Venture Kites

As updated on [01-10-2024]

This privacy policy (“Policy”) explains how Bhasava Lakshmi Private Limited, operating under the brand name Venture Kites, collects, processes, stores, and/or shares any personal data and/or other information from or about the users (“You” or “Your” or “User” or “Users”) via your access and registration on our web-based platform (“Platform”).

We value your privacy, and this Policy demonstrates our procedures in relation to personal data. By accessing and/or using the Platform, you consent to the collection, storage, disclosure, and other uses of your information per this Policy. Please read this document carefully before submitting any information on the Platform. We may update this Policy from time to time to comply with applicable laws, and you agree to be legally bound by the updated Policy. Please check this Policy each time before you share personal data with us.

The Platform is operated by Bhasava Lakshmi Private Limited, a company registered in Bangalore, India, with its registered office at No. 19, 4th C Cross Koramangala Industrial, 5th Block, Area, Bengaluru, Karnataka 560095. Venture Kites may share the information (including your personal data) with our affiliates, employees, directors, agents, contractors, business partners, data processors, and our successors or permitted assigns to provide you access to the Platform and/or services.

1. Defined Terms

1.1 “Applicable Law” means all laws, ordinances, statutes, rules, orders, decrees, injunctions, licenses, permits, approvals, authorizations, consents, waivers, privileges, agreements, and regulations of any governmental authority or court of law having jurisdiction in India over the relevant matter. This includes but is not limited to the Information Technology Act, 2000, the Digital Personal Data Protection Act, 2023, and the rules made thereunder, as amended from time to time.

1.2 “Content” means any content, including but not limited to text, images, videos, audio files, graphics, or other materials that are shared, uploaded, or posted on the Platform by the User.

1.3 “Event” refers to any program, workshop, seminar, webinar, or any other event organized by Venture Kites, either online or offline, for which the User registers or participates.

1.4 “Materials” includes (i) all forms of content such as text, software, scripts, graphics, photos, sounds, music, videos, audio-visual combinations, interactive features, and other materials; and (ii) any comments, feedback, or content contributed by the User on the Platform.

1.5 “Personal Data” refers to information relating to an identified or identifiable natural person, which includes but is not limited to name, contact details, address, email address, age, gender, payment information, and any other details that can be used to identify an individual.

1.6 “Purpose” refers to the objectives for which personal data is collected and used by Venture Kites as outlined under Clause 2.2 of this Policy.

1.7 “Services” refers to the various services offered by Venture Kites through the Platform, including but not limited to consulting, mentoring, access to educational resources, business tools, and any other features provided by the Company.

1.8 “Terms of Use” means the terms and conditions governing the use of the Platform and Services, as amended from time to time, and which are available on the Platform.

1.9 “User Account” means the account created by the User on the Platform, providing access to the Services and features of Venture Kites.

1.10 “Third-Party Service Providers” refers to any external organizations or individuals that provide services, tools, or products that assist in the functioning or enhancement of the Platform and Services, including payment processors, marketing partners, and analytics providers.

1.11 “Platform” refers to the web-based platform operated by Venture Kites for providing its Services.

1.12 “User” or “Users” refers to any individual or entity that accesses or uses the Platform, including those who register for an account or participate in events.

1.13 “Company” refers to Bhasava Lakshmi Private Limited, operating under the brand name Venture Kites, registered in Bangalore, India.

2. Notice

The Users are hereby informed, in accordance with Applicable Law, that the Personal Data collected by Venture Kites shall be used for the purposes outlined in this Policy. Below, we describe the types of Personal Data collected and the reasons for its collection:

2.1 Description of Personal Data: Venture Kites collects the following information to identify and provide services to you. The list may be updated from time to time, and Users will be notified of any changes:

• 2.1.1 Name: Your full name as provided during registration or use of our Services.
• 2.1.2 Age: Your date of birth to verify age-related legal requirements.
• 2.1.3 Gender: Information collected for demographic analysis and tailored content delivery.
• 2.1.4 Email Address: To communicate with you regarding your account, updates, and marketing communications.
• 2.1.5 Payment Details: Information such as credit card or bank details, collected securely via our payment processor when you make purchases or subscribe to paid services.
• 2.1.6 Phone Number: Used for account verification, customer support, and communication purposes.
• 2.1.7 Company Details: Information about your business or employer, if applicable, to customize services or offer relevant resources.
• 2.1.8 Interests: Preferences or areas of interest to personalize your experience and provide relevant content or service recommendations.

(Collectively referred to as “Personal Data”)

2.2 Purpose: Venture Kites does not sell or disclose Personal Data without your consent unless required by law. You agree that the Company and its third-party service providers have the right to use your Personal Data for the following purposes:

• 2.2.1 To provide Services including access to educational content, consulting sessions, and other features offered by Venture Kites.
• 2.2.2 Customer Support: To contact you and address any queries or issues related to your account or use of the Platform.
• 2.2.3 Networking and Connections: Connecting you with third parties or other Users, as required, to fulfill your service needs.
• 2.2.4 Updates and Notifications: Sending updates, information, or notifications related to the Platform, services, or your account.
• 2.2.5 Account Management: Managing your account and improving your user experience on the Platform.
• 2.2.6 Service Improvement: Conducting research, analysis, and surveys to improve the Services.
• 2.2.7 Marketing and Promotion: Sending promotional materials, newsletters, and personalized offers based on your interests.
• 2.2.8 Personalization: Optimizing and customizing the content and layout of the Platform according to your preferences.
• 2.2.9 Advertising: Sharing promotional content or advertisements tailored to your interests.
• 2.2.10 Business Intelligence: Creating reports or analyses for business strategy and decision-making.

(Collectively referred to as “Purpose”)

3. Collection of Personal Data

3.1 Personal Data Collection: Venture Kites collects Personal Data when you create a User Account, register for our services, or use the Platform. This information may include your name, address, email address, phone number, payment details, and other personally identifiable information as listed under Clause 2.1. We may also collect data from any queries, comments, communications, and messages you post, transmit, or generate on the Platform.

To enhance the user experience, the Platform may also collect device-related information, such as IP address, location data, and browser type. Users are requested to provide only the minimum amount of information necessary for the Platform’s services. We may compile aggregated non-personal data, such as browsing patterns or system data, which helps us understand and improve the Platform without identifying individual users.

3.2 User-Generated Content: Content that you post or share on the Platform, such as comments, feedback, or media uploads, may be viewed by other Users and the general public. Accordingly, Venture Kites cannot ensure the privacy of any Personal Data included in such User-generated Content, and you are advised to be cautious when sharing personal details.

3.3 Payment Information: When you subscribe to our services or make a purchase, we collect payment-related Personal Data, such as payment method details (credit card, debit card, etc.), billing address, and other related information. Payments are processed securely through third-party payment processors, and your payment information is used only for transaction purposes. By providing payment information, you consent to the collection and processing of this data by our payment partners and accept the associated terms and conditions.

3.4 Cookies and Similar Technologies: Venture Kites uses cookies and similar technologies to track and enhance your experience on the Platform. Cookies are small files stored on your device that help us recognize your preferences, collect data on how you use the Platform, and provide a more personalized experience. By continuing to use the Platform, you consent to our use of cookies. You can manage cookie settings through your browser, but blocking cookies may impact some functionality of the Platform.

3.5 Analytics and Tracking Tools: We use third-party analytics and tracking tools to analyze user behavior on the Platform, such as Google Analytics or similar services. These tools help us understand how Users interact with the Platform, which allows us to improve our services. The data collected by these tools may include your device information, usage data, and browsing patterns, but it does not include personal identifiers unless expressly consented by you.

4. Use and Disclosure of Information

4.1 Use of Personal Data:
Venture Kites uses the Personal Data collected from you for the purposes outlined in Clause 2.2. The main use of your Personal Data is to provide, maintain, and improve the services offered through the Platform. This includes verifying your identity, facilitating transactions, managing your User Account, responding to customer support requests, and personalizing your experience on the Platform.

In addition, your Personal Data may be used for internal research and analysis to better understand user preferences and improve the overall quality and functionality of the Platform. We may also use your information to send you updates, promotional materials, or other communications relevant to your use of the Platform.

4.2 Disclosure of Personal Data:
Venture Kites may share your Personal Data with third parties in the following circumstances:

• 4.2.1 Third-Party Service Providers: We may engage third-party service providers to perform functions on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. These providers will have access to your Personal Data as necessary to perform their functions but are prohibited from using your Personal Data for any other purpose.
• 4.2.2 Compliance with Legal Obligations: We may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). This includes sharing information when we believe it is necessary to comply with the law, protect the safety of any person, prevent fraud or abuse, or protect Venture Kites’ rights or property.
• 4.2.3 Business Transfers: If Venture Kites is involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your Personal Data may be transferred as part of that business transaction. We will notify you via email or a prominent notice on the Platform of any such change in ownership or control of your Personal Data.
• 4.2.4 Events and Networking: When you register for events or programs hosted by Venture Kites, your Personal Data may be shared with sponsors or partners involved in the event to enhance your experience. Please note that Venture Kites is not responsible for any information you share directly with third parties during these events.
• 4.2.5 Consent-Based Sharing: With your explicit consent, Venture Kites may share your Personal Data with other third parties not covered in this Policy. You will be notified and given the opportunity to opt-out of any such sharing before it takes place.
• 4.2.6 Data Anonymization: We may anonymize your Personal Data and aggregate it with other data for purposes such as statistical analysis, research, and business improvement. This anonymized data does not identify you individually and may be shared with third parties.

4.3 Security Measures:
While Venture Kites takes reasonable steps to protect your Personal Data, no system is entirely secure. We implement various security measures, including encryption, access controls, and regular security audits, to protect your data from unauthorized access, misuse, or disclosure. However, we cannot guarantee the absolute security of your information, and you should take steps to protect your personal information when using the Platform.

5. Your Rights on Personal Data

Under Applicable Law, you have several rights concerning your Personal Data. Venture Kites is committed to facilitating the exercise of these rights. Below is a summary of your rights and how you can exercise them:

5.1 Right to Access Your Personal Data:
You have the right to request access to your Personal Data that we hold. Upon request, we will provide you with a summary of your Personal Data, details about how we use it, and information about any third parties with whom it has been shared. To exercise this right, please contact us using the details provided in Clause 12.

5.2 Right to Correction and Erasure of Your Personal Data:
You can request that we correct any inaccuracies in your Personal Data or update any incomplete or outdated information. You also have the right to request the erasure of your Personal Data when it is no longer necessary for the purposes for which it was collected, if you withdraw your consent, or if it is unlawfully processed. To request correction or erasure, contact us using the information provided in Clause 12.

5.3 Right to Withdraw Consent:
If you have provided consent for the processing of your Personal Data, you have the right to withdraw that consent at any time. Please note that withdrawing consent may affect our ability to provide you with certain services. To withdraw your consent, please contact us with reasonable notice using the details provided in Clause 12.

5.4 Right to Data Portability:
You have the right to request a copy of your Personal Data in a commonly used electronic format, which can be transferred to another service provider if desired. This right applies only to the Personal Data that you have provided to us, and where the processing is based on your consent or for the performance of a contract.

5.5 Right to Object to Processing:
You have the right to object to the processing of your Personal Data if the processing is based on legitimate interests, including profiling. If you object, we will cease processing your Personal Data unless we can demonstrate compelling legitimate grounds for the processing, which override your rights, or if the processing is for the establishment, exercise, or defense of legal claims.

5.6 Right to Restrict Processing:
You have the right to request that we restrict the processing of your Personal Data in certain circumstances, such as when you contest the accuracy of the data, object to the processing, or need the data for legal claims while we no longer require it for processing.

5.7 Right to Nominate:
You can nominate another individual who, in the event of your death or incapacity, can exercise your rights regarding your Personal Data in accordance with the Applicable Law.

5.8 Right to Lodge a Complaint:
If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the appropriate supervisory authority or seek legal remedies.

To exercise any of your rights or if you have any concerns about how your Personal Data is handled, please contact our grievance department using the details in Clause 12. We are committed to addressing your concerns promptly.

6. Security of Personal Information and Data Protection Practices

6.1 Data Security Measures:
Venture Kites takes the security of your Personal Data very seriously and employs reasonable technical and organizational measures to protect your information against unauthorized access, misuse, loss, alteration, or disclosure. These measures include, but are not limited to, encryption, firewalls, secure servers, data anonymization techniques, access controls, and regular security audits.

While we strive to protect your Personal Data, please be aware that no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security, and any transmission of Personal Data is at your own risk. Venture Kites continuously updates and tests its security practices to provide an added layer of protection against potential threats.

6.2 Data Protection Practices:
Venture Kites adopts industry-standard data protection practices, including:

• Access Controls: Limiting access to Personal Data to authorized personnel only, based on their job requirements and responsibilities.
• Data Minimization: Collecting only the Personal Data necessary for the specified purposes and ensuring that it is kept accurate and up-to-date.
• Incident Response: Implementing a comprehensive incident response plan to quickly address and manage any data security breaches, including notifying affected individuals and regulators where legally required.
• Regular Security Audits: Conducting regular reviews and audits of our security measures to identify vulnerabilities and enhance our data protection practices.

6.3 Data Breach Notification:
In the unlikely event of a data breach that compromises your Personal Data, Venture Kites will take immediate steps to mitigate the impact, investigate the breach, and notify you and the relevant authorities in accordance with Applicable Law. Our priority is to minimize any potential harm to you and to provide transparent communication about the incident and the steps taken to address it.

6.4 Grievance Redressal Mechanism:
We have established a robust grievance redressal mechanism to handle any issues or concerns relating to your Personal Data. Our appointed grievance department oversees compliance with this Policy and Applicable Law. If you have any questions, requests, or complaints about our data protection practices or your rights, you can contact our grievance department as detailed in Clause 12.

6.5 Data Protection Training:
Venture Kites regularly trains its employees and contractors on data protection principles, security practices, and the importance of safeguarding Personal Data. This helps ensure that all personnel handling your data are aware of their responsibilities and the critical importance of data security.

7. External Links

7.1 Links to Third-Party Platforms:
The Platform may contain links to websites, applications, or services operated by third parties that are not owned or controlled by Venture Kites. These external platforms are provided for your convenience and information only. Venture Kites does not endorse and is not responsible for the content, privacy policies, practices, or security of any third-party platforms. When you click on these links, you will leave the Venture Kites Platform, and any Personal Data you provide to these third parties is not covered by this Policy.

We strongly advise you to review the privacy policies and terms of use of any third-party platform you visit, as they may collect, use, and share your Personal Data in ways that differ from this Policy.

7.2 Social Media and Sharing Features:
The Platform may offer social sharing features or other integrated tools, such as social media buttons (e.g., Facebook, LinkedIn, Twitter), which allow you to share content or interact with other services. Your use of these features may result in the sharing of information with the social media platforms or other third parties involved. Please be aware that any information you post or share through these features is publicly accessible and may be collected and used by others. Venture Kites is not responsible for the information you choose to share on these platforms.

7.3 Third-Party Advertisements:
The Platform may display advertisements or promotional content from third parties. These advertisers may collect information when you interact with their ads, including device identifiers, browser type, IP address, and interactions with the ads. This information is subject to the privacy policies of the respective advertisers, and Venture Kites does not have control over the data they collect.

7.4 Disclaimer of Liability:
Venture Kites disclaims all liability arising from your use of third-party platforms or services linked through our Platform. We encourage you to be mindful when leaving our Platform and to read the privacy policies of each site you visit. Your use of third-party services and platforms is solely at your own risk.

8. Data Retention Policy

Venture Kites is committed to protecting and respecting your privacy by retaining your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by Applicable Law. Our data retention policy outlines how long your data will be kept and the measures we take to securely manage it.

8.1 Retention Periods:
Personal Data will be retained only for as long as it is necessary for the purposes outlined in this Policy, such as providing you with the Services, complying with legal obligations, resolving disputes, and enforcing our agreements. The retention period may vary depending on the type of data, the nature of the services, and the requirements of Applicable Law.

For example:

• Account Information: Retained as long as your User Account is active and for a reasonable period thereafter to address any follow-up issues or legal requirements.
• Payment Information: Retained for as long as required by financial regulations and for accounting purposes.
• Communications and Support Requests: Retained for record-keeping purposes and to improve the quality of our Services.

8.2 Data Deletion:
Once the retention period expires, or if you request deletion of your Personal Data, Venture Kites will securely delete or anonymize your information so that it cannot be reconstructed or read. If immediate deletion is not possible due to technical, legal, or operational reasons, we will take reasonable steps to securely store and isolate the data from any further processing until it can be deleted.

8.3 Exceptions to Retention Policy:
In some circumstances, we may need to retain your Personal Data for longer periods, such as when required to comply with legal obligations, resolve disputes, or enforce our agreements. In such cases, the retention of your data will be strictly limited to the specific purpose and duration necessary under the law.

8.4 Data Minimization:
We ensure that we only collect the minimum amount of Personal Data necessary to achieve the intended purposes. Regular reviews are conducted to identify any data that is no longer required and to ensure that it is appropriately disposed of in accordance with our retention policy.

8.5 Secure Disposal of Data:
When we no longer need your Personal Data, we take appropriate measures to ensure it is securely disposed of. This may include securely deleting digital files, shredding paper records, or anonymizing the data so that it is no longer personally identifiable.

9. Communications

By using the Platform and providing your contact details, you expressly consent to receive communications from Venture Kites and our authorized partners. These communications may include service-related announcements, updates, marketing messages, and other relevant information related to your use of the Platform.

9.1 Types of Communications:
Venture Kites may communicate with you through various channels, including but not limited to:

• Emails: For sending account-related information, updates, promotional content, newsletters, and other relevant messages.
• SMS and Phone Calls: For service updates, reminders, or customer support purposes.
• Push Notifications: For delivering important notifications directly to your device, subject to your settings and preferences.
• Social Media and Messaging Apps: For updates, offers, and customer support on platforms like WhatsApp, Facebook Messenger, or similar services.

9.2 Communication Preferences:
You have the right to manage your communication preferences and can opt out of receiving promotional emails or marketing communications at any time by clicking the unsubscribe link included in such emails or by adjusting your account settings on the Platform. However, you may continue to receive non-promotional communications related to your account, transactions, or required service notifications.

9.3 Monitoring and Recording:
You consent to the monitoring and recording of communications between you and Venture Kites or its agents, employees, and representatives for quality assurance, training, and compliance purposes, as permitted by Applicable Law.

9.4 Opting Out:
If you wish to stop receiving promotional communications from Venture Kites, you can opt out by following the instructions provided in the communication or by contacting us directly using the details provided in Clause 12. Please note that it may take a reasonable time to process your opt-out request, and you may still receive service-related communications during this period.

9.5 Notifications of Changes:
We may use your contact information to notify you of changes to our services, this Privacy Policy, or other important updates. It is important to keep your contact details up to date in your account settings to ensure you receive all necessary communications.

10. General Terms

This section outlines the general terms applicable to this Privacy Policy and the use of the Platform. These terms are important for your understanding of how Venture Kites operates and governs the handling of Personal Data.

10.1 Legal Compliance:
Venture Kites may preserve or disclose your Personal Data when required to do so by law or in response to legal requests, including but not limited to court orders, government demands, or legal processes. We may also disclose your data when we believe it is necessary to prevent fraud, address security or technical issues, or protect the rights, property, or safety of Venture Kites, its Users, or the public, as required or permitted by Applicable Law.

10.2 Protection of Venture Kites’ Rights:
We reserve the right to disclose your Personal Data to defend ourselves against claims, allegations, or disputes, and to protect the rights and safety of our Users, our Company, and third parties. This includes preventing harm to individuals or property and enforcing our legal agreements, including our Terms of Use.

10.3 No Waiver of Legal Rights:
Nothing in this Policy is intended to limit any legal defenses or objections that you may have regarding a third-party, including a government request to disclose your Personal Data. If any provision of this Policy is found to be invalid or unenforceable by a court or other competent authority, the remaining provisions of this Policy shall remain in full force and effect.

10.4 Jurisdiction and Governing Law:
This Privacy Policy is governed by and construed in accordance with the laws of India, without regard to its conflict of law principles. Any disputes arising out of or relating to this Policy shall be subject to the exclusive jurisdiction of the courts of Bangalore, India.

10.5 Changes to This Policy:
The most recent version of this Privacy Policy will govern the use of your Personal Data. We may revise this Policy from time to time at our sole discretion, and any changes will be effective upon posting the updated version on the Platform. If we make significant changes, we will notify you through the Platform, via email, or by other means to provide you with an opportunity to review the revised Policy. Your continued use of the Platform following any changes signifies your acceptance of the revised Policy.

10.6 Force Majeure:
Venture Kites shall not be liable for any failure to comply with its obligations under this Policy if such failure results from circumstances beyond its reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, labor disputes, or government regulations.

11. Changes to This Policy

Venture Kites is committed to keeping this Privacy Policy up to date with legal requirements, changes in our business operations, and evolving best practices in data protection. Below, we outline how we manage changes to this Policy and your rights concerning these changes.

11.1 Right to Update the Policy:
Venture Kites reserves the right to revise, amend, or update this Privacy Policy at any time to reflect changes in our services, legal obligations, or data protection practices. Any such changes will be posted on the Platform, and the “Last Updated” date at the top of the Policy will be revised accordingly. We encourage you to review this Policy periodically to stay informed about how we protect your Personal Data.

11.2 Notification of Changes:
In the event of significant changes to this Privacy Policy that materially affect your rights, Venture Kites will provide additional notice through email, in-app notifications, or other appropriate means. This notice will allow you to review the changes before they take effect. Your continued use of the Platform after such changes have been communicated will signify your acceptance of the updated Policy.

11.3 Consent to Changes:
If you do not agree with the revised Policy, you must stop using the Platform and contact us to close your User Account. By continuing to access or use the Platform and Services after any changes become effective, you agree to be bound by the revised Policy.

11.4 Historical Versions:
For your reference, previous versions of this Privacy Policy will be archived and made available upon request. This transparency ensures that you can review the evolution of our data protection practices and understand your rights at any point in time.

11.5 Questions About the Policy Changes:
If you have any questions or concerns about changes to this Privacy Policy, please contact us using the details provided in Clause 12. We are committed to addressing your concerns and ensuring that you feel confident about how your Personal Data is managed.

12. Customer Care & Grievance Mechanism

Venture Kites is dedicated to providing the highest level of service and support to our Users, especially regarding the handling of Personal Data. If you have any questions, concerns, or complaints about this Privacy Policy or how your Personal Data is processed, please reach out to our customer care team using the contact details provided below.

12.1 Contacting Customer Care:
For general inquiries or support related to your use of the Platform, you can contact our customer care team at:

• Email: team@venturekites.com
• Operating Hours: Monday to Friday, 9:00 AM – 5:00 PM IST

We aim to respond to all queries promptly and to provide the assistance you need to address any concerns related to your account or use of the Platform.

12.2 Grievance Redressal Mechanism:
If you have concerns specifically related to your Personal Data or believe that your data protection rights have been violated, please contact our team:

• Email: team@venturekites.com
• Address: No. 19, 4th C Cross Koramangala Industrial, 5th Block, Area, Bengaluru, Karnataka 560095

The Grievance department is responsible for overseeing compliance with this Privacy Policy and Applicable Law, as well as managing any complaints or requests related to your Personal Data.

12.3 Grievance Resolution Timeline:
Upon receipt of your grievance or complaint, we will acknowledge your request within 24 hours and aim to resolve your issue within 15 (fifteen) days from the date of receipt. In complex cases that require further investigation, we will keep you informed of the progress and any expected delays.

12.4 Right to Appeal:
If you are not satisfied with the response received from our Grievance department, you have the right to escalate your concern to the appropriate data protection authority in your jurisdiction.

12.5 Commitment to Privacy:
Venture Kites is committed to protecting your privacy and addressing any issues you may have in a fair, transparent, and timely manner. Your feedback is invaluable in helping us improve our services and data protection practices.