Privacy Policy

Last updated on 13 March 2019.

Mara Labs, Inc., and Mara Studios Private Limited (hereinafter referred to as “Company”, “We”, “Us” or “Our”) owns, operates and maintains the website https://locus.sh (“Website”) referring to its product Locus through which the Company provides services to its clients (hereinafter referred to as “Client”, “ User”, “You” or “Your”) and assist in managing intra-city logistics for scheduled and on-demand deliveries (“Services”). In order to provide the Services in an efficient manner, the Company collects certain information regarding the Client and the customers of the Client. We value the trust placed by You and therefore, We follow the highest standards of privacy guidelines to protect the information shared by You with Us.

This Privacy Policy (“Policy”) governs the use of Personal Information shared (as defined below) with or collected by the Company from its Clients. This Policy describes and helps a Client understand our policies and procedures related to collection, use, storage, processing, disclosure and protection of any information including, but not limited to, business or personal information provided by the Client. The Policy shall further assist the Client in understanding the ways in which his/her information can be updated, managed, exported and deleted. Clients shall mean and include any person/persons, who visits, uses, deals with and/or transacts through the Website and includes a buyer, guest user and browser. In circumstances where the User is less than 18 years of age, consent from the legal guardian shall be required and it is advised that this policy be read in the presence of the legal guardian.

This Policy has been drafted in accordance with the General Data Protection Regulation, 2018 (“GDPR”), the Information Technology Act, 2000 (“IT Act”) and the Information Technology (Reasonable Security Practices and Procedures And Sensitive Personal Data or Information) Rules, 2011 (“IT Rules”). This Policy is subject to change from time to time and shall be uploaded on our Website for Your reference. The notice of a change in Policy shall be duly provided to You for your perusal. Please review the amended Policy to be updated with the latest changes and modifications. We are committed to safeguarding the information of our Clients and continue to provide them with the control over their Personal Information and means to determine how the information is being used.

We take Privacy with utmost Seriousness and care. We take utmost care and due diligence to ensure Privacy aspects of each and every individual who interact with our solutions and Services are taken care of, by design and by default, in alignment with all applicable laws and regulations.

Our Privacy policy detailed below explains our perspective and stance towards Privacy and processing of personal information, what data we collect and what we do with it. It also explains how the rights of every individual whose personal information we are dealing with, is effectively protected and fulfilled. Our Privacy Policy explains:

  • What nature and extent of personal information we collect, how we collect it and why.

  • How we use that information.

  • The options and methods we offer to individuals to fulfil their right towards Privacy, including how to access and update information.

Your privacy matters to us, and hence please do take the time to get to know our policy and practices.

Also, please be aware that these could be reviewed and updated to make our practices towards Privacy better and stronger.

All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Use.

  1. Collection and Use of Personal Information

    Personal Information’, ‘Information’ and ‘Sensitive Personal Data or Information ’ shall have the meaning ascribed to it under the GDPR, IT Act, 2000 and IT Rules read together.

    1. Category of Data

      Data is ingested into our systems through Locus website in many ways. This can be either through registering for Demos, when one subscribes for newsletters or when one is tracked while visiting the website. The following is a list of all different Personal Identifiers (“PIDs”) (such as name, IP, address, Pixel tags, Device ID) that are collected segmented by the entry point and what We do by collecting that information.

      The information provided by you is used only in accordance with purposes described in the policy, only with specific consent from your end for the same.

      1. Subscribing for Newsletters

        • email (used to send out newsletters via Mail Chimp)

      2. Registering for Demos

        • name

        • email

        • contact number

        • company name

      3. Website Tracking

        • ip

        • browser name

        • location

      4. Case Study Download

        • name

        • Email

        • Contact

        • company name

      5. Confirming on Demo

        • Contact Number

        • Name

        • Email

    1. Sub-Processors

      The PIDs of Users are shared with many vendors such as self-serve tools like Zoho Sales IQ, GA or many 3rd party providers.

      We have provided below a list of all our vendors who receive PIDs, We have also detailed the PID shared with such vendors and the purpose for sharing such PIDs

      1. MailChimp

        • PID shared: email, name, company

        • Purpose: Mail Chimp sends newsletters to You on Our behalf

      2. LinkedIn, Google Adwords and Facebook Adverts

        • PID Shared: email id

        • Purpose: This partner assists Us with automated campaigns targeting audience who might find Our products useful

      3. Zoho Sales IQ/ Zoho CRM

        • PID Shared: IP Address, browser information, email ids (if available)

        • Purpose: This vendor assists us with understanding the user behaviour on Our Website in order to enable Us to improve Our services.

    1. Transfer of Data

    2. The Data collected will be stored in the cloud based Servers and Databases owned and managed by us and/or our partners and authorized sub-processors.

      The data might be stored and/or transferred within or outside the region of collection, in order to fulfil the agreed and lawful processing. However any transfer of data outside the region of data subjects will be done in compliance with the applicable Privacy acts and regulations.

    1. Demographic Information

    2. We may track certain information about You based upon Your behaviour on the Website, Services purchased by You or the nature of business You are engaged in. We use this information for conducting internal research on Our Users' demographics, interests, and behaviour to better understand, protect and serve Our Users. This information is compiled and analysed on an aggregated basis.

      We may also collect Your Information to track user behaviour and preferences for internal analytics and research. We may also use Your information: (i) to perform analytics and conduct customer research, to determine Your interest, for identifying Your preferences in order to enable Us to provide You with services or products of Your preference and to analyse traffic patterns.

      If You choose to post messages on Our message boards, chat rooms or other message areas or leave feedback, We will collect that information You provide to Us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

      If You send Us personal correspondence, such as emails or letters, or if other users or third parties send Us correspondence about Your activities or postings on the Website, We may collect and store such information.

      We identify and use Your IP address to help diagnose problems with Our server, and to administer the Services. Your IP address is also used to help identify You and to gather broad demographic information in order to enable Us to understand and plan marketing strategies to serve You better.

      We will occasionally ask You to complete optional online surveys. These surveys may ask You for contact information and demographic information (like zip code, age, or income level). We use this data to tailor Your experience for provision of Services.

    1. Children

    2. We do not provide services or sell products/services to, nor engages or recruits/employs children under the age of 18. Hence, as a business and organization context, there are no avenues where we collect and processes personal data of children below 18 years of age.

      We don’t use the personal data collected/provided to us for any purpose other than:

      • Those which are detailed in this privacy Policy.
      • Those which we have sought and received specific consent from our Data subjects.
      • Those which are explicitly included in our formal Data processing agreement with our Customers as Data controllers.
      • Those which are obligated by any applicable laws and regulations.
    1. Recruitment

    2. As a part of our recruitment process, we might also collect your personal information from other sources such as LinkedIN,Job Portals or consulants. In addition to the personal information mentioned above, specific details such as Education, Qualification, Family, Employment and Salary details might also be sought and collected from you, during the process, subject to specific consent from your side for the same

      The data collected for Recruitment purpose will only be used for the purposes and processes related to the same, as per the consent received from you, and in accordance with applicable laws and regulations.

  1. Cookie

    1. We use data collection devices such as "cookies" on certain pages of the Website to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. "Cookies" are small files placed on Your hard drive that assist Us in providing Our services.

    2. Cookies can also help Us provide information that is targeted to Your interests. We also use cookies for debugging, and for analytics for various purposes including but not limited to identifying the usage of the web based dashboard provided by Us. Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if Your browser permits, although in that case You may not be able to use certain features on the Website.

    3. Additionally, You may encounter "cookies" or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties.

    Please refer to our Cookie Policy

  1. Disclosure of Personal Information with Third Parties

    1. We may disclose Personal Information to affiliates and group companies. We may also disclose Your Personal Information with third parties strictly on confidential terms. We may disclose such information to third parties in order to provide You with customer support facilities, to comply with Our legal obligations, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to the Website and to avail services from third parties in order to improve and manages Our services and for data analysis and market research.

    2. In the event of any requirement by court order, government or quasi-government agency to disclose Your Personal Information, We will disclose information as may be legally required. We may also disclose Your Personal Information if We, in the good faith believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process.

    3. In the event the Company is merged with or acquired by another company or in case of re-organization or re-structuring of business, We and Our affiliates will share Your Personal Information, wholly or in part, with another business entity.

    4. Some of the personal data may also be shared with designated Service/solution providers who act as sub-processors for designated purposes, such as Marketing services, recruitment and Payroll Services, and other technical services such as emails, spam filtering, analytics, monitoring and troubleshooting etc. We contractually require our agents, service providers, and affiliates who may process personal data related to the Services to provide the same level of protections for personal data as required under the Principles and applicable laws and regulations. Locus currently does not transfer personal data to a third party for the third party’s own use, but only for Locus purposes as a part of our legitimate business purposes as a Data Controller and Data Processor.

  1. Promotional and Marketing Activities

    1. We will send communications to You at regular intervals to notify You of, among other things, various offers, and exclusive deals etc., that may be available or new services that You may be interested to subscribe.

    2. However, if You do not wish to receive any communication from us, You may request to opt-out by writing to us at support@locus.sh. or choose the unsubscribe provided to You with each communication. Once, We are in receipt of Your request, We will cease sending promotional messages to You.

  1. Security and Compliance with Laws

    1. We strive to protect Your Personal Information against unauthorized disclosure, misuse, unlawful use, modification, loss or destruction. We take all reasonable measures and precautions, as per standard industry practices, to keep Your Personal Information confidential. We ensure compliance with all applicable laws including GDPR and IT Rules.

    2. We take Data Security including that of Personal Data very seriously. All our systems and processes are planned, designed and managed by keeping Security and Privacy in mind.

    3. We have established an effective Personal Information Management System (PIMS) in alignment with BS10012:2017 standard.

    4. A robust information Security Management system (ISMS) is established that governs our systems and practices, in alignment with ISO/IEC 27001:2013 standard. The system is subject to strong controls including ongoing monitoring, periodic Security testing, internal/external audits and verifications.

    5. We contractually require our agents, service providers, and affiliates who may process data related to the Services to provide the same level of protections for data as required under the Principles and applicable laws and regulations.

  1. Rights of the Users

  2. The primary rights of the Users with respect to data protection are:

    1. The right to access: Users shall have the right to confirm whether or not the Company is allowed to process their personal data. Additionally, all Users shall have the right to access the Personal Information shared with the Company including certain other information like the details relating to the purpose of processing information which We shall provide them with upon their demand.

    2. The right to rectification: The Users shall have the right to correct any inaccurate Personal Information about themselves and further complete any incomplete information related to them which is available on the Website.

    3. The right to erasure: Users shall at all times have the right to erase any Personal Information concerning them without any undue delay. In such case, the User is required to request Us to delete the Personal Information relating to such User by writing to Us at security@locus.sh.

    4. Right to restrict processing; Users shall have the right to restrict the Company from processing their Personal Information entirely or for any specific purpose as detailed under this Policy. However, the Company shall continue to have the right to process such Personal Information if the same is required as per applicable laws or to defend any legal claims against the Company.

    5. Right to Object Processing: Users have the right to object to our processing of their personal data for one or more purposes. Any such formal objection from user will be seriously recorded, analysed and necessary actions will be carried out within reasonable time limits.

    6. Right to data portability: Users shall have the right to receive the Personal Information provided to the Company to be received in a readable format in order to share it with a third party. For this purpose, the User has the right to direct the Company to share such Personal Information with the identified third party directly.

    7. Right to withdraw consent: The personal Information processed by Us is conditional upon the requisite consent being provided by You to process such personal Information. Clients shall have the right to withdraw such consent at any time should they wish to decide against permitting the Company process their Personal Information.

    8. Access to Information: Users have right or they are able to upon request to have confirmation whether or not personal information concerning them is being processed, and where that is the case users have access to personal information, they can have a piece of copy of their personal information and how it is processed.

  1. Retention and Disposal of Personal Data

    We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected.

    The Retention of Any Personal Data in our Systems will be limited to the terms agreed in Our contracts/agreements with our customers, as well as the the requirements in applicable laws and regulations.

    We don’t retain the data beyond the tenure required by our Customer and / or any applicable laws/regulations.

  1. Amendments

    We reserve the right to modify the terms of this Privacy Policy from time to time in order to ensure compliance with applicable laws (“Updated Terms”). The Updated Terms shall be effective immediately and shall supersede these the terms of this Privacy Policy. The notice for any change in the policy shall be duly provided to you. Please be advised to be updated related to any changes in the policy.

  1. Governing Law

    The Company and You shall be governed in accordance with the laws prevailing in Delaware and in the event of any disputes, the courts at Delaware shall have the exclusive jurisdiction to settle the disputes between the parties.

  1. Contact us

    Please address Your grievances, feedback or questions, without limitation, with respect to this Policy or any other policy of the Company on the Website, please reach out to us at privacy@locus.sh or contact Our Data Protection Officer, Mr. Jamsheed Kamardeen at dpo@locus.sh. You can always withdraw Your consent for usage, processing of Your information by Us by writing to Us at the address mentioned above.

  1. Roles & Responsibility

    1. Role: Policy Owner

      Responsibilities:

      • Overall accountability of the Policy

      • Accountable for Creation, Modification, authorizations, publishing, communication, withdrawal, disposal of the Policy

      • Accountable for effective enforcement and compliance of the policy across the organization.

      • Accountable for Adequacy, Effectiveness and Continual improvement of the policy

    2. Role: Users

      Responsibilities:

      • Access and use only authorized information systems and Services

      • Access and use the Locus information systems as per the policies and controls established in Locus.

    3. Role: Privacy owners

      Responsibilities:

      • Apply and maintain necessary and adequate controls for protection of the Information Assets in alignment with the Policies and controls mandated by PIMS.

      • Establish and manage effective access management mechanism for all information systems and services in alignment with the Policies and procedures.

  1. Exceptions

    Currently there are no exceptions that are established within Locus for this Policy.

    Any exception to this policy should be authorized by the Locus Management or DPO (Data Protection Officer) or any person specifically designated and authorized by the Management.

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