GDPR COMPLIANCE

This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing.

Article 4 of GDPR defines Personal Data and Troop Messenger App collects the following Personal Data about you (“Data Subject”).

• Name
• Email ID
• Mobile No
• Name of the Company
• Designation Details
• Google Play/Apple App Store Service Details

Troop Messenger App is a comprehensive business team collaboration & instant messaging tool requiring you (“Data Subject”) to provide your Personal Data for the purpose of enabling you to use the App (Troop Messenger App) for chatting, broadcasting, screen sharing, audio/video calls, unlimited group creation, free email/ call support, burnout, storage up to 1 TB.

Troop Messenger App processes your (“Data Subject”) Personal Data as a Data Controller with the meaning as defined under Article 4 of GDPR. However, in these circumstances, Troop Messenger App shall be acting under a “Legitimate Interest” to process the Personal Data for the purpose of enabling you (“Data Subject”) to use the App (Troop Messenger App) and call, chat, meet, communicate, collaborate on a single screen addressing your business needs. It is this purpose which forms the “Legal Basis” for the processing of your (“Data Subject”) Personal Data.

Troop Messenger App processes your (“Data Subject”) Personal Data as a Data Processor also with the meaning as defined under Article 4 of GDPR.

Troop Messenger App respects your (“Data Subject”) rights regarding the processing of your (“Data Subject”) Personal Information and provides the details of the Data Protection Officer who can be contacted in case of any concerns and questions regarding how Troop Messenger App controls your Personal Data or in case you (“Data Subject”) wish to exercise any of the rights provided under GDPR.

# TVISHA SYSTEMS PVT LTD, PLOT NOS. 97&98, SS ARCADE, GUTTALA BEGUMPET, KAVURI HILLS PHASE III, MADHAPUR, HYDERABAD- 500081
Email : sudhir.naidu@tvisha.in

Troop Messenger App has adopted the following principles to govern the collection and processing of your (“Data Subject”) Personal Data

• Your (“Data Subject”) Personal Data shall be processed lawfully, fairly and in a transparent manner
• Your (“Data Subject”) Personal Data shall be collected and processed only for the purpose of enabling you to download, access, use Troop Messenger App
• Your (“Data Subject”) Personal Data shall be processed only for the purposes as mentioned herein, except where such interests are overridden by the fundamental rights and your (“Data Subject”) freedom which shall always take precedent. However, in the event you (“Data Subject”) have provided any specific consent to such processing, then such consent shall be withdrawn at any time as mentioned in this privacy notice.

To process your request, Troop Messenger App shall ask you to provide your Mobile Number for OTP and Email id for verification purpose. Your (“Data Subject”) rights under GDPR are:

• THE RIGHT TO BE INFORMED

Troop Messenger App as a data controller, shall be obliged to provide clear and transparent information about your data processing activities.

• THE RIGHT OF ACCESS

You (“Data Subject”) shall have the right to see what data is held about you by Troop Messenger App (“Data Controller”) (Right to Access). You (“Data Subject”) may request a copy of your (“Data Subject”) Personal Data we (“Troop Messenger App”) hold. Once we (“Troop Messenger App”) have verified your identity, we (“Troop Messenger App”) shall provide access to the Personal Data, we (“Troop Messenger App”) hold about you (“Data Subject”). However, if any requests require any additional time, then we (“Troop Messenger App) shall inform you regarding the same.

• THE RIGHT TO RECTIFICATION

In the event, you (“Data Subject”) believe that we (“Troop Messenger App”) hold inaccurate or incomplete Personal Information about you (“Data Subject”), you may exercise your right (“Data Subject Right”) to correct or complete or rectify the same. Further, this may be used with the right to restrict processing so as to ensure that incorrect / incomplete information is not processed until the same is rectified or corrected

• THE RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”)

You shall have the right to inform us (“Troop Messenger App”) to delete or erase any of the Personal Data we (“Troop Messenger App”) hold about you (“Data Subject”). In the event of such intimation, we (“Troop Messenger App”) shall take all reasonable steps to ensure such deletion or erasure. Further, where no overriding legal basis or legitimate reason continues to exist for processing your (“Data Subject”) Personal Data, you (“Data Subject”) shall inform us to delete your Personal Data.

• THE RIGHT TO RESTRICT PROCESSING

You (“Data Subject”) shall have the right to inform us (“Troop Messenger App”) to stop processing your Personal Data. However, in case of the following, you (“Data Subject”) may exercise the right to restrict processing

• Accuracy of your Personal Data is contested
• Processing of your Personal Data is unlawful
• We (“Troop Messenger App”) no longer require your Personal Data for processing
• The Right to object has been exercised and processing is restricted, pending a decision on the status of the processing

• THE RIGHT TO DATA PORTABILITY

You (“Data Subject”) may request your Personal Data be transferred to another controller or processor, which is to be provided in a commonly used and machine-readable format. This right shall be available in case the original processing was based on your (“Data Subject”) consent, the processing is by automated means and if such processing is based on the fulfillment of a contractual obligation as provided for under GDPR

• THE RIGHT TO OBJECT

You (“Data Subject”) shall have the right to object to the processing of your Personal Data by us (“Troop Messenger App”) in case

• The processing is based on legitimate interest
• The processing is for the purpose of direct marketing
• The processing is for the purpose of scientific or historic research
• The processing involves any automated decision making and profiling

We (“Troop Messenger App”) shall retain your Personal Data as long your activity on Troop Messenger App is active and you continue to use the Troop Messenger App. However, we (“Troop Messenger App”) retain your Personal Data till such time we have addressed the basis for your contacting us and using Troop Messenger App.

Your (“Data Subject”) Personal Information shall only be transferred to, or processed by, such third-parties as mentioned below only for the fulfilment of the purpose as mentioned herein i.e. for facilitating data backup or storage, screen sharing, call integration etc. Troop Messenger App shall be integrated with Google Drive, Drop Box for Data Backup or Storage, Team Viewer for Screen Sharing, Vonage/Cisco for Call Integration.
However, your (“Data Subject”) Personal Data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless such country or territory is recognised by the EU as having an adequate level of Data Security.

Troop Messenger App shall disclose your (“Data Subject”) Personal Data where required to do so by law, if subject to court order or subpoena or other legal proceeding or if Troop Messenger App reasonably believes that such disclosure is necessary to

• Comply with the law
• Comply with the requests of law enforcement
• Enforce legal policies including terms and conditions, Privacy Notice mentioned on Troop Messenger App
• Protect the security or integrity of Troop Messenger App services
• Exercise or protect the rights of Troop Messenger App and its users

Troop Messenger App has in place appropriate physical, electronic, technical, operational and managerial procedures and measures to protect your (“Data Subject”) Personal Data against loss, misuse and unauthorised access. Troop Messenger App shall ensure that your Personal Data is encrypted using Secure Socket Layer (SSL) and is stored with industry-standard encryption.
Although Troop Messenger App endeavours to safeguard your (“Data Subject”) Personal Data, transmissions made by means of Internet cannot be made absolutely secure. Troop Messenger App shall hold no liability for any acts, attacks, inadvertent disclosure beyond its control.

You (“Data Subject”) shall have the right to ask for any data provided by you through Troop Messenger App (“Data Controller”) which may be provided in a structured, commonly used and machine-readable format. Further, you (“Data Subject”) shall have the right to have the data, Troop Messenger App holds about you (“Data Subject”), transferred to any third party.

Troop Messenger App (“Data Controller”), shall notify you (“Data Subjects”) in case of becoming aware of data breach within 72 hours upon such awareness regarding such data breach under GDPR. Further, such data breach notification shall be sent via email to the email id registered or mentioned by you at the time of using or registering on Troop Messenger App.

Troop Messenger App shall implement appropriate technical and organisational measures in an effective manner to meet the requirement of GDPR as also protecting your (“Data Subject”) rights. Troop Messenger App shall hold and process the Personal Data absolutely necessary for completion of our obligations (data minimisation), as well as limiting the access to personal data to those needing to act out of processing.

Your (“Data Subject”) consent to this Privacy Notice and legal policies mentioned on Troop Messenger App while downloading, accessing, using Troop Messenger App shall be as per Article 6 and 9 of GPDR.

You (“Data Subject”) shall also be provided with an option to OPT- OUT. Further, in case you intend to withdraw your consent provided through Troop Messenger App, then you shall contact our Data Protection Officer and send an email (mentioned in this privacy notice) informing the same.