PRIVACY POLICY


This Privacy Policy is made effective as of: September 16, 2020
Pesto Tech (India) Private Limited (“us”, “we”, or “Pesto”) is the author and publisher of the
website, www.pesto.tech, mobile-optimized versions of the website, digital applications, and
any other media formats for the purposes of use and promotion of www.pesto.tech (collectively
referred to as the “Platform” or “Website”) and other products, software and services offered on
the Website by Pesto.
We value your privacy. In this Privacy Policy (“Policy”), we describe the information that we
collect about you when you visit our Website and use the services available on the Website
(“Services”), and how we use and disclose that information.


YOU UNDERSTAND THAT BY USING THE SITE OR SITE SERVICES AFTER THE EFFECTIVE
DATE, YOU AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO THE
COLLECTION, UTILIZATION, SHARING AND DISCLOSURE OF YOUR INFORMATION AS
DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT THE PRIVACY POLICY IN ITS
ENTIRETY, YOU MUST NOT ACCESS OR USE THE SITE OR THE SITE SERVICES AFTER THE
EFFECTIVE DATE.
IF YOU AGREE TO THE PRIVACY POLICY ON BEHALF OF AN ENTITY OR AGENCY, OR IN
CONNECTION WITH PROVIDING OR RECEIVING SERVICES ON BEHALF OF AN ENTITY OR
AGENCY, YOU REPRESENT AND WARRANT THAT YOU HAVE THE AUTHORITY TO BIND THAT
ENTITY OR AGENCY TO THE PRIVACY POLICY AND AGREE THAT YOU ARE BINDING BOTH
YOU AND THAT ENTITY OR AGENCY TO THE TERMS OF SERVICE. IN THAT EVENT, “YOU” AND
“YOUR” WILL REFER AND APPLY TO YOU AND THAT ENTITY OR AGENCY.


1. DATA PROTECTION PRINCIPLES
Pesto has adopted the following principles to govern its collection, use, retention, transfer,
disclosure and destruction of personal data:
a) Lawfulness, Fairness and Transparency . Personal data shall be processed lawfully,
fairly and in a transparent manner in relation to the data subject. This means that Pesto
must tell the data subject what processing will occur (transparency), the processing must
match the description given to the data subject (fairness), and it must be for one of the
purposes specified in the applicable data protection regulation (lawfulness).
b) Purpose Limitation . Personal data shall be collected for specified, explicit and legitimate
purposes and not further processed in a manner that is incompatible with those purposes.
This means Pesto must specify exactly what the personal data collected will be used for and
limit the processing of that personal data to only what is necessary to meet the specified
purpose.
c) Data Minimisation . Personal data shall be adequate, relevant and limited to what is
necessary in relation to the purposes for which they are processed. This means Pesto must
not store any personal data beyond what is strictly required.
d) Accuracy . Personal data shall be accurate and kept up to date. This means Pesto must
have processes in place for identifying and addressing out-of-date, incorrect and redundant
personal data.
e) Storage Limitation . Personal data shall be kept in a form that permits identification of
data subjects for no longer than is necessary for the purposes for which the personal data is
processed. This means Pesto must, wherever possible, store personal data in a way that
limits or prevents identification of the data subject.
f) Integrity & Confidentiality . Personal data shall be processed in a manner that ensures
appropriate security of the personal data, including protection against unauthorized or
unlawful processing, and against accidental loss, destruction or damage. Pesto must use
appropriate technical and organizational measures to ensure the integrity and confidentiality
of personal data is maintained at all times.
g) Accountability . The Data Controller (Board of Pesto Tech (India) Private Limited) shall be
responsible for, and be able to demonstrate compliance. This means Pesto must
demonstrate that the six data protection principles (outlined above) are met for all personal
data for which it is responsible.


2. COLLECTION OF YOUR PERSONAL INFORMATION

2.1. We collect personal information from the individuals who want to register on our website
www.pesto.tech. This information is not accessible to the visitors using Pesto’s website,
either directly or by submitting a request. Individuals are required to create an account to
be able to access certain portions of our Website, Individuals, if and when they create and
use an account with Pesto need to register on the website, they will be required to
disclose and provide to Pesto information including personal contact details like name and
email address. In some cases, additional details like billing information including name,
GST, address, PAN etc. may be required. Such information gathered shall be utilized to
ensure greater customer satisfaction and help a customer satiate their needs.


2.2. Our website may include social media features, which are available on Twitter, Facebook
and Instagram. The features may include “like” button and widgets, such as the “share
this” button. These features may collect your personal information and track your use on
the website. These social media features are hosted directly on our website. Your
interactions with these features are governed by this privacy policy and by the policies of
the company providing such functionality.


2.3. We also automatically collect certain computer, device and browsing information when
you access the website or use Pesto Services. This information is aggregated to provide
statistical data about our users’ browsing actions and patterns, and does not personally
identify individuals. This information may include:


● Computer or mobile device information, including IP address, operating system,
network system, browser type and settings;
● Website usage information.


2.4. The Pesto website uses cookies. Cookies are small text files that are placed on your
computer by websites that you visit. They are widely used in order to make websites
work, or work more efficiently, as well as to provide information to the owners of the site.
Cookies are typically stored on your computer’s hard drive. Information collected from
cookies is used by us to evaluate the effectiveness of our Site, analyze trends and
administer the Platform. The information collected from cookies allows us to determine
such things as which parts of our website are most visited and what difficulties our visitors
may experience in accessing our website. With this knowledge, we can improve the
quality of your experience on the Platform by recognizing and delivering more of the most
desired features and information, as well as by resolving access difficulties. We also use
cookies and/or a technology known as web bugs or clear gifs, which are typically stored in
emails to help us confirm your receipt of, and response to, our emails and to provide you
with a more personalized experience when using our Site.
We may use one or more third-party Service providers, to assist us in better
understanding the use of our Site. Our Service provider(s) will place cookies on the hard
drive of your computer and will receive information that we select that will educate us on
such things as how visitors navigate around our Site, what products are browsed and
general Transaction information. Our Service provider(s) will analyze this information and
provide us with aggregate reports. The information and analysis provided by our Service
provider(s) will be used to assist us in better understanding our visitors’ interests in our
Site and how to better serve those interests. The information collected by our Service
provider(s) may be linked to and combined with information that we collect about you
while you are using the Platform. Our Service provider(s) is/are contractually restricted
from using the information they receive from our Site for any other purpose than to assist
us.


If you want to avoid using cookies altogether, you can disable cookies in your browser.
However, disabling cookies might make it impossible for you to use certain features of our
website or Services, such as logging in to your Pesto Account or making Transactions.
Your use of our website or Service with a browser that is configured to accept cookies
constitutes acceptance of our and third-party cookies.


3. HOW PESTO USES THE INFORMATION WE COLLECT
3.1. We collect your personal information and aggregate information about the use of our
Website and Services to better understand your needs and to provide you with a better
Website experience. Specifically, we may use your personal information for any of the
following reasons:
● To provide our Services to you, including registering you for our Services, verifying
your identity and authority to use our Services, and to otherwise enable you to use our
Website and our Services;
● For customer support and to respond to your inquiries;
● For internal record-keeping purposes;
● To process billing and payment, including sharing with third party payment gateways
in connection with Website and/or Pesto’s products and Services;
● To improve and maintain our Website and our Services (for example, we track
information entered through the “Search” function; this helps us determine which
areas of our Website users like best and areas that we may want to enhance; we also
will use for trouble-shooting purposes, where applicable);
● To periodically send promotional emails to the email address you provide regarding
new products from Pesto, special offers from Pesto or other information about Pesto
that we think you may find interesting;
● To contact you via email, or, where requested, by text message, to deliver certain
services or information you have requested;
● For Pesto’s market research purposes, including, but not limited to, the customization
of the Website according to your interests;
● We also may compare personal information collected through the Website and
Services to verify its accuracy with personal information collected from third parties;
and
● We may combine aggregate data with the personal information we collect about you.
● From time to time, Pesto may use personal information for new and unanticipated
uses not previously disclosed in our Privacy Policy. If our information practices change
regarding information previously collected, Pesto shall make reasonable efforts to
provide notice and obtain the consent of any such uses as may be required by law.
3.2. We may collect Pesto services usage information in order to improve function or UI, but
will only use this information in an aggregated, anonymized fashion, and never in
association with your name, email, or other personally identifying information.


4. DATA RETENTION
4.1. To ensure fair processing, personal data will be retained by the Board of Pesto (who
shall at all times be considered as the “Data Controller” under this Policy) until a
customer has an active account on the website and undertakes transactions therefrom.
4.2. The Board of Pesto shall maintain all records relevant to administering this policy and
procedure in electronic form on our computers, servers, cloud storage etc.
4.3. We will retain records of all such information for five years after the account has been
closed.
4.4. All personal data should be deleted or destroyed as soon as possible where it has been
confirmed that there is no longer a need to retain it.


5. DATA PROTECTION
5.1. We employ procedural and technological security measures, which are reasonably
designed to help protect your personal information from unauthorized access or
disclosure. Pesto may use encryption, passwords, and physical security measures to help
protect your personal information against unauthorized access and disclosure. No
security measures, however, are 100% complete. Therefore, we do not promise and
cannot guarantee, and thus you should not expect, that your personal information or
private communications will not be collected and used by others.
5.2. You should take steps to protect against unauthorized access to your password, phone,
and computer by, among other things, signing off after using a shared computer,
choosing a robust password that nobody else knows or can easily guess, and keeping
your log-in and password are private. Pesto is not responsible for the unauthorized use of
your information or for any lost, stolen, compromised passwords, or for any activity on
your Account via unauthorized password activity.


6. DATA PROTECTION RIGHTS
We would like you to be completely aware of your data protection rights. Every customer is
entitled to the following:
● Information access.
● Objection to processing.
● Objection to automated decision-making and profiling.
● Restriction of processing.
● Data portability.
● Data rectification.
● Data erasure.
If a customer makes a request relating to any of the rights listed above, the Board of Pesto will
consider each such request in accordance with all applicable data protection laws and
regulations. No administration fee will be charged for considering and/or complying with such a
request unless the request is deemed to be unnecessary or excessive in nature. Requests shall
be made in writing/email to: [email protected]


7. DISCLOSURE
We may share the information that we collect about you, including your personal information,
as follows:
a) Information Disclosed to Protect Us and Others
We may disclose your information including Personal Information if: (i) Pesto reasonably
believes that disclosure is necessary in order to comply with a legal process (such as a court
order, search warrant, etc.) or other legal requirement of any governmental authority, (ii)
disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) reasonably
necessary to enforce this Privacy Policy etc. (iv) disclosure is intended to help investigate or
prevent unauthorized transactions or other illegal activities, or (v) necessary or appropriate to
protect our rights or property, or the rights or property of any person or entity.
b) Information Disclosed to Third Party Service Providers and Business Partners
We may contract with various third parties for the provision and maintenance of the
Website, Services and our business operations, and Pesto may need to share your personal
information and data generated by cookies and aggregate information (collectively,
“information”) with these vendors and service agencies. The vendors and service agencies will
not receive any right to use your personal information beyond what is necessary to perform its
obligations to provide the Services to you. If you complete a survey, we also may share your
information with the survey provider; if we offer a survey in conjunction with another entity, we
also will disclose the results to that entity.
c) Disclosure to Non-Affiliated Third Parties in Furtherance of Your Request
Your request for services may be shared with third party websites with whom we have a
contractual relationship in order to provide your request with maximum exposure. The post on
the third party website will include the details of your request, including your location, and other
contact details. Interested bidders, however, will be able to click on your request on such third
party site, and will be directed to our Website where they will have access to your contact
details (Partial or complete), as would any other service provider on our Website interested in
bidding on your request.
d) Links to External Websites
The Website may contain links to other websites or resources over which Pesto does not have
any control. Such links do not constitute an endorsement by Pesto of those external websites.
You acknowledge that Pesto is providing these links to you only as a convenience, and further
agree that Pesto is not responsible for the content of such external websites. We are not
responsible for the protection and privacy of any information which you provide while visiting
such external websites and such sites are not governed by this Policy. Your use of any external
website is subject to the terms of use and privacy policy located on the linked
to external website.


8. MARKETING
We may send periodic promotional or informational emails to you. You may opt-out of such
communications by following the opt-out instructions contained in the email. Please note that it
may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving
emails about recommendations or other information we think may interest you, we may still
send emails on a case to case basis.


9. BREACH REPORTING
Any individual who suspects that a personal data breach has occurred as a result of the theft or
exposure of personal data must immediately notify the Board of Pesto immediately at
[email protected] by providing a description of what occurred. They will investigate all reported
incidents to confirm whether or not a personal data breach has occurred. If a personal data
breach is confirmed, Pesto will follow the relevant authorized procedure based on the criticality
and quantity of the personal data involved. For severe personal data breaches, Pesto’s senior
management will initiate and chair an emergency response team to coordinate and manage the
personal data breach response.


10.PRIVACY POLICY UPDATES
THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH ABOVE. PESTO MAY, IN
ITS SOLE AND ABSOLUTE DISCRETION, CHANGE THIS POLICY FROM TIME TO TIME BY
UPDATING THIS DOCUMENT. PESTO WILL POST ITS UPDATED POLICY ON THE WEBSITE ON
THIS PAGE. PESTO ENCOURAGES YOU TO REVIEW THIS POLICY REGULARLY FOR ANY
CHANGES. YOUR CONTINUED USE OF THIS WEBSITE AND/OR CONTINUED PROVISION OF
PERSONAL INFORMATION TO US WILL BE SUBJECT TO THE TERMS OF THE THEN-CURRENT
POLICY.


11.GRIEVANCES
If you have any questions or comments about the Privacy Policy, please contact us
at [email protected] Your use of the Website and/or Services and any personal information you
provide on the Website remains subject to the terms of this Policy.