Privacy Policy and Data protection

(Release date – 11 March 2017)

Bug86 Private Ltd is a private limited company duly constituted under the Companies Act 1956, (hereinafter referred to as “Bug86 ” or the “COMPANY”) Bug86 has developed a software / platform / software as a service which can be used by a Client, User or a Researcher by accessing the website www.Bug86.com, www.threatbar.com.

By agreeing to use the Bug86 Platform or the website www.Bug86.com or www.threatbar.com, You (Client, Researcher or User as applicable) agrees to the following :

A. Privacy Policy and Data Protection

  1. General

    This privacy policy is published in compliance of provisions of the Information Technology Act 2000. The Privacy Policy sets out:

    • The type of information collected from Client, Researcher or User (You)
    • The purpose, means and modes of usage of such information; and
    • How and to whom BUG86 will disclose such information

    The Client, Researcher or User is expected to read and understand the Privacy Policy, so as to ensure that it has express knowledge of:

    • the fact that the information is being collected;
    • the purpose for which the information is being collected;
    • the intended recipients of the information;
    • the name and address of the entity that is collecting the information and the entity that will retain the information; and
    • the various rights available to such it in respect of such information.
  2. Definitions of Personal Information and Sensitive Personal Information as defined in IT Act 2000 and Rules

    Personal Information is defined to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. Sensitive Personal Data or Information of a person means such personal information which consists of information relating to-

    • Password
    • financial information such as bank account or credit card or debit card or other payment instrument details
    • physical, physiological and mental health condition
    • sexual orientation
    • medical records and history
    • biometric information
    • any detail relating to the above clauses as provided to body corporate for providing service
    • any of the information received under the above clauses by body corporate for processing, stored or processed under lawful contract or otherwise
  3. Collection of Personal Information

    BUG86 may collect Personal information from You directly at the time of enrolment or thereafter. BUG86 at the time of enrolment asks for and collects certain information about You, including personally identifiable information, such as name, age, educational qualifications, postal address, phone number, email address, etc. BUG86 may also collect or gather information about you indirectly in the background relating to the usage of the BUG86 Platform or Website by You, such as IP address, location details, Date-Time stamp, etc. BUG86 may also collect your information from Social media platforms or profiles wich may include photos or links to other social media profiles or other sources. By using the BUG86 Platform or Website you have given your consent to BUG86 to collect or gather information about you directly or indirectly through cookies or other technical methods. However if you choose to diable the “cookies” , some parts of the portal or the website may not function properly.

  4. Collection of Sensitive Personal Information

    BUG86 collects only Bank account details from you for the purpose of processing payment. BUG86 does not collect any other Sensitive Personal Information from You at any time.

  5. Use of Personal Information and Sensitive Personal Information by BUG86

    BUG86 may use your Personal Information collected by BUG86 directly or indirectly to provide member benefits or to promote or market products and services of BUG86 or of a third party which BUG86 thinks may be of interest or beneficial to you, or to communicate with you for other purposes or to enable you to effectively use BUG86 or for analytics such as studying user behavior or to evaluate or improve the BUG86 Platform or Website design or to enhance the User experience or for technical support or for marketing purposes of BUG86. BUG86 may use your Personal Information collected by BUG86 directly or indirectly for commercial purposes. BUG86 also reserves the right to use the personal information for analytics, research, etc and also for providing analytics and business intelligence based on your personal information for commercial purposes in an anonymised form.

    BUG86 shall use the Bank account details collected from you for the purpose of processing payment.

  6. Disclosure Policy

    BUG86 may sell, share, or otherwise disclose your Personal Information for commercial purposes and may disclose your Personal Information to other BUG86 affiliates, agents, partners, and clients worldwide for the stated Purpose or Use. Personal Information may also be disclosed to third parties who act for or on behalf of BUG86 for further processing in accordance with the purpose for which the information was originally collected or may otherwise be lawfully processed. Also, Personal Information may be disclosed to a third party if BUG86 is required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.

    BUG86 may sell, share, or otherwise disclose anonymised Personal Information for commercial purposes or to other BUG86 affiliates, agents, partners, and clients worldwide for the stated Purpose or Use. Anonymised Personal Information to which BUG86 has access may also be disclosed to third parties who act for or on behalf of BUG86.

  7. BUG86 shall disclose personal information collected from you to Court , statutory bodies or law enforcement agencies as and when required by law.

  8. BUG86 shall not disclose sensitive personal information collected from you to anyone except to Court , statutory bodies or law enforcement agencies as and when required by law.

  9. BUG86 shall retain all the information provided by you even after termination of services or disabling of deletion of the account.

  10. BUG86 reserves the right, at any time and without notice, to change this Privacy and Disclosure Policy, simply by communicating the same to you via email or SMS. Regardless of later updates, BUG86 will never use the information you submit in a new way without first providing you with an opportunity to prevent that use.

  11. The information submitted by the You shall be held for as long as is required to access the service requested and as required by law. You have the right to withdraw your consent at any time. On termination of this agreement or withdrawal of consent, all personal information will be deleted from Bug86’s records unless required by law.

  12. You can review and amend your personal information. If You update any of your personal information, BUG86 may keep a copy of the information which You originally provided in its archives.

  13. BUG86 shall not be responsible in any manner for the authenticity of the personal information or sensitive personal information or information supplied by You.

  14. BUG86 is not liable for any loss of data technical or otherwise, information or particulars supplied by You, due to reasons or causes or conditions beyond its control including but not limited to corruption of data, strike, riots, civil unrest, Govt. policies, tampering of data by unauthorized persons like hackers, war and natural calamities.

  15. Should you have questions about this Privacy Policy or BUG86's information collection, use and disclosure practices, you may contact, the Data Protection Officer appointed by BUG86. BUG86 will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information. If you have any grievance with respect to our use of your information, you may communicate such grievance to the Data Protection Officer at legal@threatbar.com

B. Intermediary Guidelines / Covenants

As mandated by Regulation 3(2) of the IG Rules, BUG86 hereby informs You that You are not permitted to host, display, upload, modify, publish, transmit, update or share any information that:

  1. belongs to another person and to which You not have any right to;
  2. is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, paedophilic, libellous, invasive of another's privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever;
  3. harm minors in any way;
  4. infringes any patent, trademark, copyright or other proprietary rights;
  5. violates any law for the time being in force;
  6. deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;
  7. impersonate another person;
  8. contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource;
  9. threatens the unity, integrity, defense, security or sovereignty of India, friendly relations with foreign states, or public order or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting any other nation.

BUG86, upon obtaining knowledge by itself or being brought to actual knowledge by an affected person in writing or through email signed with electronic signature about any such information as mentioned hereinabove, BUG86 shall be entitled to disable such information. BUG86 shall be entitled to preserve such information and associated records for at least 90 (ninety) days for service on to governmental or investigative authorities for investigation purposes.