Introduction

This policy addresses the vision of SPRING RAIN PRIVATE LTD on information security. Information security is defined as:

“The effective protection of SPRING RAIN PRIVATE LTD., confidential information by a coherent set of appropriate measures aimed at securing the availability, integrity and confidentiality of information.”

General

• Information security measures are based on a risk-based approach. SPRING RAIN PRIVATE LTD accepts an acceptable level of risk at an acceptable cost and updates its risk picture at least annually.
• The SPRING RAIN PRIVATE LTD team is hired and screened appropriately. Team members are committed to the information security policies and guidelines of SPRING RAIN PRIVATE LTD. SPRING RAIN PRIVATE LTD is an organization with an open and professional culture, in which employees are forced to be creative to deliver a contribution to the organization goals. The communication structure within SPRING RAIN PRIVATE LTD . is lean and flexible, and always aimed at collaboration and innovation. Team members are used to share information with other team members as well as with customers. SPRING RAIN PRIVATE LTD realizes that the use of modern media and collaboration tools is essential to its success, however raising awareness regarding information security is essential to use these tools safely.
• This Information Security Policy and all other guidelines and procedures are embedded in the SPRING RAIN PRIVATE LTD. Information Security Management System (ISMS). The ISMS is available to all employees. The ISMS must ensure that SPRING RAIN PRIVATE LTD. Continue to fulfill relevant information requirements, as defined in the ISO 27001 standard and relevant legislation.

CONFIDENTIALITY NOTICE

This documentation is proprietary information of SPRING RAIN PRIVATE LTD. and is not to be copied, reproduced, lent or disposed of, nor used for any purpose other than that for which it is specifically provided without the written permission of SPRING RAIN PRIVATE LTD.
SPRING RAIN PRIVATE LTD. All rights reserved. The unauthorized possession, use, reproduction, distribution, display or disclosure of this material or the information contained herein is prohibited.

DISCLAIMER

The content in this guide may include outdated information or omissions due to development activity that has occurred since its printing. In addition, your screens may look different than those depicted in the screenshots based on your system preferences and configuration.

1. Introduction
   1. We are committed to safeguarding the privacy of our website visitors and service users.
   2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
   3. In this policy, “we”, “us” and “our” refer to SPRING RAIN PRIVATE LTD. Personal information is data that can be used to identify or contact a single person.
2. What personal information we collect and how we use it
   1. When you use our website our services or contact us we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, company, IP address and location information.
   2. We may process your personal information for the purposes described in this Privacy Policy with your consent, when we have assessed it is necessary for the purposes of our legitimate interests or for compliance with a legal obligation to which we are subject.
   3. The different categories of personal data we may collect are:
      1. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and through the use of cookies. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
      2. We may process your account data (“account data”). The account data may include your name, email address and your company. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services,ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
      3. We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
      4. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent. If you don’t want to be on our mailing list, you can opt out anytime by emailing  info@springrainit.com.
      5. We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
      6. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
      7. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent. If you don’t want to be on our mailing list, you can opt out anytime by emailing info@springrainit.com.
      8. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3. Providing your personal data to others
   1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
   2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
   3. We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, such as lawful requests by public authorities, including to meet national security or law enforcement requirements, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
   4. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party. We remain liable for appropriate onward transfers of personal data to third parties who do not comply with the Privacy Shield principles.
4. Cookies
   1. Our websites, online services, interactive applications, email messages, and advertisements may use “cookies” to identify you when you visit our website and as you navigate our website. We treat information collected by cookies and other technologies as non-personal information, except any IP addresses or similar identifiers which are considered personal information by local law. When non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.
   2. We use this information to help us to analyze the use and performance of our website and services, including user behavior on the site, demographic information of visitors and to improve our product and services.
   3. In some of our email messages, we use a “click-through URL” linked to content on our website to measure the effectiveness of our customer communications.
5. Retaining and deleting personal data
   1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy. We will retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.
6. Access to personal information
   1. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
   2. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
   3. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
   4. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
   5. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
   6. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
   7. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
   8. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier.
7. International users
   1. All the information you provide may be transferred or accessed by our entities around the world as described in this Privacy Policy. We and our other group companies have offices and facilities in the USA and UK. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards.
8. Contacting us

   If you have any questions or concerns about our Privacy Policy or data processing, please contact us:
   7th Floor, Commercial Cove, House 56/C, Road 132, Dhaka 1212, Bangladesh. You can contact us:

   1. by post, to the postal address given above;
   2. using our website contact form;
   3. by telephone, on the contact number published on our website.

   We may update this policy from time to time by publishing a new version on our website.
   You should check this page occasionally to ensure you are happy with any changes to this policy.
   We may notify you of significant changes to this policy by email.

9. Credit

   This Privacy Policy was created through a template from SEQ Legal (https://seqlegal.com).