the event CACTUS goes through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account and personal data will likely be among the assets transferred. You will be notified via a prominent notice of any such change in ownership or control. During such event, we may also disclose your Personal Information to any other third party with your prior consent.

10. Responsibility with You

When you submit any Personal Information to us, you represent that you have the lawful right to submit the Personal Information and agree that you will not submit any information unless you are legally entitled to do so and that such Personal Information is true, complete, and accurate. You may not use a false email address or other identifying information to impersonate any person or entity, or otherwise mislead as to the origin of any content. Any improper collection or misuse of Personal Information is in violation of this Privacy Policy and of the applicable terms and conditions of use.

You agree not to misuse any Personal Information available on our Site or to gather it or use robots or other automated scripts, codes, or functionalities to do so. We may immediately suspend or terminate your access to our Site without notice if we become aware that you are in breach of applicable terms and conditions of use or of this Privacy Policy.

11. Opting Out and Unsubscribing

11.1. Reviewing, Correcting, and Deletion of Your Personal Information Upon request, CACTUS will provide you with information about whether we hold any of your Personal Information. We allow users of the Service(s) or Website to access, update, or modify their information by clicking on the My Account link in the CACTUS navigation menu. If you provide us with your Personal Information, you have the following rights with respect to that information:

To exercise any of these rights and requests, please contact us at privacy @cactusglobal.com or by postal mail to Cactus Communications Private Limited, 510, Shalimar Morya Park, Off Link Road, Andheri West, Mumbai 400053, India, Attention: Privacy Team. We will respond to your request within reasonable timeframe and notify you of the action we have taken.

11.2 Opting Out and Unsubscribing

Your registered email address will be automatically subscribed to our weekly newsletter, which will contain information on industry updates, author resources, upcoming webinars, latest offers, and new services by CACTUS. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by sending us an email at privacy@cactusglobal.com. Customers cannot opt out of receiving transactional emails related to their account with us.

12. Sensitive Personal Information

What Is Sensitive Personal Information?

“Sensitive Personal Information” is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health, or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive Personal Information from individuals, and you must not submit sensitive Personal Information to us.

If, however, you inadvertently or unintentionally transmit sensitive Personal Information to us, you will be considered to have explicitly consented to us processing that sensitive Personal Information.

13. Amendments to Privacy Policy

We may update this Privacy Policy from time to time to keep up with changing legislation and best practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective. Provided that we will not notify you if we amend the Policy to make addition, deletions, or modifications to the list of cookies from time to time, to keep the list of cookies current and accurate. Your continued use of this Websites or the Service(s) following the posting of any amendment, modification, or change to this Policy shall constitute your acceptance of the amendments to this Policy. You can choose to discontinue use of the Websites or Service(s) if you do not accept the terms of this Policy or any modified version of this Policy.

14. Legal Disclosure

We reserve the right to disclose your personal data as required by applicable law, in response to lawful requests by public authorities, including meeting national security or law enforcement requirements and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us.

15. Contact Us

If you have any questions about this Privacy Policy or the data we hold about you or you wish to ensure that the data we hold about you is accurate and kept up to date, please do not hesitate to contact us at privacy@cactusglobal.com.

Effective Date: February 1, 2019