1.Personal Data That We Collect
We do not collect any special categories of personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
The Website may contain links to other sites. CACTUS is not responsible for the privacy notices or the content of such third-party websites even if:
- You accessed the third-party website using links from our Website; or
- You accessed our Website using links from a third-party website.
2.How We Use Your Personal Data
As Data Controller:
We may share Personal Information with trusted service providers or our affiliates for payment processing, supplementing the information you provide us in order to provide you with better service, account administration, perform statistical analysis, provide marketing assistance, host the Website, index user profile pages and usernames as part of the URL, technical and customer support. Any third parties receiving your Personal Information from us are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
After you place an order on our Website, you may need to make payments for the services you have ordered. In order to process your payments, 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 or other payment mode details, we solely use such details to process payment refunds, if any, to you. The third-party payment processors we use also collect, use, and process your information, including payment information, in accordance with their respective privacy policies.
To ensure that the security and integrity of the Website 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 Website.
We will share the Personal Information, if disclosure was required by law, rule or regulation or was in response to a valid order of a court or authorized agency of government or other legal process. We may be required to process Personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention or prevention of fraud. We may also use Personal Information to meet our internal and external audit requirements and for information security purposes.
International Transfer of Personal Information:
To the extent that it may be necessary, and solely for the purposes of providing the service available on the Website 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.
In cases where personal information would need to be transferred outside of a country where CACTUS operates, towards other jurisdictions, specific requirements may apply for such Transfer to be allowed. We may also transfer personal information to a third party located outside your country of origin without having to implement the above measures if you have given consent to us for the transfer of your Personal Information.
As of now, your Personal Information is being transferred via internet to a third-party service provider Amazon Web Services in either Singapore, India, USA or Japan for hosting/back-up the data on cloud. The data is encrypted at rest and in transit.
By using the services, you expressly agree to the transfers of personal data to third countries where this requires your consent.
As Data Processor:
We shall use and process the information or data we collect through Data Controllers/Controllers (“Business Partners”) as per the instructions given by Controllers and in compliance with the terms and conditions applicable to Processors under the Controller/Processor Binding Agreement entered with the Controllers and applicable Regulations. 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.
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 report to us 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.
We will retain your information for no longer than necessary, taking into account the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- whether we have any legal basis to continue to process your information (such as your consent);
- how valuable your information is (both now and in the future);
- any relevant agreed industry practices on how long information should be retained;
- the levels of risk, cost, and liability involved with us continuing to hold the information;
- how hard it is to ensure that the information can be kept up to date and accurate;
- any relevant surrounding circumstances (such as the nature and status of our relationship with you); and
- the time period your account remains active.