BugBase Privacy Policy

BugBase PTE LTE (referred as Company or “we” or “us” or “our”) an affiliate of BugBase Security Private Limited is the owner of the website domain at https://bugbase.ai/ and other associated/ancillary applications, products, websites and services and all other variations and sub-domains of the same (referred as “Platform”); and any service availed by Users (hereinafter referred to as “you”, “your” or “User”) through the Platform is conditioned upon your acceptance of the terms and conditions contained in Terms of Service as available on Platform and this privacy policy (“Privacy Policy”).

THIS PRIVACY POLICY IS AN ELECTRONIC RECORD IN THE FORM OF AN ELECTRONIC CONTRACT FORMED UNDER THE INFORMATION TECHNOLOGY ACT, 2000 AND THE RULES MADE THEREUNDER AND THE PROVISIONS PERTAINING TO ELECTRONIC DOCUMENTS / RECORDS IN VARIOUS STATUTES AS AMENDED BY THE INFORMATION TECHNOLOGY ACT, 2000 OR ANY RELEVANT STATUTE OR REGULATION UNDER ANY APPLICABLE JURISDICTION. THIS PRIVACY POLICY DOES NOT REQUIRE ANY PHYSICAL, ELECTRONIC OR DIGITAL SIGNATURE.

We are committed to keeping your personal data private and secure. We process any personal data we collect from you in accordance with the applicable laws and regulations and the provisions of this Privacy Policy. We have taken considerable efforts to ensure that we only collect minimal data from you and only to the extent necessary in order for us to provide you with Services.

The purpose of this Privacy Policy is to ensure that there is an intact charter to collect, use and protect any personal and/or sensitive data collected by us. This Policy defines our procedure for collection, usage, processing, disclosure and protection of any information obtained by us through the Platform. Capitalized terms that are not defined in this Privacy Policy shall have the same meaning as ascribed to them in our Terms of Service. Any reference made to Privacy Policy in this document shall mean and refer to the latest version of the Privacy Policy.

1. CONSENT

THIS PRIVACY POLICY IS A LEGALLY BINDING DOCUMENT BETWEEN YOU AND THE COMPANY. THE TERMS OF THIS PRIVACY POLICY WILL BE EFFECTIVE UPON YOUR ACCEPTANCE OF THE TERMS OF SERVICE OR BY YOUR USE OF OUR SERVICES AND WILL GOVERN THE RELATIONSHIP BETWEEN COMPANY AND YOU WITH RESPECT TO THE COLLECTION AND TREATMENT OF INFORMATION SHARED BY YOU.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT AFFECTS YOUR RIGHTS AND LIABILITIES UNDER LAW. BY USING THIS PLATFORM AND AVAILING OUR SERVICES, YOU INDICATE THAT YOU UNDERSTAND, AGREE AND CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THIS WEBSITE OR AVAIL OUR SERVICES.

Please be advised that any Information procured by us, shall be:

• processed fairly and lawfully for rendering the Services;
• obtained only for specified and lawful purposes;
• adequate, relevant and not excessive in relation to the purpose for which it is required;
• able to be reviewed by the User, from time to time and updated-if need arises; and
• not kept longer than for the time which it is required or the purpose for which it is required or as required by the applicable law.

If you do not agree with this Privacy Policy, you may refuse or withdraw your consent any time, or alternatively choose to not provide us with any Personal Information, you understand that under such circumstance, we may be unable to render Services. Any such intimation to withdraw your consent can be sent to [email protected].

WE SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE SUSTAINED BY REASON OF ANY DISCLOSURE (INADVERTENT OR OTHERWISE) OF ANY DATA, IF THE SAME IS EITHER (A) REQUIRED FOR SHARING YOUR INFORMATION FOR LEGITIMATE PURPOSES; OR (B) WAS CAUSED THROUGH NO FAULT, ACT, OR OMISSION OF THE COMPANY.

2. TYPES OF INFORMATION COLLECTED BY US

“Personal Data” means and includes any Information that relates to a natural person through which an individual is identified, such as the name, email id, country of origin or any other information relevant to product choice and preferences provided by a User, including but not limited to information gathered through availing Services.

“Sensitive Personal Data” means and includes information relating to (i) financial information such as bank account or credit card or debit card or other payment instrument details of the Cyber Security Professional.

“Technical Information” means and includes any Information gathered through various technologies that may employ cookies or similar technologies to automatically record certain information from your device through which you use the Platform. This technical information may include your Internet Protocol (IP) address.

“Non-Personal Information” means and includes any information that does not reveal your specific identity, such as, browser information, information collected through Cookies (as defined below), pixel tags and other technologies, demographic information, etc. As is true with most websites, our Company gathers some information automatically when you visit the Platform. When you use the Platform, we may collect certain information about your computer or mobile to facilitate, evaluate and verify your use of the Platform. For example, we may store environmental variables, such as browser type, operating system, speed of the central processing unit (CPU), referring or exit web pages, click patterns. This information is generally collected in aggregate form, without identifying any User individually.

(The Personal Data, Sensitive Personal Data, Technical Information, and Non-Personal Information are collectively referred to as “Information”).

3. COLLECTION OF INFORMATION

3.1 Information may be collected in various ways including during the course of you registering as a User on the Platform, or availing certain Services offered on the Platform.

3.2 We may receive Information about you from third-party platform, such as social media platforms, marketing and advertising firms, commercially available sources and business partners to whom you have consented disclosure of such Information.

3.3 Please do note that each category of Information may be treated differently as per this Privacy Policy.

4. PURPOSE FOR COLLECTING OF INFORMATION

1. to render Services and facilitate your use of the Platform;
2. to respond to your inquiries or fulfil your requests for information about the various Services offered on the Platform;
3. to provide you with information about Services available on the Platform and to send you information, materials, and offers;
4. to send you important information regarding the Platform, changes in terms and conditions, user agreements, and policies and/or other administrative information;
5. to send you surveys and marketing communications;
6. to improve user experience
7. to help you address your problems incurred on the Platform including addressing any technical problems;
8. to protect the integrity and for proper administering of the Platform;
9. to conduct academic research, surveys, analytical studies on various aspects including user behaviour, user preferences etc.;
10. to respond to legal, judicial, quasi-judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law;
11. to implement information security practices;
12. to determine any security breaches, computer contaminant or computer virus;
13. to investigate, prevent, or take action regarding illegal activities and suspected fraud,
14. to enable a potential buyer or investor to evaluate the business of the Company.
15. Business or Research Purposes: The Information saved and except Sensitive Personal Information, is used for business or research purposes, including improving and customizing the Platform for ease of use and the products and services offered by us. We may archive this information to use it for future communications for providing updates and/or surveys.
16. Aggregating Information / Anonymized data: We may aggregate Information and analyse it in a manner to further accentuate the level of services that we offer to our customers. This Information includes average number of Users of the Platform, the average clicks of the services/, the features used, the response rate, etc. and other such statistics regarding groups or individuals. In doing so, we shall not be making disclosures of any Sensitive Personal Information as defined above.

[Individually and collectively referred to as ("Legitimate Purposes")]

5. SHARING AND DISCLOSURE OF YOUR INFORMATION

5.1 We do not rent, sell or disclose or share any Information that we collect from you, with third parties, save and except in order to provide you with the Services. Any such disclosure, if made, shall be in accordance to this Privacy Policy and as per the procedure prescribed by law and in compliance with our legal obligations. We may share your Information in circumstances and for the purposes as specified hereunder:

5.2 We shall share the information to the third-party service providers/ vendors, to provide you with the Services.

5.3 We may disclose any Information provided by you on the Platform as may be deemed to be necessary or appropriate:

• under applicable law, including laws outside your country of residence;
• to comply with legal process;
• to respond to requests from public and government authorities including public and government authorities including public and government authorities outside your country of residence;
• to protect our operations or those of any of our affiliates;
• to protect our rights, privacy, safety or property, and/that of our affiliates, you or others;
• to allow us to pursue available remedies or limit the damages that we may sustain; or
• to protect against legal liability;
• to protect the personal safety of Users of the Platform;
• to prevent or investigate possible wrongdoing in connection with the Platform.

5.4 Merger or Acquisition: We may share Information upon merger or acquisition of Company with another company. We shall transmit and transfer the Information upon acquisition or merger of Company with another company.

5.5 With our service providers: We may share Information with other service providers on a need to know basis, subject to obligations of confidentiality for provision of Services. We hereby clarify that we work with institutions, vendors, partners, advertisers, and other service providers, including (but not limited) to those who provide products or services such as contact Information verification, website hosting, data analysis, providing infrastructure, information technology services, auditing services and other similar services, in different industries and categories of business by virtue of lawful contracts instituted between such third parties and Company to improve our product and services. Accordingly, we may share your Information with such service provider in order to provide you with Services.

5.6 Employees /Agents of Company: We follow a strict confidentiality policy with regard to disclosure of confidential information to our employees or other personnel. There may be situations, where we may disclose the confidential information only to those of our employees and other personnel on a need to know basis. Any breach of confidential information by the employees, personnel within the Company is dealt with stringently by us.

5.7 Except for the Information disclosed pursuant to this section, Company may share Information only if you authorize us to do so.

6. LINK TO OTHER WEBSITES AND THIRD-PARTY SERVICES

6.1 Our Platform may provide links to other sites. These links are provided for your convenience only and the provision of these links does not mean that sites are related or associated with us. Please note that these sites have their own terms of use and privacy policy. You should check their privacy policy before you submit Your Personal Information or any other data with them. We don’t guarantee the content and the security of those sites.

6.2 We may have certain features on our Platform which may be hosted by third parties, your interaction with such features shall be governed by the privacy policy of such third parties.

6.3 We shall not be responsible for any loss, damage, claim or expense caused as a result of you accessing these third-party sites and features.

6.4 We may use your Information to send you promotional Information about third parties which, we think you may find interesting, if you tell us that you wish this to happen. We shall not be responsible for any disclosure of Information due to unauthorized third-party access or other acts of third parties or acts or omissions beyond our reasonable control and you agree that you will not hold us responsible for any breach of security unless such breach has been caused as a direct result of our negligence or wilful default.

6.5 We use support services of third-party platforms and/or companies to direct you to payment gateways when you opt to pay for our Services. Your financial information is collected, stored and retained by such third-party platforms. We and such designated third-party platforms undertake measures designed to provide a security level that is appropriate to the risks of processing your personal information. However, you are requested to check and consent to the “Privacy Policy” of such third-party platforms in order to accept how such third-party platforms handle your Information.

7. CHILDREN’S PRIVACY

Children between the ages of 13 and 17 may register as Cyber Security Professionals on the Platform. Any such registration and the use of the Platform by the child will be subject to consent of the child’s parent or guardian.

If you are a parent or a guardian and your child wishes to register on the Platform, we request that you read the following section carefully:

For your child to have their own Account, we may need your permission to collect, use or disclose your child’s information as described in this Privacy Policy. When you allow your child to use our Services, you and your child are trusting us with your Personal Data. We understand this is a big responsibility and work hard to protect your information and put you in control.

Once you grant permission for your child to have an Account or profile, their account or profile will generally be treated like your own with respect to the information that we collect and all rights and obligations as stated in this Privacy Policy including with respect to consent, collection and disclosure will extend to you and your child.

At any time, parents can refuse to permit us to collect further Personal Data from their children in association with a particular Account, and can request that we delete from our records the personal information we have collected in connection with that Account. Please keep in mind that a request to delete records may lead to a termination of an Account, subscription, or other service.

About Verifiable Parental Consent:

Email Consent. In the event that the Company wishes to collect Personal Data from a child during the Account creation, we will first seek a parent or guardian’s consent by email verification. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If you do not provide parental consent by clicking on the link shared with you on the email, we will delete the parent contact information and any other information collected from the child in connection with that activity.

KYC: In the event that your child is taking part in a Bounty Program that involves a monetary transaction, we are mandated under law to verify your KYC prior to processing any such monetary incentives. In such a scenario, we would be conducting your KYC through our third-party service provider and in the event you do not consent to the same, you may reject the KYC request or reach out to us at [email protected].

Please be aware that to protect children’s privacy and security, we will take reasonable steps to verify a parent or legal guardian’s identity before granting access to any Personal Data.

If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us as at [email protected]. We will dispose of that data in accordance with applicable laws and regulations.

8. DATA PROTECTION RIGHTS

8.1 You have certain rights available to you when it comes to your Personal Information. Subject to any exemptions provided by the applicable laws, you have the following rights:

• 8.1.1 Rectifying, correcting, updating and removing Your information:

  You can access, edit, modify and/or update your Personal Information by logging into your user profile or you can write to us via email in case you wish to exercise this right.

• 8.1.2 Accessing and updating or deleting Your information:

  Our Services and related documentation on our Platform provide you with the ability to access, update and delete certain Personal Information from your Account, if any. We will provide you with information about whether we hold any of your Personal Information upon request. We will respond to such requests within a reasonable timeframe. Please note, however, that we may need to retain certain information for record keeping purposes, to complete our Services and related obligations to you or to comply with our legal obligations.

• 8.1.3 Object or restrict processing of Your information:

  You have the right to: (i) object to our processing of your Personal Information; and/or (ii) request that we restrict the processing of your Personal Information.

• 8.1.4 Portability:

  You shall have the right to request us to transfer Your Personal Information to another controller, or directly to you, in a structured, commonly used and machine-readable format.

8.2 In order to exercise these rights, please contact us on [email protected].

9. STORAGE AND TRANSFER OF INFORMATION

Your Information will primarily be stored in electronic form; provided, however, that certain data can also be stored in physical form. We primarily store all Information within the territory of India. If your Information is transported outside the territorial jurisdiction of India, we will provide you due notice of such transfer. We may enter into agreements with third parties (in or outside of India) to store or process your information or data. These third parties may have their own security standards to safeguard your information or data and we will on commercial reasonable basis require from such third parties to adopt reasonable security standards to safeguard your information / data.

10. COOKIES AND OTHER TRACKING TECHNOLOGIES

10.1 Our Platform may utilize “cookies” and other Technical Information. “Cookies” are a small text file consisting of alphanumeric numbers used to collect the Information about Platform activity. Cookies in no way gives us access to your computer or mobile device. We only use session Cookies to keep a track of session information for persistence of authentication.

11. DATA RETENTION

We will retain your Information for as long as your Account is active or as needed to provide our Services. We shall retain and use the Information collected by us as necessary to comply with our legal obligations, resolve disputes or for other Legitimate Purposes. If you cancel/ deactivate/ unsubscribe your account with us, we are not under any obligation to retain your Information. However, may retain the Information pertaining to the User for the maximum period permitted under the law of the land from the date of deactivation of User’s Account.

12. SECURITY MEASURES AND SAFEGUARDS

You agree and accept that your Information may be stored in third-party cloud service infrastructure providers. While all reasonable attempts have been taken from our end to ensure the safe and secure storage of your data, we shall not be liable for any data breach on the part of the third-party cloud service infrastructure provider that was beyond our control. In addition to the security measures put in place by the third-party cloud service infrastructure provider for safe and secure storage of your Information, we use certain physical, managerial, technical or operational safeguards as per industry standards and established best practices to protect the Information we collect. We use reasonable security practices and procedures and use secure servers as mandated under applicable laws for the protection of your Information. We review our Information collection, storage, and processing practices, including physical security measures to guard against unauthorized access to systems. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the Information you supply will not be intercepted while being transmitted to us over the internet. However, since the internet is not a 100% secure environment, we on best effort basis ensures the security of any information the User transmits to us and that the information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please note that e-mails and other communications the User sends to us through our Platform are not encrypted, and we strongly advise the User not to communicate any confidential information through these means.

The Company is also in compliance with the reasonable security processes and procedures standard as recommended by the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011. The Company has also gotten certified for industry standards such as ISO27001:2013 and SOC 2 Type II as well as the ISO 29147:2018. Further, the Company has taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the Information you entrust to us.

13. UPDATES TO THIS PRIVACY POLICY

We may change the data privacy practices and update this Privacy Policy as and when the need arises, and the same will be made available on the Platform. But our commitment to protect your privacy will continue to remain. We suggest that you regularly check this Privacy Policy to apprise yourself of any updates. Your continued use of Platform and Services or provision of Information thereafter will imply your unconditional acceptance of such updates to this Privacy Policy. Further, we retain the right at any time to deny or suspend access to all, or any part of, the service to anyone who we reasonably believe has violated any provision of this Privacy Policy

14. MISCELLANEOUS

ENFORCEABILITY OF THE REMAINDER OF THIS PRIVACY POLICY. THIS PRIVACY POLICY DOES NOT APPLY TO ANY INFORMATION OTHER THAN THE INFORMATION COLLECTED BY US THROUGH THE PLATFORM. THIS PRIVACY POLICY SHALL BE INAPPLICABLE TO ANY UNSOLICITED INFORMATION YOU PROVIDE US THROUGH THE PLATFORM OR THROUGH ANY OTHER MEANS. ALL UNSOLICITED INFORMATION SHALL BE DEEMED TO BE NON- CONFIDENTIAL AND WE SHALL BE FREE TO USE AND/ OR DISCLOSE SUCH UNSOLICITED INFORMATION WITHOUT ANY LIMITATIONS. THE RIGHTS AND REMEDIES AVAILABLE UNDER THIS POLICY MAY BE EXERCISED AS OFTEN AS NECESSARY AND ARE CUMULATIVE AND NOT EXCLUSIVE OF RIGHTS OR REMEDIES PROVIDED BY LAW. RIGHTS UNDER THIS POLICY MAY BE WAIVED ONLY IN WRITING. DELAY IN EXERCISING OR NON-EXERCISE OF ANY SUCH RIGHT OR REMEDY DOES NOT CONSTITUTE A WAIVER OF THAT RIGHT OR REMEDY, OR ANY OTHER RIGHT OR REMEDY.

15. GRIEVANCE OFFICER

In furtherance of the Information Technology Act, 2000 (“IT Act”) and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“Intermediary Guidelines”) a grievance officer is appointed to ensure compliance with the IT Act and the Intermediary guidelines.

Name: Kathan Desai
Address: The Octagon, Singapore
Phone: +91 88265 23484
Email: [email protected]


The grievance officer shall revert to every complaint within 24 hours of receipt of the complaint. Further, the Company shall take best possible efforts to redress the complaint within 15 days of receipt of the complaint. Any suggestions by Company regarding use of the Services shall not be construed as a warranty.

Please feel free to reach out to us by e-mail at [email protected] in case of any concerns, grievances, or questions relating to our privacy or data related practices