Privacy Policy

Last updated: 19 November 2019

Welcome to Glocal Desi! a membership based, global online platform (Portal) for Desis to connect, meet and share with each other.

This Portal is an initiative of Glocal Phygital Media, a brand name owned by BeNedIN Group B.V., a limited liability company, registered at the Netherlands’ Chamber of Commerce (Dutch: Kamer van Koophandel) with registration number 74322877 (hereinafter also referred as “Company”, “We”, “Us”, “Our”).

This Privacy Policy is an extension of the www.glocaldesi.com  Terms of Use. Please read this Privacy Policy and our Terms of Use carefully in conjunction with each other, before using our Services. By using our Services, you agree to the provisions of this Privacy Policy and Terms of Use. If you do not agree with our Privacy Policy, unfortunately you cannot use our Services.

For the purpose of this Privacy Policy, the following definitions apply:

·       Personal information means any information relating to an identified or identifiable natural person (a ‘Data Subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier (such as a name, an identification number, location data, or one or more factors specific to the physical, economic, cultural or social identity of that natural person).

·       Processing means any (set of) operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment, combination, restriction, erasure or destruction.

·       Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

·       Processor means the natural or legal person, public authority, agency or other body which, alone or jointly with others, processes the personal data on behalf of the controller.

·       Non-personally identifiable information (Non-PII) means information that cannot by itself be able to identify an individual person, but provides some attributes linked to an anonymous person. Non-PII includes information received from the web browser, operating system, or device, including such things as information about the browser, browser settings, operating system or device, the unique identifier assigned to a device, the web address of a web page visited, the name or type of mobile device, the time and date a web page or app was visited, duration of visit to a web page, number of times a page is viewed, the address of the referring web page, and other information about location of device used by visitor. 

In general, we are the controllers of your personal data, and we enter into processing agreements with all third party data processors for processing some personal and non-PII. These agreements include adequate obligations to safeguard that your personal data is being shared with that data processor only for the purpose of providing the agreed services to us. If it is required that your personal data is transferred to a country that does not provide an adequate level of protection of personal data, we will take measures to ensure that your personal data are adequately protected in accordance with the applicable privacy requirements in the country of user or the European Union (EU).

Scope of this Policy

This Policy applies to everyone who uses our Portal, but specifically we direct parts of it toward particular groups, as follows:

Visitors: Visitors are everyone who visits our website, by typing its address in their internet browser.

Users: "Users" are everyone who uses our Services by registering and creating a profile via ‘Sign-up’ or ‘Login’ buttons at the top of Home page of our website www.glocaldesi.com.

Partners: “Partners” are users who have partnered with us online by creating an account via ‘Register as Partner’ option at the footer of the Home page on our website, or offline via a formally signed memorandum of understanding to host / organize events, sell, rent or lease their services, participate in our advertising services, and participate in other Services that we direct toward the desi community.

A Partner could be active in event management, expat re-location, advise and consulting, banking, e-commerce, travel & tourism, hospitality, care and other expat related services.

Why do we collect information from you (our Legitimate Business Purpose)

The Portal, currently in its ‘beta’ website version (i.e. concept / test mode), acts as a medium for the global Desis (i.e. people of South Asian origin, specifically Indian, Bangladeshi, Pakistani, Nepali, Sri Lankan and Afghanistani) to connect digitally, meet physically and share personally within their glocal (i.e. globally local) communities.

The Portal enables Desis to contact other Desis digitally for acquaintance, friendship, matrimonial, experience sharing, food sharing, ride sharing or home sharing. It also allows the community members to join or organize Desi meets (i.e. events or experience sharing tours) and share personalized services or requirements, such as a package or goods delivery from country of origin to country of living, and vice versa, in accordance with their own mutual understanding, in their own personalized way. Due to this combination of physical and digital interchange of information and services, we call ourselves a phygital community.

To provide our Services, we need some personal information from visitors, our users, and partners to be able to:

·       Help you find the most relevant information (e.g. a match with other user or their service) for your situation by customizing our search services and optimizing your experience;

·       Keep you connected with other www.glocaldesi.com users, across the internet and update you with relevant news and information;

·       Put you in contact with the right service provider to participate in an event or avail a service, and to optimize the information we share with those parties to initiate a productive and efficient relationship; and

·       Analyse the usage of our portal and further improve our service and user experience.

Our goal in this policy is to be transparent about the data we collect from you, where do we collect it from, why we collect it, how we use or process it, how we protect it and how you can amend / modify the data in order to make your experience seamless and effective!

What information do we collect, where do we get it, and where is it stored

We collect some personal information directly from our users (i.e. functional information), and some indirectly from all visitors to our website (i.e. analytical and tracking information):

Direct (functional) information:

For the purpose of effectively using the portal, all registered users (Desis) are required to create a detailed profile, providing accurate information including but not limited to their real name, picture, date of birth, e-mail id, mobile number, place of origin, place of living, hobbies, interests, languages and expertise (collectively referred to as “User Content”). This information is essential functional information, without which the users cannot use the Portal. We ask users to verify their email ownership by sending a verification email. The portal does not allow fake profiles with nick names or dubious names.

Partners also need to provide their real name or company name, email id, picture or company logo, phone number, address and details of service. Without this functional information, partners cannot list their services or events on our website.

All direct information (i.e. profile related information) is stored and processed in our data servers, based in the Netherlands and Germany (i.e. within the European Union).

Indirect (analytical or tracking) information:

Cookies:

Cookies are small data files that are transferred to your computer. We use "session" cookies to keep you logged in while you use our Services, to better understand how you interact with our Services, and to monitor aggregate usage and web traffic information on our Services. We use "persistent" cookies to technically recognize you each time you return to our Services.

Most internet browsers automatically accept cookies, but you can change your settings or use third-party tools to refuse cookies or prompt you before accepting cookies from the websites you visit. You can also use your browser settings or other tools to delete cookies you already have. Please be aware that some parts of our Services may not work for you if you disable cookies (e.g. you would need to login every time you visit the website).

Google Analytics:

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), specifically to monitor our web traffic, i.e. number of unique visitors and their usage. Google Analytics uses Cookies to help the website analyse how users interact with the Platform. Indirect information generated by the Cookie about your use of the website (including your IP address) is transmitted to and stored by Google on their servers in the United States.

Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site. For more information on opting out of being tracked by Google Analytics across all websites you use, visit Google Ad Settings. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Mailchimp and Log Data:

Our mail servers (Mailchimp) and data servers also automatically records usage information (called "Log Data") created by use of our Services by users and partners. Log Data may include information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device, search terms, and cookie information. We also receive Log Data when you interact with our Services, for example, when you visit our website, sign into our Services, or interact with our email notifications. We use Log Data to monitor our Services and use it in aggregate for management reporting purposes. Mailchimp privacy policy is available here.

Financial information:

We do not store or control any financial information of our users directly. However, if you purchase an event ticket, buy apremium subscription, or order an online service on our website, our payment gateway provider (Stripe) may collect financial data like your bank account number, credit card information and billing addresses of our subscribers, so that they can process your payment. In case of any failed payments or any KYC requirements, Stripe representative may call you to verify your information.

Stripe is one of the most popular and secure payment gateways in the world and has all the required security measures in place to secure your payment profile. By purchasing a ticket, a service or premium subscription on our website you provide us your consent to let Stripe process your financial data. For more information, please visit Stripe Privacy Policy

Location information: 

While creating a detailed profile, we ask our users to mention their place of origin and place of current living (like a locality, neighbourhood, street address, or even just a city). This is a static location, that users choose to mention, on a Google Map API. Static location means, the location on a map, which is not real-time. We do not use or track any real time mobile device or other types of user location at all.  We store static location information in our data servers and associate it with your profile to be able to advice you and other users, who might have a nearby static location. However, we never publish your house number, and do not advise you to even mention that in your profile. Street level or locality / neighbourhood level address is good enough to have a match with other near-by users.

In addition to your profile, we may in future use your static location information to provide localized features (such as local events), to analyse our Services with the help of third-party analytics services, to provide you with relevant advertising and marketing materials, and otherwise to improve and customize our Services.

How we process or share your information

Our main purpose of processing your information is to provide you services via the Portal. From time to time, we may send you promotional emails of other reputable organizations whose products or services we think you might find interesting. If you do not want us to send you such e-mails, you can opt-out of those email communication by clicking the ‘unsubscribe’ link at the bottom of emails.

Persons who supply us with their telephone numbers may receive telephone or text message from us or other users with information regarding new products and services or upcoming events. If you do not wish to receive such telephone calls or text messages, please let us know by e-mailing us at support@glocalphygital.com.

Direct contact with a partner: 

If you fill out an event registration form or contact a Partner (or use any other contact forms available on our Website) or call a Partner via our mobile site or app for a service, we may share personally identifiable information that you share with us and information about your use of our Services with the party you wanted to contact. This may include your profile data, as well as data that you input such as search criteria or Log Data that we collect as you use the Services. Depending on the type of service and your interest, the Partner may contact you based on your profile information. This contact and information exchange with partner is solely between you and the partner at your own discretion. We do not explicitly monitor any communication between a user and a partner.

Personalized communication: 

If you request a personalized service or order a service online, you authorize us to share the personally identifiable information necessary for our other users or Partners to deliver that service. They are not permitted to use the information for any other purpose.

For Partners, in case you list a service or a requirement for other Desi users, you also agree to share your personal information directly with other users at your discretion. We do not monitor any direct communication between two users, and do not guarantee protection and authenticity of that direct communication.

User-generated content: 

If you use our user-generated content services, like posting a question, answer or blog on our Website, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

Disclosure of information: 

We may release personal information when we believe that doing so is appropriate to comply with a applicable law, regulation, or legal request; to enforce or apply our policies; to initiate, render, bill, and collect for amounts owed to us; to protect our rights or property; to protect the safety of our users; to address fraud, security, or technical issues; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

All our Portals including this website fully comply with all applicable privacy laws in the country of operations. We will always cooperate with all law enforcement inquires. We may disclose all or part of your personal details in response to a request from the law enforcement authorities.

How we protect your information:

We use commercially reasonable security measures to protect the loss, misuse, and alteration of the information under our control. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We take all reasonable steps to protect Personal Information and Other Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Our data servers, and server of our data processors are secured with latest anti-virus, cyber threat protection and detection systems. Our third-party data center providers operate highly secure physical infrastructure and administrative facilities, as prevalent in Europe, and are certified on physical, environmental and information security standards such as ISO27001.

However, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information that you supply will not be intercepted while being transmitted to and from us over the Internet.

How long we keep your information:

Your personal and direct profile information is kept for as long as your profile is active, or maximum until 1 year after you have deactivated the profile yourself, to be able to comply with any law enforcement queries.

Payment information of users (not necessarily personally identifiable), is maintained in our financial systems up to 7 years, to comply with Tax regulations in the Netherlands. Stripe maintains information of all payments and associated users in line with Stripe privacy policy

Indirect and non personally identifiable information is kept in accordance with our analytics service provider Google’s terms of use and privacy policy.

European Union (EU) users and General Data Privacy Regulation (GDPR)

Our portal’s primary servers are located in the Netherlands, with a backup in Germany. All personal data of all our users (direct profile information) remains physically in the EU at all times. However, as with any online community, the data can be accessed by other users from outside the EU. If an end user (i.e. other user than you) downloads any of your personal information, e.g. your profile picture, your pdf profile or other information you have shared publicly, we cannot control dissemination of that information. We do not publicly display any user’s contact information, such as email address or phone number on our portal.

If you are located outside of the EU, please be aware that any Personal Information you provide to us will be physically transferred to and stored in the EU servers. By using the portal and by providing us Personal Information in any manner, you consent to this transfer and our use of the information and data provided by you in accordance with this Privacy Policy. 

Rights of EU data subjects, in accordance with GDPR:

EU data subjects, and all our users, can request access, correction, restriction, portability, objection or removal of your personal data at any time by sending a request to us via support@glocalphygital.com.

In the event we are processing your personal data on the basis of consent, you have the right to withdraw your consent at any time. Should you have any questions regarding the collecting or processing of your personal data, or if you are unsatisfied about the way in which we are processing your personal data, contact us at support@glocalphygital.com.

Right to access and update / correct your data: You are completely in control of your functional profile information all the time. You can update, change or completely deactivate your profile anytime from your dashboard’s my profile and my settings tabs.

Right to forget: In your profile page, you can find a button to deactivate your profile any time you wish not to continue with our portal. Once deactivated, your profile will no longer be visible to any of our front end users anymore, nor you can contact any users yourselves. We will delete your profile permanently from our servers, maximum after 6 months of your profile deactivation, in accordance with our profile retention policy.

Right to notify in case of data breach: In an unlikely situation of a mass data breach or cyber attack on our servers, we will notify the EU data protection authorities and the affected users within 72 hours of the breach notification and acknowledgement by our data centre service provider or our technical system administrators.

Minors or people under 18 years of age

We do not allow people below 18 years of age to register on our portal and hence do not intentionally collect or process any Personal Information from children. If you are under 18, please do not register, as your profile will not be approved by our admin. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Information without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us, please inform us at support@glocalphygital.com, so that we can verify and delete that information from our databases permanently.

General Matters

The accuracy and confidentiality of your profile information is your responsibility: You are responsible for maintaining the secrecy and accuracy of your password, email address, and other account information at all times. We recommend a strong password that you do not use with other services. We are not responsible for personal data transmitted to a third party as a result of an incorrect email address.

Third-Party websites: 

Our Website may contain links to other websites. When you click on one of these links, you are navigating to another website. We do not accept liability for misuse of any information by any website controller to which we may link. We also do not have any responsibility of liability for the content on websites that use the www.glocaldesi.com search functionality. We encourage you to read the privacy statements of these websites, which may differ from ours.

Search Engines and other sites

Search engines and other sites not affiliated with us, such as archive.org or google.com, may crawl the Site and make available to the public publicly-available content and postings from the site. The portal may also contain links to other websites. We are not responsible for the privacy practices of such other websites. We encourage visitors and users to be aware of such search engines and other sites when they leave the Site and to read the privacy statement of each website they visit.

Sale/Merger

Information about our Users and our Website is a business asset of BeNedIN Group B.V. Consequently, information about our Users, including personal information, will be disclosed as part of any merger or acquisition, creation of a separate business to provide the Website, our Services or fulfill products, sale or pledge of company assets as well as in the event of an insolvency, bankruptcy or receivership in which personal information would be transferred as one of the business assets of the company.

Policy Changes: 

We may update this Privacy Policy to reflect changes to our information practices. If we make any change in how we use your personal information we will notify you by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. For any further questions or notification of data breaches, please contact us on support@glocalphygital.com

Our intent is to promptly reply to every message we receive. This information is used to respond directly to your questions or comments. We also may file your comments to improve our services in the future.