This Privacy Policy (“privacy policy”) explains our policy regarding the collection, use, disclosure and transfer of the end user’s (hereinafter referred to as “you”/ “your”/ “user”) information by Highlanders Media and Entertainment Private Limited and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as the company”/ “us”/ “our”/ “we”), collected by the company as a result of your access to and use of Headline 8 website (which term shall be deemed to include the website https://headline8.in as well as its mobile application [as and when the same shall be made available]) or any other technological variants thereof including social media platforms, accessible through a computer, mobile or any internet-connected device(s) or any other means to access the same from time to time) and the services offered thereunder (“services”). This privacy policy forms an integral part and parcel of, and shall be read in conjunction with the Terms of Use (hereinafter referred to as “TOU”, and available here).

By accessing the Headline 8 website or otherwise using the services, you consent to the collection, storage, and use of the personal information made available by you (including any changes thereto as provided by you) for any of the services that we offer. The company reserves the right to modify this privacy policy in any manner, from time to time, entirely at its own discretion, with or without any notification to you. The company shall be under no obligation to notify the implementation of any modifications to the privacy policy to you. You are responsible for checking the privacy policy periodically to remain in compliance with the terms of this privacy policy. Your access to and use of the Headline 8 website after any amendment to the privacy policy shall constitute your deemed acceptance of such modified terms. Discontinuing the use of the services will not affect the applicability of the privacy policy to your prior uses of the services.

The company respects your privacy and is committed to reasonably protect it in all respects. The information about you is collected by the company is: (a) information supplied by users and (b) information automatically tracked while navigation (c) information collected from any other source (collectively referred to as “information”).

1. INFORMATION RECEIVED, COLLECTED AND STORED BY THE COMPANY

A. INFORMATION SUPPLIED BY USERS

i) Registration or comment data:

When you register and/or leave comments on the Headline 8 website, we may ask that you provide basic contact information such as your name, sex, age, address, pin code, contact number, occupation, interests, website and email address etc. When you register using your accounts on third-party platforms like Facebook, Twitter, Gmail etc. (as facilitated by the company on the Headline 8 website from time to time), we shall retrieve Information from such account(s) to continue to interact with you and to continue providing the services seamlessly.

ii) Voluntary information:

We may collect additional information at other times, including but not limited to, when you provide feedback, change your content or email preferences, respond to a survey, or communicate with us.

B. INFORMATION AUTOMATICALLY COLLECTED/ TRACKED WHILE NAVIGATION

i) Cookies:

To improve the responsiveness of the Headline 8 website for you, we may use “cookies”, or similar electronic tools to collect information to assign each user a unique, random number as a user identification (user ID) to understand your individual interests using the identified computer. Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer. The only personal information a cookie can contain is information you supply. Our advertisers may also assign their own cookies to your browser (if you click on their ads), a process that we do not control.

ii) Cookies – Opting out:

If a user opts out using the Ads Settings, the unique ‘DoubleClick cookie ID’ on the user’s browser is overwritten with the phrase “OPT_OUT”. Because there is no longer a unique cookie ID, the opt-out cookie can’t be associated with a particular browser.

iii) Log File information:

We automatically collect limited information about your computer’s connection to the Internet, mobile number, including your IP address, when you visit Headline 8 website. Your IP address is a number that lets computers attached to the Internet know where to send you data — such as the pages you view. We automatically receive and log information from your browser, including your IP address, your computer’s name, your operating system, browser type and version, CPU speed, and connection speed. We may also collect log information from your device, including your location, IP address, your device’s name, device’s serial number or unique identification number (e.g. UDiD on your iOS device) etc.

iv) Clear GIFs:

Besides web beacons, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. We use this information to inter-alia to measure traffic within the Website/ Service to improve the Website/ Service quality, functionality and interactivity and let advertisers know the geographic locations from where our visitors come.

v) Information from other sources:

We may receive information about you from other sources, add it to our user information database and treat it in accordance with this privacy policy. If you provide information to the platform provider or other partner, whom we provide services, your account information and order information may be passed on to us. We may obtain updated contact information from third parties in order to correct our records and fulfil services or to communicate with you.

vi) Demographic and purchase information:

We may reference other sources of demographic and other information in order to provide you with more targeted communications and promotions. We use Google Analytics, among others, to track user behaviour on the Headline 8 website. Google Analytics specifically has been enabled to support display advertising towards helping us gain an understanding of our users’ demographics and interests. The reports are anonymous and cannot be associated with any individual personally identifiable information that you may have shared with us. You can opt-out of Google Analytics for ‘Display Advertising’ and customize ‘Google Display Network ads using the ‘Ads Settings’ options provided by Google.

2. INFORMATION USE BY THE COMPANY

i) The information supplied by the users enables us to improve the services and provide you with the most user-friendly experience. All required information is service dependent and the company may use the above-said user information to, maintain, protect, and improve the services (including advertising on the Headline 8 website) and for developing new services. Pursuant to your confirmation to access the services, we may also use your email address or other personally identifiable information to send commercial or marketing messages without your consent [with an option to subscribe/unsubscribe (where feasible)]. We may, however, use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major changes, for customer service purposes, billing, etc.).

ii) Any personally identifiable information provided by you will not be considered as sensitive if it is freely available and/or accessible in the public domain like any comments, messages, blogs, scribbles available on social platforms like Facebook, Twitter, Instagram etc.

iii) Any content posted/uploaded/conveyed/communicated by users on the public sections of Headline 8 website and social media platforms becomes published content and is not considered personally identifiable information subject to this privacy policy.

iv) In case you choose to decline to submit personally identifiable information on the Headline 8 website, we may not be able to provide certain services on the Headline 8 website to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of any services to you for your failure to provide the necessary personal information.

3. INFORMATION SHARING

i) The company may share your information with a third party without obtaining your prior consent in the following limited circumstances:

a) When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing the terms of this privacy policy or TOU or for complying with the applicable laws and regulations;

b) The company may share such information within its group companies and officers and employees of such group companies for the purpose of processing personal information on its behalf. We also ensure that these recipients of such information agree to process such information based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures;

c) The company may present information to its advertisers – to help them understand our audience and confirm the value of advertising on the Headline 8 website – however, it is usually in the form of aggregated statistics on traffic to various pages within Headline 8 website without identifying any specific user;

d) The company may share your information regarding your activities on the Headline 8 website with third party social websites to populate your social wall that is visible to other people however you will have an option to set your privacy settings, where you can decide what you would like to share or not to share with others.

4. ACCESSING AND UPDATING PERSONAL INFORMATION

When you use the Headline 8 website (or any of its sub-sites), we make good faith efforts to provide to you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible, subject to any requirement for such personal information or sensitive personal data or information to be retained by law or for legitimate business purposes. Before processing requests by a user pertaining to access, correction or removal of any information related to such user, we may ask each user to identify them initially and thereafter, the information requested to be accessed, corrected or removed. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

5. INFORMATION SECURITY

We take appropriate security measures to protect the Headline 8 website and your information against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered on the Headline 8 website is securely stored within the company controlled database on a best-effort basis. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. However, we cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the internet. Further, you agree and confirm that any information you include in a posting to the discussion areas on the Headline 8 website is available to anyone with Internet access.

6. GRIEVANCE REDRESSAL

Redressal Mechanism: Any complaints or concerns with regards to content and or comment or breach of these terms shall be taken up with the designated Grievance Officer as mentioned below in writing via email/post/courier sent to the appropriate address:

info@headline8.in

Or,

Manoranjan Majumder,

Grievance Officer,

Headline 8,

S.K. Hazarika College Building,

2nd Floor, Shree Nagar, RG Baruah Road,

Guwahati, Assam—781024

7. GOVERNING LAWS

These TOU shall be governed by the Laws of the Union of India. The Courts of law at Kamrup Metropolitan district, Assam shall have exclusive jurisdiction over any disputes arising in relation to these TOU.

8. GENERAL TERMS

i) This privacy policy and the TOU constitute the entire agreement between you and the company with respect to the subject matter hereof and supersede and replaces all prior or contemporaneous understandings or agreements, written or oral, regarding such subject matter.

ii) By using the Headline 8 website and services provided thereunder, you signify your acceptance of the TOU and this privacy policy. If you do not agree or are not comfortable with any policy described in the TOU and/ or the privacy policy, your only remedy is to discontinue the use of the Headline 8 website. We reserve the right, to modify the TOU and/ or the privacy policy at any time.

[YOUR ACCESS AND USE OF SERVICE SHALL MEAN THAT YOU HAVE READ, UNDERSTAND AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND TERMS OF USE. BY ACCESSING OR USING OUR SERVICE, YOU ALSO REPRESENT THAT YOU HAVE THE LEGAL AUTHORITY AS PER APPLICABLE LAW TO ACCEPT THE TERMS ON BEHALF OF YOURSELF AND/ OR ANY OTHER PERSON YOU REPRESENT IN CONNECTION WITH YOUR USE OF THE SERVICE.]