Privacy Policy

Data Protection Policy

Introduction

This Data Protection Policy (“Policy”) is established by UPSPRING TECHNOLOGIES PRIVATE LIMITED (“Organisation”) in compliance with the Digital Personal Data Protection Act, 2023 (“DPDPA”), its rules, and other applicable laws of India. This Policy ensures lawful, fair, and transparent processing of personal data and reflects our commitment to safeguarding privacy and data security.

Venusxiospace is a product/platform operated and managed by UPSPRING TECHNOLOGIES PRIVATE LIMITED. Where personal data is collected, used, stored, processed, or otherwise handled through Venusxiospace, such processing shall be governed by this Policy.

This Policy applies to all employees, contractors, vendors, and third parties processing personal data on behalf of the Organisation, including in connection with the operation and provision of Venusxiospace.

Definitions

1.

Organisation: Refers to UPSPRING TECHNOLOGIES PRIVATE LIMITED, registered under the Companies Act, 2013.

2.

Venusxiospace: Refers to the product/platform, including its associated website, application, software, services, features, and functionalities, operated and managed by UPSPRING TECHNOLOGIES PRIVATE LIMITED.

3.

Data Subject: Any identified or identifiable natural person whose personal data is processed.

4.

Personal Data: Information relating to an identified or identifiable individual, as defined under the DPDPA.

5.

Processing: Any operation on personal data, including collection, recording, storage, sharing, and deletion.

6.

Special Categories of Data: Sensitive personal data, such as financial, health, or biometric information.

7.

Data Protection Officer (“DPO”): Designated individual overseeing compliance with this Policy.

Scope

This Policy applies to all personal data processed by the Organisation, including personal data collected or processed through Venusxiospace, its associated systems, applications, websites, platforms, and services.

This includes:

  • Collection, use, retention, and transfer of personal data.
  • Personal data processed in connection with the provision and use of Venusxiospace.
  • Cross-border data transfers.
  • Monitoring, profiling, and other automated decision-making activities.

Where conflicting legal requirements arise, the DPO must provide guidance.

Data Protection Principles

The Organisation adheres to the following principles in relation to personal data processed by the Organisation, including through Venusxiospace:

1.

Lawfulness, Fairness, and Transparency: Processing activities comply with the law and are transparent to data subjects.

2.

Purpose Limitation: Data is collected for specific, legitimate purposes only.

3.

Data Minimisation: Only data necessary for specified purposes is processed.

4.

Accuracy: Data must be accurate and updated promptly.

5.

Storage Limitation: Data is retained only as long as necessary for the stated purposes.

6.

Integrity and Confidentiality: Robust security measures protect against unauthorized access or loss.

7.

Accountability: The Organisation ensures and demonstrates compliance with these principles.

Governance Structure

1.

DIRECTOR: Responsible for Policy implementation across the Organisation, including activities relating to Venusxiospace.

2.

Privacy Council: Approves privacy initiatives and reviews risk assessments.

3.

DPO: Manages Policy enforcement, breach notifications, and compliance audits.

4.

Stakeholders: Including IT, Legal, HR, and others, support the DPO in data protection tasks relating to the Organisation and Venusxiospace.

Policy Implementation

1. Data Lifecycle Management
  • Maintain records of processing activities (RoPA).
  • Ensure secure data disposal.
  • Ensure appropriate handling and retention of personal data processed through Venusxiospace.
2. Consent Management
  • Obtain informed and explicit consent where required.
  • Provide mechanisms for withdrawal of consent.
  • Where applicable, provide appropriate consent and privacy choices to users of Venusxiospace.
3. Data Subject Rights
  • Fulfil rights including access, correction, and erasure within statutory timelines.
  • Provide appropriate mechanisms for users of Venusxiospace to exercise applicable data protection rights.
4. Data Breach Management
  • Report significant breaches to the Data Protection Board within 72 hours.
  • Maintain an incident management framework for personal data processed by the Organisation, including through Venusxiospace.
5. Data Sharing and Transfers
  • Comply with legal requirements for data transfers, including cross-border transfers.
  • Ensure that personal data processed through Venusxiospace is shared with third parties only in accordance with applicable law and this Policy.
6. Security Measures
  • Implement encryption, access control, and vulnerability assessments.
  • Conduct regular audits to ensure compliance.
  • Apply appropriate technical and organisational security measures to protect personal data processed through Venusxiospace.
7. Training and Awareness
  • Regularly train employees and third parties on data protection obligations.
  • Ensure personnel involved in the operation or support of Venusxiospace understand their data protection responsibilities.

Special Categories of Data

Sensitive personal data is processed only with explicit consent or as legally permitted. Enhanced safeguards such as pseudonymization or encryption are applied.

Where such data is processed through Venusxiospace, the Organisation shall implement appropriate safeguards and security measures in accordance with applicable law.

Privacy by Design and Default

The Organisation integrates privacy into the design of its systems and products, including Venusxiospace, ensuring:

  • Data minimisation.
  • Default privacy settings.
  • Clear choices for data subjects.
  • Appropriate privacy and security measures during the design, development, operation, and maintenance of Venusxiospace.

Monitoring and Compliance

Regular audits are conducted to ensure adherence to this Policy. Non-compliance may result in disciplinary action or contract termination.

The Organisation may also periodically review the data protection and privacy practices associated with Venusxiospace to ensure continued compliance with applicable laws and internal policies.

Contact Information

For queries or complaints regarding this Policy or the processing of personal data in connection with Venusxiospace:

UPSPRING TECHNOLOGIES PRIVATE LIMITED

Email: upSpring.Technology@gmail.com

Phone: +91-8796154183