PRIVACY POLICY

Route Mobile Limitedand its affiliated Companies (Collectively known as “RML”) are sensitive to privacy issues on the Internet. We believe it is important for you to know how we treat the information we receive from you while visiting RML websites. This privacy policy has been compiled to better serve those who are concerned with how their ‘Personal Information’ (“PI”) is being used online. PI, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personal Information in accordance with our website.

  • 1. What personal information do we collect from the people that visit our website, blog or app?

    When registering on our site, as appropriate, you may be asked to enter your name, email address, phone number, Company Name, Country, queries or other details to help you with your experience.

    While sharing personal information, you recognize and understand that there is no compulsion on you to provide us with your personal information and any and all personal information provided by you to us is with your full consent, own volition and desire to provide such personal information. You also understand that we are under no obligation to verify the source from which the personal information about you is provided to us, and they are deemed to be provided by you, unless you demonstrate to us within a period of fifteen days from the date of providing of such information to us, to our satisfaction, that the information was provided to us without your free consent.

  • 2. When do we collect information?

    We collect information from you when you fill out a form or enter information on our website.

  • 3. How do we use your information?

    We may use the information:

    • i) To follow up after correspondence (email or phone inquiries);
    • ii) To understand your requirements;
    • iii) To send you promotional emails;
    • iv) To research and update the services as per your requirement;
    • v) To serve you better.
  • 4. How do we protect your information?

    Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We secure your personal information through regular malware scanning.

    Your personal information is secured behind networks which is accessible to limited Company Personnel who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

    We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information

    Also, all transactions are processed through a gateway provider which are not stored or processed on our servers.

  • 5. Do we use'cookies'?

    Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, cookies may be used to help remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We may also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

    We may use cookies to:

    • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third- party services that track this information on our behalf.

    You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.

    If users disable cookies in their browser:

    some features may be disabled. Some of the features that make your site experience more efficient and may not function properly.

  • 6. Third-party disclosure

    We do not sell, trade, or otherwise transfer to outside parties your Personal Information.

  • 7. Third-party links

    We do not include or offer third-party products or services on our website.

  • 8. Other Websites Link

    RML Web site may contain links to other sites such as RML partners and affiliates. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites.

  • Data Privacy and GDPR

    The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.

    The 21st Century brings with it, a broader use of technology, new definitions of what constitutes personal data; and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU;affording individuals stronger, more consistent rights to access and control their personal information.

    Our Commitment

    Route Mobile Limited is committed to ensure the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection policyin place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding our Data Protection program to meet the demands of the GDPR and the Indian Information Technology Act, 2000 and The Indian Contract Act, 1872.

    Route Mobile Limited is dedicated to safeguarding the personal information under our remit and indeveloping a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

    How we are preparing for GDPR

    Route Mobile Limited already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018.

    Our preparation includes: -

    • Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed, and if and to whom,it is disclosed.
    • Policies & Procedures - revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
      • Data Protection – our main policy and procedure document for data protection is being overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
      • Data Retention & Erasure – we are updating our retention policy and schedule to ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We are developing dedicated erasure procedures to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
      • Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow. If there is any data breach, Route Mobile Limited will notify its customers after becoming aware ofthe breach and provide necessary support and assistance to the customers.
      • International Data Transfers & Third-Party Disclosures – where Route Mobile Limited stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
      • Subject Access Request (SAR) – we are revising our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
    • Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
    • Privacy Notice/Policy – we are revisingour Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
    • Obtaining Consent - we are revising our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
    • Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
    • Processor Agreements – where we use any third-party to process personal information on our behalf, we are drafting compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.Route Mobile Limited will notify the customers in advance regarding any changes to its third party and affiliates.
    • Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
    Data SubjectRights

    In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information at our office of an individual’s right to access any personal information that Route Mobile Limited processes about them and to request information about: -

    • What personal data we hold about them
    • The purposes of the processing
    • The categories of personal data concerned
    • The recipients to whom the personal data has/will be disclosed
    • How long we intend to store your personal data for
    • If we did not collect the data directly from them, information about the source
    • The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
    • The right to request erasure of personal data (where applicable) or to restrictprocessing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
    • The right to lodge a complaint or seek judicial remedy and who to contact in such instances
    Information Security & Technical and Organisational Measures

    Route Mobile Limited takes the privacy and security of individuals and their personal information very seriously and takeevery reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, includingSSL, Access controls, Password policy, Encryptions, Pseudonymisation, Restriction, IT authentication etc.

    GDPR Roles and Employees

    Route Mobile Limited have designated a Data Protection Officer (DPO) and Data Protection Coordinators (DPC’s) and have appointed an independent internal auditor to develop and implement our roadmap for complying with the new data protection Regulation. Our Internal team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

    Route Mobile Limited understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We will be implementing an employee training program specific to which will be provided to all employees prior to May 25th, 2018,and forms part of our induction and annual training program.

    If you have any questions about our privacy policies, please contact dpo@routemobile.com