Stoughton Street Tech Labs Private Limited (“We/Us”) operates the Loco application as a free-to-use mobile application, along with the website at loco.com and loco.gg (collectively referred to as the “Platform”), and the offered content therein, which is provided to users (“You”) at no cost and is intended for use as is. This page is used to inform website visitors regarding our policies in relation to the collection, use, and disclosure of personal information of anyone using our Services through the Platform (“Personal Information”).

If You choose to use any of our Services, then You acknowledge that we may collect and use Your information in accordance with this policy. The Personal Information that We collect is used for providing and improving the Service. We shall not use or share Your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms of Use, which are accessible at the Loco application and website, unless otherwise defined in this Privacy Policy. The capitalised terms used but not defined herein shall have the same meaning as ascribed to them under the Terms of Use.

This Privacy Policy shall apply to all the persons using the App or the Services. 

Information Collection 

Type of data/information collected

We may collect, use, store and transfer different kinds of Personal Information about You, including but not limited to (“Information”) :

1. identification information, such as: name, e-mail address, date of birth, telephone number, taxpayer identification number;
2. transactional information, such as: details related to transactions made on the Platform, including Loco Diamond purchases, reward redemption history, , transaction amount, and Loco wallet values;
3. communication information, such as: information You provide directly to us in communications, feedback and correspondences with us;
4. usage information, such as: your interests, chat data, preferences, and comments, usage data/ information, including but not limited to Your usage of the Platform and/or any of its specific functions or Services; and
5. log data, such as: Your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of Your use of the Service, and other statistics.

We may also collect, use and share Your data to produce and share aggregated insights that do not identify You. 

We shall retain the Personal Information for such duration as it shall be required to provide the Services to You, and thereafter for such duration required as per any legal, contractual or business purposes. 

Mode of collection of data

We may use various methods to collect Personal Information from and about You, including but not limited to:

1. directly collecting data from You when You directly provide data to us or by using the Services; 
2. through the use of cookies when You access the Platform;
3. by, via, through any third-party(ies) who may be appointed or authorized by Us; and/ or
4. collecting data/ information provided by You for searching any queries or filling in any forms for registration, uploading any content, reporting an issue or availing of any products and the Services offered by Us.

Circumstances for use of data

We shall only use Your Personal Information in accordance with the applicable laws, usually under one of the following circumstances:

1. for providing: (i) the Services; (ii) customer management; (iii) content, (iv) functionality; and/ or (v) security, as may be necessary to perform the Services provided to You under our Terms of Use and any other contract that You may have with Us;
2. to verify your identity and information you share with Us, to the extent permitted by law;
3. for analytical purposes to our third-party vendors and partners;
4. for protection of our legitimate interests (or those of a third party), such that Your interests and fundamental rights do not override these interests;
5. for sending any periodic communications (including emails and messages) about features, products and services, and any upcoming events, including promotion of programmes being organised by third parties through the Platform; 
6. to supervise and prevent any fraudulent or illegal activities on the Platform;
7. to conduct our corporate reorganizations;
8. for compliance with a legal or regulatory obligation; and/ or
9. for any purpose for which You declare Your valid consent under this Privacy Policy and / or the Terms of Use.

User Contributions

Any Personal Information You may submit, display, or publish in or through the Platform shall be publicly available and may be read, collected, used, and disclosed by others. We encourage You to exercise discretion and caution with respect to Your Personal Information.

As our user, You agree not to host, display, upload, modify, publish, transmit, store, update or share any information that:

1. belongs to another person and to which You do not have any right; 
2. includes bodily privacy, insulting or harassing, that is libellous, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or otherwise inconsistent with or contrary to the laws in force;
3. is harmful to children; 
4. infringes any patent, trademark, copyright, or other proprietary rights;
5. violates any law for the time being in force; 
6. deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any information which is patently false or misleading in nature but may reasonably be perceived as a fact; 
7. impersonates another person; 
8. threatens the unity, integrity, defence, security or sovereignty of any country, friendly relations with foreign states, or public order, or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting other nation; and/or
9. contains software virus or any other computer code, file or program designed to interrupt, destroy, or limit the functionality of any computer resource.

Cookies

The Service shall use “cookies” explicitly. The Platform may also use third party code and libraries that use “cookies” to collect information and to improve the Services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to Your device. If You choose to refuse our cookies, You may not be able to use or access certain portions of the Services.

Third Party Service Providers

We may employ third-party companies and individuals to:

1. facilitate our Service;
2. provide the Service on our behalf;
3. perform Service-related services; and/or
4. assist us in analysing how our Service is used.

These third parties may have access to Your Personal Information for performing the tasks assigned to them on our behalf. However, they are obligated to not disclose or use the information for any other purpose.

Cross-border data transfer

Personal Information that We hold about You may be transferred to countries outside of your country for any of the purposes mentioned in this Privacy Policy. Any Personal Information will be transferred and protected in accordance with this Privacy Policy as well as any applicable laws and regulations.

If you are a Brazilian user, please refer to Appendix A of this Privacy Policy for additional information on international transfer.

If you are an Indian user, please refer to Appendix B of this Privacy Policy for additional information on international transfer.

Security

We have in place physical, electronic and administrative safeguards to protect Your Personal Information. Your posting and sharing of Personal Information through the Platform constitutes Your acceptance of the risk that We cannot guarantee absolute security.

Your Rights

Depending on the jurisdiction You are located you may be entitled to exercise some rights in relation to your Personal Information, such as the rights presented below.

If you are a Brazilian user, please refer to Appendix A of this Privacy Policy for additional information on Your privacy rights.

If you are an Indian user, please refer to Appendix B of this Privacy Policy for additional information on international transfer.

You may exercise your rights by emailing us at privacy@loco.gg.

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, You will be directed to that site. We strongly advise You to review the privacy policy of these websites before proceeding to avail any services or engaging in a transaction with such third-party websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children’s Privacy

These Services do not address anyone under the age of 13 (thirteen). We do not knowingly collect personally identifiable information from children under 13 (thirteen). In the event that We discover that a child under 13 (thirteen) has provided us with Personal Information, We shall immediately delete such Personal Information from our servers. If You are a parent or guardian and You are aware that Your child has provided us with Personal Information, please contact us so that We are able to take necessary actions.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, You are advised to review this page periodically for any changes. We will notify You of any changes by posting the new Privacy Policy or amendments to the Privacy Policy on this page. These changes are effective immediately after they are posted on this page. Your continued use of this Platform, our Services or providing Us with your Personal Information shall signify acceptance of the terms of the updated Privacy Policy.

Contact Us

If You have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at privacy@loco.gg.

If you are a Brazilian user, this Appendix A is applicable to our processing of Your Personal Information.

1. Cross-border Transfers

You should be aware that we may share Your Personal Information with our group companies in India, UAE or any other country for conducting our operations, and with third parties (such as service providers) in other countries to assist in the provision of the Services.

All cross-border transfers are carried out in accordance with applicable law requirements and specific regulation on international transfer of personal information. We will ensure that an adequate level of data protection is provided for the international transfer of Your Personal Information.

2. Your rights

According to the applicable privacy laws, in relation to Your Personal Information processed by us, You have the right to:

• Obtain confirmation that we process your Personal Information. In response to this request, we will inform you whether we process your Personal Information or not.
• Access your Personal Information. If you are interested, you can receive a report in which we present the Personal Information related to you and processed by us.
• Correct Personal Information that is incomplete, inaccurate or out of date. If you understand that your Personal Information is incorrect, you can request correction, indicating what needs to be changed and why. We may ask for proof to make the required update.
• Request anonymization, blocking or deletion of unnecessary, excessive or processed Personal Information that does not comply with the provisions of the Brazilian law. If you understand that we are processing your Personal Information in an unnecessary, excessive or non-compliant manner with the Brazilian law, you can request that the Personal Information be anonymized, blocked or deleted.
• Request the portability of your Personal Information to another service or product provider, subject to our commercial and industrial secrets, after regulation by the relevant authority. You are the owner of your own Personal Information. Therefore, you may request that this Personal Information be transferred to another service or product provider, in accordance with regulations, as long as commercial and industrial secrets are respected.
• Obtain information about who we share your Personal Information with. You can request that we provide information on which entities we share your Personal Information with.
• Obtain information about the possibility of not providing your consent and the respective consequences. When consent is used as a legal basis for the processing of Personal Information, you have the right to be informed about the possibility of not providing consent and the consequences of refusal.
• Revoke your consent to the processing of your Personal Information. If your Personal Information is processed based on consent, you may revoke this consent. As a result, any processing of your Personal Information that is being carried out based on consent will be ceased.
• Oppose processing that violates the law. If you understand that we are processing your Personal Information in a manner contrary to the law, you can object to this processing. The request will be analyzed very carefully and, if we agree, the processing of your Personal Information that does not comply with the law will be ceased.
• Request the review of decisions made solely based on automated processing of your Personal Information. It is possible that decisions will be made based on the automated processing of your Personal Information. If this occurs, you can request a review of these decisions.

You may exercise your rights by emailing us at privacy@loco.gg.

3. Data Protection Officer (DPO)

If you have any questions in relation to our privacy practices or this Privacy Policy You may contact our DPO.

DPO’s identity: Abhisek Mohanty

DPO’s contact information: privacy@loco.gg

Grievance Redressal Mechanism

In accordance with the Information Technology Act, 2000 and its rules thereof, if You face any grievance with respect to our Privacy Policy, You may contact our Grievance Officer as provided below:

Name: Puneet Chauhan / for privacy related matters: Abhisek Mohanty

Email: grievance.officer@loco.gg; For privacy related matters: privacy@loco.gg

Address: B/202 Shakti Sadan, Bldg. No. 14Kher Nagar, Near Provident Fund Office, Bandra(East), Mumbai, Bandra, Maharashtra, India, 400051

If Your issue is not resolved even after contacting the Grievance Officer or in the timelines mentioned above or if You are satisfied with the response, You may contact our Nodal Officer as provided below:

Nodal officer - Ashwin Sasikumar

Email: ashwin.sasikumar@loco.gg; For privacy related matters: privacy@loco.gg

Address: B/202 Shakti Sadan, Bldg. No. 14Kher Nagar,Near Provident Fund Office, Bandra(East), Mumbai, Bandra, Maharashtra, India, 400051

The Grievance Officer shall acknowledge receipt of Your complaint within 24 (twenty-four) hours and shall dispose of the same within 15 (fifteen) days of receipt.

Periodic Compliance Reports