+919637909033 / +919637909044

Privacy Policy

Posted as of 22 April, 2023
Last updated as of 22 April, 2023

1. INTRODUCTION TO INKWELL

1.1.M/s InkWell Consultancy, a sole propritory firm incorporated and
registered and having its registered office at Bldg D, 303 & 304, Spring
Bloom, Mundhwa, Ghorpadi, Pune 411036 (collectively referred to as
“INKWELL”, “Firm", “we”, “us”, “ours”, synonymously as per the context of
this Policy) and we have created this Website wherein you avail the Services
of contract drafting and complaince.
1.2.We understand the importance of connecting the right service providers with
the right clients. That's why we've created a comprehensive Website that
caters to a diverse range of individuals. Towards the same, we have
introduced this Privacy Policy (referred to as “Policy”) to protect your data
that has been shared over our Website i.e., InkWell (referred to as
“Website”).

2. INTRODUCTION TO PRIVACY POLICY

2.1.This Policy is made to protect the data that you share with Firm. It lays down
our parameters and approach regarding the collection, usage, storage,
disclosure, and protection of your personally identifiable or other data as

collected on our Website for all the purposes as illustrated under this Policy
and as per the applicable laws for the time being in force.
2.2.The creator of this Policy ensures a steady commitment to your privacy
concerning the protection of the invaluable information that you may share
across this Mobile Website (referred to as “Website”) of the Firm. This
Policy contains information about the Website.
2.3.2.3. To provide you with our uninterrupted use of the Website, we may
collect and, in some circumstances, disclose information about you with
your permission. To ensure better protection of your privacy, we provide this
notice explaining our information collection and disclosure policies and the
choices you make about how your information is collected and used.

3. DEFINITIONS
3.1.Applicable Laws - shall mean and refer to all the laws, rules, ordinances,
by-laws, etc., and amendments after that, applicable within the territory of
India.
3.2.Content - shall refer to all the text, advertisement, graphics, User interfaces,
visual interfaces, photographs, trademarks, logos, brand names,
descriptions, sounds, music, and artwork.
3.3.Third Parties - shall mean and refer to all the legal entities, either individual
or entity linked on the Website apart from the Users and the creator of this
Website, respectively.
3.4.Service - shall mean and refer to all Contract Drafting and Complaince
services available on the Website.
3.5.Cookies - it is a small piece of data/ software code that automatically tracks
and stores the Data and the pattern on your hard drive or your device's web
browser. Cookies assist you in remembering your actions/information and


preferences on the Website over time, which assists us in providing better
Services on our Website and improving your use and browsing experience.
3.6.Data - shall refer to Business Information, Non-Personal Data, Personally
Identifiable Data, and other details, whether individually or in combination,
that you may provide on our Website when using accessing the Website.
3.7.User - refers to every individual who registers itself and creates an Account
on the Website to avail of the Services provided by the Firm.

4. INTERPRETATION
4.1.For interpretation in this Policy:
4.1.1. the terms “Customer”, “User”, "you", "your", and "yours" shall refer
to any natural person or legal person who is either browsing our Website
or availing our Services unless the context denotes otherwise;
4.1.2. the words denoting the singular shall include the plural and vice versa
for interpretation in this Policy unless the context denotes otherwise;
4.1.3. the words denoting any gender include all genders for the purposes of
interpretation in this Policy unless the context denotes otherwise;
4.1.4. the headings in this Policy are inserted for convenience only; and
4.1.5. the use of this Website is solely governed by the Terms of Use, this
Privacy Policy, and any other relevant policies as updated on the
Website.

5. COMPLIANCES
5.1.This Policy is framed and enforced per the Information Technology Act,
2000 and rules there under as applicable and the amended provisions about
electronic records in various statutes as amended by the Information


Technology Act, 2000. This electronic record is generated by a computer
system and does not require any physical or digital signatures. This legal
document is published following the provisions of Rule 3 (1) of the
Information Technology (Intermediaries Guidelines) Rules, 2011 and Rule
4 of the Information Technology (Reasonable Security Practices and
Procedures And Sensitive Personal Data or Information) Rules, 2011 of
Information Technology Act, 2000 amended through Information
Technology Amendment Act, 2008 that require publishing the Terms of Use
and practices for access and usage of any functional Website.
5.2.This Policy is made in inspiration of the General Data Protection Regulation
(GDPR), the GDPR gives individuals certain data rights. Accordingly, we
are happy to offer transparency and access controls to help Users take
advantage of those rights. As available, except as limited under applicable
law, the rights afforded to individuals are:
5.2.1. right of access- the right to be informed of, and request access to, the
data we process about you
5.2.2. right to rectification – the right to request that we amend or update
your data where it is inaccurate or incomplete;
5.2.3. right to erasure- the right to request that we delete your data;
5.2.4. right to restrict – the right to request that we temporarily or
permanently stop processing all or some of your personal data;
5.2.5. right to object – the right to object to us processing your personal data
on grounds relating to your particular situation. Along with the right to
object to your personal data being processed for direct marketing
purposes;


5.2.6. right to data portability – the right to request a copy of your personal
data in electronic format and the right to transmit that personal data for
use in another part’s service; and
5.2.7. right not to be subject to automated decision-making, the right to not
be subject to a decision based solely on automated decision-making,
including profiling, where the decision would have a legal effect on you
or produce a similarly significant effect.

6. APPLICABILITY
This Policy applies to all natural or legal people who use our Website either by
browsing it or by availing of the Services on it. Your Registration as a User on this
Website. This Policy also applies to you by continuous access of the Website, even
without any Account or Registration. This Policy, along with all the amendments
made to it occasionally, applies to all individuals and natural legal persons.

7. WHY DO WE COLLECT DATA?
7.1.We may collect certain information to provide you with the best Services
and a seamless experience while browsing the Website. We may collect
certain information. We strive to improvise the Services and User experience
the Website offers daily.
7.2.We collect and store the Data for any legal and regulatory requirements
under applicable laws. We collect and maintain your Data to notify you of
any changes in the Policy or operation of the Website.


7.3.The information you provide shall be used to provide and improve the
service for you and all users and the following services, including but not
limited to:
7.3.1. to provide you with services on your request;
7.3.2. for maintaining an internal record;
7.3.3. to enhance the Services provided on the Website, including our
interface, mode, style, etc.; and
7.3.4. for maintaining records under the legal and statutory provisions.
7.4.We use your tracking information, such as IP addresses and Device ID, to
help identify you, gather broad demographic data, and make further services
available. We will not sell, license, or trade your personal information. We
will not share your personal information with others unless they act under
our instructions or we are required to do so by law. Information collected via
our server logs includes Users' IP addresses and the pages visited; this will
be used to manage the web system and troubleshoot problems. We also use
third-party analytics, tracking, optimization, and targeting tools to
understand how Users engage with our Website so that we can improve it
and cater personalised content/ads according to their preferences.

8. WHAT DO WE COLLECT?
8.1.We are committed to respecting your online privacy. We further recognise
your need for appropriate protection and management of any Personal
Information you share with us. We may collect the following information:
8.1.1. if you register using your Google Account: your first name, last name,
and email address will be collected;


8.1.2. if you register using your Facebook Account, we collect your first and
last names as they appear on your account and the URL to your profile
picture. Suppose you have provided permission to Facebook through
their in-app privacy option (which appears just before you register on
our Website). In that case, we may collect your gender, age, or email id,
depending on your permission;
8.1.3. information is collected through permission derived by the Website for
location access, storage permissions, etc.;
8.1.4. tracking information such as but not limited to, the IP address of your
device and Device ID when connected to the Internet. This information
may include the URL that you just came from (whether this URL is on
the Website or not), which URL you next go to (whether this URL is on
the Website or not), your computer or device browser information, and
other information associated with your interaction with the Website;
8.1.5. proof of product ownership, like an invoice of Website as a products.
Please note that the option is currently available to a limited number of
Users;
8.1.6. GST verification for business owners. Please note that the option is
currently available to a limited number of Users; and
8.1.7. details of Website usage for analytics.

9. HOW DO WE COLLECT THE DATA?
9.1.When collecting personal information, we will identify the purposes for
which information is being collected. Suppose the same is not determined to
you. In that case, you have the right to request the Firm to elucidate the
purpose of collecting said personal information, pending the fulfilment of


which you shall not be mandated to disclose any information. We will collect
and use your personal information solely to fulfil those purposes specified
by us, within the scope of the consent of the individual concerned or as
required by law. We will only retain personal information as long as
necessary to fulfil those purposes. We will collect personal information by
lawful and fair means and with the knowledge and consent of the individual
concerned.
9.2.Personal Data should be relevant to the purposes for which it is to be used
and, to the extent necessary, should be accurate, complete, and up-to-date.
9.3.We collect information about your activity on our Website, which includes
the sites from which you accessed our Website, the date and time of each
visit, searches you have performed, listings or advertisement banners you
clicked, your interaction with such advertisements or listings, duration of
your visit and the order in which you visit the content on our Website.

10.VALIDATION OF YOUR INKWELL ACCOUNT
10.1. We validate the Accounts of InkWell Users by using Email
verification to ensure that each account is associated with a genuine and
unique User. If you do not agree to validate your account, then your account
will remain active, and you will be able to use our Services with limited
functionality.
10.2. If you create several InkWell Accounts using the same mobile number
or email id, all such accounts will have limited functionality, and you will
be asked to choose one. The account you chose will return to full
functionality, and the rest of the accounts will remain to have limited
functionality or be disabled permanently.


10.3. Account validation is done once for each account until the user verifies
it via email.
11.SECURITY AND HOW WE RETAIN THE DATA?
11.1. We treat Data as an asset that must be protected against loss and
unauthorised access. We employ many different security techniques to
protect such data from unauthorised access by members inside and outside
the Firm. We follow generally accepted industry standards to protect the
Personal Information submitted to us and the information we access.
11.2. All the information we receive about you is stored on secure servers,
and we have implemented technical and organisational measures that are
suitable and necessary to protect your Personal Data. We continually
evaluates the security of its network and adequacy of its internal information
security program, which is designed to:

11.2.1. help secure your Data against accidental or unlawful loss,
access or disclosure;
11.2.2. identify reasonably foreseeable risks to the security of the
our network; and
11.2.3. minimise security risks, including risk assessment and
regular testing. In addition, we ensure that all payment Data are
encrypted using SSL technology.
11.3. Please note, despite the measures we have implemented to protect your
Data, Data transfer through the Internet or other open networks is never
completely secure. There is a risk that unauthorised third parties may access
your Personal Data. We have taken certain security protections in
safeguarding Data.


11.4. However, as with most electronic transactions, no method is 100% safe
in case of data theft or loss during restoration. However, as effective as
encryption technology is, no security system is impenetrable. our Firm
cannot guarantee the security of our database, nor can we guarantee that the
information you provide won’t be intercepted while being transmitted to the
Firm over the Internet.

12.THIRD-PARTY WEBSITE LINKS
12.1. The Website may include third-party advertisements and hyperlinks to
their websites and mobile Websites or other resources. We have no control
over any other website and mobile Website or resources or contents
available on this other website and mobile Websites provided by companies
or persons other than Us. You acknowledge and agree that we are not
responsible for the availability of any such external sites or resources and do
not endorse any advertising, services/services, or other materials on or
available from such websites and mobile Websites or resources.
12.2. You acknowledge and agree that we are not liable for any loss or
damage which you may incur as a result of the availability of those external
sites or resources or as a result of any reliance placed by you on the
completeness, accuracy, or existence of any advertising, services or other
materials on, or available from, such website and mobile Websites. This
external third-party website and mobile Websites and resource providers
may have their respective privacy policies governing the collection, storage,
retention, and disclosure of your Personal Information that you may be
subject to. We recommend entering the website and mobile Website and
reviewing their privacy policies.


13.COOKIES
13.1. A cookie is a small file of letters and numbers that we store on your
browser or your computer's hard drive if you agree. By continuing to browse
the site, you agree to our use of cookies. Cookies contain information that is
transferred to your computer’s hard drive. You can set your browser to
refuse all or some browser cookies or to alert you when Website are
established or access cookies. If you disable or refuse cookies, please note
that some parts of this Website may become inaccessible or not function
properly. A list of the type of cookies we use is as follows;
13.1.1. Strictly necessary cookies. These are cookies that are
required for the operation of our Website. They include, for example,
cookies that enable you to log into secure areas of our Website, use a
shopping cart or make use of e-billing services.
13.1.2. Analytical/performance cookies. They allow us to recognise
and count the number of visitors and see how visitors move around our
Website when using it. This helps us improve how our Website work,
for example, by ensuring that users find what they are looking for easily.
13.1.3. Functionality cookies. These recognise you when you return to
our Website. This enables us to personalise our content for you, greet
you by name and remember your preferences (for example, your choice
of language or region).
13.1.4. Targeting cookies. These cookies record your visit to our
Website, the pages you have visited and the links you have followed. We
will use this information to make our Website, and advertising more


relevant to your interests. We may also share this information with third
parties for this purpose.

13.2. We use cookies to manage our Users’ sessions, store your preferred language
selection and deliver relevant advertisements. The Cookies are small text files
transferred from a web server to your device's hard drive. Cookies may collect the
date and time of your visit, browsing history, preferences, and username. You can
set your browser to refuse all or some cookies or to alert you when Website set or
access cookies. If you disable or refuse cookies, please note that some parts of our
Services/Website may become inaccessible or malfunction. For more information
on the cookies we use, please see our Policy on Cookies and Similar Technologies.

14.GOOGLE ANALYTICS
14.1. We use Google Analytics to help us understand how you use our
content and work out how we can make things better. These cookies follow
your progress through us, collecting anonymous data on where you have
come from, which pages you visit, and how long you spend on the site.
Google then stores this data to create reports. These cookies do not store
your personal data.
14.2. The information generated by the cookie about your use of the
Website, including your IP address, may be transmitted to and stored by
Google on servers in the United States. Google may use this information to
evaluate your use of the Website, compile reports on Website activity for us
and provide other services relating to Website activity and internet usage.
Google may also transfer this information to third parties where required by
law or where such third parties process the information on Google's behalf.


Google will not associate your IP address with any other data held by
Google. Using this Website, you consent to process data about your Google
in the manner and for the above-mentioned purposes.

15.GOOGLE ADSENSE
15.1. Google AdSense is a tool that allows Website publishers to deliver

advertisements to site visitors in exchange for revenue calculated on a per-
click or per-impression basis. To do this, Google uses cookies and tracking

technology to deliver ads personalised to a Website User/visitor. In this
regard, the following terms are specified to the Users:
15.1.1. third-party vendors, including Google, use cookies to serve
ads based on your prior visits to our Website or other website and mobile
Websites;
15.1.2. Google's use of advertising cookies enables our partners and
us to serve advertisements to you based on their visit to our Website
and/or other website and mobile Websites on the Internet;
15.1.3. you may opt out of personalised advertising by visiting Ads
Settings;
15.1.4. all advertisements of third parties on our Website are for
informative purposes only. Neither the Website nor the Firm guarantees
or bears liability for the authenticity of the advertisements;
15.1.5. at no point will the Firm permit its competitors to advertise on
the Website; and
15.1.6. you may visit the links in the advertisements at your own risk or
choose not to accept the cookies permitting third parties to display their
advertisements.


16.YOUR RIGHTS
16.1. Unless subject to an exemption, you have the following rights
concerning your data:
16.1.1. the right to request a copy of the data which we hold about
you;
16.1.2. the right to request any correction to any personal data if it is
found to be inaccurate or out of date;
16.1.3. the right to withdraw Your consent to the processing at any time;
16.1.4. the right to object to the processing of personal data;
16.1.5. the right to complain about a supervisory authority; and
16.1.6. the right to obtain information on whether Personal Data are
transferred to a third country or an international organisation.
16.2. If you do not want us to process your Data, you can use the Data
Deletion Request by emailing our support to exercise your privacy rights and
choices. There may be situations where we cannot grant your request — for
example, if you ask us to delete your transaction Data and we are legally
obligated to keep a record of that transaction to comply with the law.
16.3. Where you hold an account with any of our Services, you are entitled
to a copy of all Personal Data which we hold concerning you. You are also
entitled to request that we restrict how we use the Data in your account when
you log in.


17.CONFIDENTIALITY

17.1. You further acknowledge that the Website may contain information
that is designated confidential by us and that you shall not disclose such
information without our prior written consent. Your information is regarded
as confidential and, therefore, will not be divulged to any third party unless
legally required to do so to the appropriate authorities. We will not sell,
share, or rent your personal information to any third party or use your e-mail
address for unsolicited mail. Any emails sent by us will only be in
connection with the provision of agreed Services, and you retain sole
discretion to seek for discontinuation of such communications at any point
in time.
17.2. We will communicate with you by email, SMS or app notification in
connection with our Services/Website to confirm your registration, to inform
you in case your ad listing has become live/expired and to other transactional
messages in relation to our Services. As we must provide you with such
transactional messages, you may be unable to opt -out of such messages.

18.OUR DISCLOSURE OF YOUR INFORMATION
18.1. We may host surveys for survey creators for our Website who are the
owners and Users of your survey responses. We do not own or sell your
responses. Anything you expressly disclose in your responses will be
disclosed to survey creators. Please contact the survey creator directly to
understand how they might share your survey responses.
18.2. Information collected will not be considered sensitive if it is freely
available and accessible in the public domain or is furnished under the Right
to Information Act, 2005, any rules made thereunder, or any other law for
the time being in force.


19.ACCESSING, REVIEWING, AND CHANGING YOUR PROFILE
19.1. You can review and change your submitted information except for the
Email ID. An option for facilitating such change shall be present on the
Website, and the User shall facilitate Website and such change.
19.2. We may or may not keep track of your old information if you change
any information. We will not retain in our files information you have
requested to remove for certain circumstances, such as to resolve disputes,
troubleshoot problems and enforce our terms and conditions.
19.3. Such prior information shall be removed entirely from our databases,
including stored ‘backup’ systems. Suppose you believe any information we
hold on to you is incorrect or incomplete, or remove your profile so others
cannot view it. In that case, the User must promptly correct any incorrect
information.

20.CONSENT WITHDRAWAL, DATA DOWNLOAD & DATA REMOVAL
REQUESTS
20.1. If we discover any acts or behaviours that violate this Policy or any
other policies that apply to you, we retain the right to withdraw, suspend, or
delete your Account from our Website. Moreover, we retain the right to
revoke or restrict your access to our Website if you violate this Policy or in
the following other situations:
20.1.1. if you provide any wrong, incorrect, or materially altered
information or Data at the time of creation or registration of your
Account;


20.1.2. uploading of anything inconsistent, obscene, vague, vulgar,
or any information that is exclusively associated with any third party or
your;
20.1.3. in case you offer and deliver Services to the Customers in an
inconsistent, vague, vulgar, materially altered, and defective manner;
and
20.1.4. such other acts or actions strictly against this Policy of the
Firm or any different policy or agreement which the Firm may enter with
you to render the Services.
20.2. To withdraw your consent or to request the download or delete your
data with us for any or all our services at any time, please email
“support@inkwellconsultancy.com”.

21.SEVERABILITY
21.1. Each Clauses of this Privacy Policy shall be and remain separate from
and independent of and severable from all and any other Clauses herein
except where otherwise expressly indicated or indicated by the context of
this Agreement. The decision or declaration that one or more of the Clauses
are null and void shall not affect the remaining Clauses of this Privacy
policy.

22.AMENDMENT
22.1. You accept and agree that we retain the exclusive right, at its
discretion, to amend and update this Policy whenever there is any change in
the applicable laws or the Firm's policies, processes, and norms. You must


periodically read the Policy for a better understanding and to keep current
on the revised policy. The amended Policy will be placed on the Website
from time to time. Your continuing use of the Website will be interpreted as
accepting the Firm's revised policy.
22.2. If you disagree with how we process your Personal Data and the
choices we provide you, you may close your account anytime by emailing
our support.

23.GOVERNING LAW AND DISPUTE RESOLUTION
23.1. Any disputes, disagreements, or conflicts between the Parties
regarding the interpretation, legality, Website, or claimed violation of any
term or clause of this Policy will be resolved per Indian law. The competent
Pune, Maharashtra, India based courts will hear it.
23.2. In the event of any dispute arising out of or in connection with this
Privacy Policy, including any dispute relating to the validity of this Privacy
Policy, the Parties shall, at first instance, attempt to resolve the dispute by
mediation administered by the Centre for Online Resolution of Disputes
(“CORD”) (www.resolveoncord.com) and conducted in accordance with the
CORD Rules of Mediation, by a sole mediator to be appointed by CORD. In
the event the Parties are unable to resolve any such dispute through
mediation within 45 days of the initiation of the dispute, subject to a contrary
agreement between the Parties, the dispute shall be finally resolved by
arbitration administered by CORD and conducted in accordance with the
Rules of Arbitration of CORD, by a sole arbitrator to be appointed by
CORD. The language of the arbitration shall be English. The seat of
arbitration shall be Pune, India.


23.3. You agree that the Privacy Policy, Terms of Use and any other
agreements between the Parties are governed by India's laws, rules, and
regulations.

24.GRIEVANCES AND COMMUNICATION
24.1. If you have any questions or concerns regarding this Privacy Policy,
you should contact us by sending an e-mail to Mr. Shubham Rajkumar Jaju,
(Grievance Officer) addressed at B13, 4th Floor, Garden View Apartment,
Near Ozone Guest House, Nal Stop, Erandwane, Pune 411004, email
“support@inkwellconsultancy.com” or by writing to us at:

M/s. InkWell Consultancy

Bldg D, 303 & 304, Spring Bloom, Mundhwa, Ghorpadi, Pune 411036