Except for certain information that is required by law or by Turquoise’s policies (including management of an employment relationship with the company name), your decision to provide any personal data to us is voluntary.  The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to register) or indirectly from certain third parties (for example, we may collect information from credit reporting services when you use certain of our Services. We use the information as needed in the course of providing services you request, ongoing customer relationships, to service and account, and as permitted by state and federal law) including and not limited to publicly available sources (e.g. internet), public authorities, public websites and social media, third party data providers, Turquoise’s subsidiaries and newly acquired businesses, suppliers and vendors. Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors. In those circumstances, the privacy policy of that third party will apply.

You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your data, or by utilizing opt-out mechanisms in e-mails we send to you. In such cases, we will retain minimum personal data to note that you opted out to avoid contacting you again.

Apart from the aforementioned purposes, some other purposes for the collection of data include:

• To maintain our security and transparency and protect against deceptive, fraudulent or illegal activity including attempts to manipulate or violate our policies, procedures and terms and conditions.
• To conform with legal obligations, to institute or exercise our rights, to defend against a legal claim, and to investigate, avert, or take action regarding likely misconduct.
• For such other purposes that are per existing legislation and as you may from time-to-time consent to.

Although the purposes hereinbefore mentioned are chief purposes, there are other ancillary and incidental purposes to certain activities that have an implied purpose of collection and storage of your data. For example, when you’ve completed an online purchase, we may retain your data and information so that we can assist you better in case you have queries about your purchase. Hence it follows that our collection, retention, sharing and controlling of your data has their basis in a number of different contexts and we do not fall outside the ambit of any legislation on data protection laws and the underlying purpose is to facilitate our contractual obligations.

3. Sharing or Disclosing of Your Information

Apart from the specific situations discussed elsewhere in this policy, we may disclose your Personal Information in the following situations:

• We may share your information with our Websites and Apps for purposes and uses consistent with this Privacy Policy. We also may share your Personal Information with our corporate affiliates (e.g., parent company, joint ventures, other companies under common control etc.). If another company acquires our plans to acquire, our company, business, or our assets, we will also share your Personal Information with that company using appropriate safeguards, including at the negotiation stage.
• We share the information with the business clients on whose behalf we collect the said information.
• We may share your information with third parties who provide specialised services on our behalf to help with our business activities including authentication services, email service providers, and data analysers to facilitate our services. These companies are authorized to use your personal information only as essential to deliver these services to us.
• We may share aggregated, anonymous information with any third party.
• Some of our Services may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on our Services, that information may be publicly available.
• We may disclose information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your information to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, the safety of person or property, or a violation of our policies.

4. How Long Do We Retain Data?

We are committed to protecting your data and we do not keep your personal information for a period longer than necessary for the purposes for which it is processed. The periods of such retention vary for different situations and contexts, depending on your interactions with us. We do not store such personal information without your prior consent.  Once the purposes for which we process your data have concluded, we will either permanently delete or destroy or anonymize it, in a manner that ensures individuals are no longer identifiable.

5. Your Rights and Choice

• Right to Data Portability – this entitles you to receive a copy of personal data that you have provided to Turquoise or request Turquoise to transmit such personal data to another data controller.
• Right to be Forgotten – this right entitles you to request the erasure of your data, including where such personal data would no longer be necessary to achieve the purposes.
• Right to Rectification – this right entitles you to correct, complete or update your information if it is incorrect or incomplete.
• Right to Access – this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
• Right to Object – this right entitles you to object to the processing of data by Turquoise should you wish for Turquoise to stop processing your data.
• Right to Restriction – this right entitles you to request Turquoise to process your data in only specified and limited situations, including with your consent.
• Right to Withdraw Consent – If you revoke your consent for the processing of Personal Information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

Contact us at contact@trqauto.com to exercise any of your rights. If despite your requests and our efforts to address your concerns, you believe that we violate your privacy rights, we strongly encourage you to come to Turquoise first and register a complaint with the relevant authorities here to seek resolution of your complaints or you could alternatively make a claim against Turquoise with a competent court.

6. Security of Your Data

No method of transmission over the internet is fully secure. However, we do use reasonable mechanisms and measures to ensure utmost transparency, accountability and responsibility to protect your data under the data privacy laws in force. We may notify you electronically, in writing, or via telephone if permitted by law, in case of any breach of security of your data.

7. Miscellaneous

We may update and change our privacy policy from time to time. We will notify you through our Services of any material changes to our privacy policy and specify when it was recently updated or modified.

We understand how critical and personal your children’s information is and that it must be protected and safeguarded. Our services are intended to be directed toward a general audience and not minors.  We do not knowingly collect or use the information of minors (i.e., ‘minor’ as understood by laws of your country) without prior verifiable parental/guardian’s consent. If we learn that a minor has submitted personal information to us, we would take reasonable measures to remove such data from our databases.

8. Jurisdiction

If you choose to visit the website, your visit and any dispute over privacy are subject to this Policy and the website’s terms of use. In addition to the foregoing, any disputes arising under this Policy shall be governed by the laws of India.

Further, please note that our mobile applications store your data with the cloud Platform provided by Heroku, which may store this data on their servers located in London, United Kingdom. Heroku has security measures in place to protect the loss, misuse and alteration of the information, details of which are available at https://www.heroku.com/policy/security. The privacy policy adopted by Heroku is detailed https://www.salesforce.com/company/privacy/.

In the event, you have questions or concerns about the security measures adopted by Heroku you can contact their data protection/ privacy team/ legal team or designated grievance officer at these organisations, whose contact details are available in its privacy policy, or can also write to us at the address provided below.

9. Contact us

For any further assistance or queries, you can reach us at contact@trqauto.com