GOLDEN EPAULETTES AVIATION (“we”, “us”, “our”) values your privacy and is committed to ensuring that your privacy is protected. The purpose of this privacy policy (“Privacy Policy”) is to describe what information we collect about you while you use our services (“Services”) through our platform(“Platform” or “Platforms”), why we collect the information, how we use your information, how we protect and share your information, the choices we offer you, including your ability to access, update and remove information about yourself (“User” or “your” or “you”).

This Privacy Policy must be read in conjunction with the “Terms of Use” and all the terms and conditions therein. Please read and understand this Privacy Policy carefully, and its applicability to the Services that we provide you. If you do not agree with this Privacy Policy, do not access or use the Services.

1. APPLICABILITY

We ask for and collect certain information (specified below in section 2) about you when you use the Services. This information is necessary for the adequate performance of our obligations towards you and to allow us to comply with our legal obligations. Without this information, we may not be able to provide you access to and allow the use of the Services.

2. INFORMATION WE COLLECT

a) We collect the following broad categories of information from you (collectively referred to as “Information”)

i) “Personally Identifiable Information” – information that could be used to identify you such as, your name, email address, age, gender, date of birth, internet protocol (IP) addresses, demographic data such as your device location, and other similar information;
ii) “Sensitive Personal Information” – such as records of call logs, message logs, passwords, medical health information, and payment-related information;
iii) “Non–Personal Information” – information that cannot be used to identify you such as the web pages that you have viewed and your usage patterns, including certain types of device information;

b) Having regard to the foregoing, below is an inclusive list of Information we collect from you in connection with your access and use of the Platform:
i) Account Information:
Information that we need you to provide to enable you to sign-up for the use of the Platform provided by the Company. When you sign-up for an account on the Platform (“User Account”) or while booking appointments for consultation services from Consultants, we require certain information such as your name, phone number, and email address for the purpose of user registration, identification, and account verification, and in the event you intend on using the Platform on behalf of any other person, then the details and information of such other person.
ii) Health and Well-being Information:
In connection with the consultation with the Consultants, you will be providing us and the respective Consultants with the relevant information pertaining to your health conditions and well-being and other information which may include information or records relating to your health status, medical history, information relating to partner or spouse, information pertaining to your family and information relating to your professional life.
iii) Payment Transaction Information:
We may collect your first name, last name, phone number, and billing address when you register for availing the services offered on the Platform. Your payment details are collected through a third-party gateway to which you will be required to provide requisite information separately in order to process your payments. Refer to our Terms of Use for more details on payment processes. Iv)Call Information:
We collect information pertaining to your calls with the Consultants on the Platform. The Platform records when a phone call is initiated with a Consultant on the Platform and stops when the phone call is finished. This information is collected to analyse call quality and to investigate any complaints pertaining to such calls or any offensive behaviour done by any side of the calling parties.

c) Information we automatically collect from your use of the Platform:
When you use the Platform, we automatically collect information, about the functionalities you use on the Platform and how you use them. This information is necessary for the effective performance of the contract between you and us, to enable us to comply with the legal obligations given our legitimate interest in being able to provide and improve the functionalities relating to the Platform and the services. i) Geo-location Information:
When you use certain features of the Platform, we may collect information about your location such as your IP address, which in turn would enable us to infer your city, region/state, country, continent, Internet Service Provider (ISP), longitude/latitude coordinates of the location, type of connection (residential, business, etc.), and name of the organization that owns the connection (i.e. if it is a business connection or not).
ii) Usage Information:
We collect information about your interactions with the Platform such as the pages viewed on the Platform and the User Account dashboard, content created or uploaded through the use of the Platform and services.
iii) Log File and Device Information:
When you use the Platform, we automatically collect and store certain information in server logs. This includes details of how you used the Platform, such as access to your User Account, certain information that your web browser sends whenever you visit any website, internet protocol address, information inferred from your internet protocol address like location, ISP details, device information such as hardware configuration and operating system, browser types, referring / exit pages and URL’s, number of clicks, domain names, landing pages, pages viewed and other such information. We do not link this automatically-collected data to Personally Identifiable Information.
iv) Cookies and Tracking Technologies:
We collect device-specific information (such as your hardware model, operating system version, unique device identifiers). The Company may associate your device identifiers with your User Account. You may decline these cookies by changing your browser settings if permitted. However, do note that this may impact certain features of the Platform or your experience in using the Platform.

d) All the Information provided to the Company by you, including personally identifiable information or any Sensitive Personal Information, is voluntary. You understand that the Company may use certain information of yours as provided in Section 3 below.
e) This Privacy Policy does not apply to, nor do we take any responsibility for any information that is collected by any third party either using the Services or through any third-party links made available to you during your use of the services or through any of the advertisements or through BOTS. Please note that you will be bound by the terms of use and privacy policy(ies) published by third parties in respect of any information that you may provide to them, and the Company expressly disclaims any liability arising from the content available on such third-party websites or applications.

3. HOW WE USE INFORMATION WE COLLECT

We will use the Information collected from you for the following purposes:
(i) To allow you to collaborate and communicate with other Users.
(ii) Ensuring the Services and/or the content on the website is presented in an effective manner for your use.
(iii) To perform our obligations as per your requests and for providing you the services. This includes sharing your Information in strict confidence with the Consultants, as Consultants will need to access your information to provide the Services, subject to the terms of this Privacy Policy.
(iv) To provide you with information pertaining to Services.
(v) To notify you about any changes and improvements to Services and/or website; or analytical purposes, including but not limited to assessing usage data, usage patterns, and other similar activities.
(vi) When you create a User Account, we keep a record of your communication to help solve any issues you might be facing.
(vii) We use information collected from cookies and other tracking technologies to improve your user experience.
(viii) To conduct analysis to ensure that the Services are provided in an efficient manner.
(ix) In any other way that we may describe to you at the time you provide the information.
You hereby acknowledge and agree to the Company using your Information for the foregoing purposes. Except as otherwise provided herein, we will not disclose, publish, sell, rent, market or share with any third party your personal information without your express consent.
Please do not include or provide any personal information unless specifically requested as part of the registration or other applicable processes. If any information you have provided or uploaded violates the terms of this Privacy Policy, Find Your Path may be required to delete such information upon informing you of the same and revoke your access if required without incurring any liability to you.

4. INFORMATION WE SHARE AND DISCLOSE

We share information about you for the following operating and maintaining Services:

(i) To conduct Analytics
We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, and areas for integration and improvement of the Services. We also test and analyze certain new features with some users before rolling the feature out to all users. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other pseudonymized information for compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

(ii) For Customer Support:
We use your information to resolve technical issues you encounter, to respond to your requests for assistance, analyze crash information, and repair and improve the Services.

(iii) For Legal Reasons:
We will also share information including personal information with individuals or entities to the extent it believes in good faith it is required to:
(a) ensure compliance with law/ regulations and/or pursuant to enforceable orders of government, law enforcement, or regulatory authorities;
(b) address fraud, security, or technical issues;
(c) protect against harm to the rights, property, or safety of the Product, its other users, or the public as required or permitted by law.

(iv) For Effective Provision of Services:
We may share your personal information with our employees, contractors, and agents or to our affiliates (and their employees, contractors, and agents) who need to know the information in order to provide services to you and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

5. HOW WE STORE AND PROTECT YOUR INFORMATION

The Information that you provide, subject to disclosure in accordance with this Privacy Policy, shall be maintained in a safe and secure manner. Find Your Path databases and information are stored on secure servers with appropriate firewalls.
Find Your Path uses industry-standard physical, technical, and administrative security measures in accordance with all security standards required under applicable law to safeguard and keep secure your Information. We conduct periodic reviews of our security measures pertaining to our information collection, storage, to guard against unauthorized access to systems.
Given the nature of internet transactions, Find Your Path does not take any responsibility for the transmission of information including User Information shared by you. Any transmission of User Information on the internet is done at your risk and Find Your Path shall not be responsible for the circumvention of the privacy settings or security measures either by you or any third party.
When you enter User information (such as log in credentials) in respect of your user account (“User Information”) or when you upload any information through the use of the Platform, we take reasonable efforts to ensure that your user information and all other information submitted by you is safe and secure; however, the Company makes no representation, warranties or other assurances that the security measures are adequate, safe, full proof or impenetrable.
As a User of the Services, you have the responsibility to ensure data security. You should use the Services responsibly and not share your User Information including your username or password or account information with any person. Do remember that you are solely responsible for all acts done under the account registered to you.

6. YOUR RIGHTS

(i) Data Retention and Data Deletion (a) Request for Deletion
If you no longer want to use our Services and want your User Account/personal information to be deleted, you may contact us at [email protected] to request that your User Account be deleted. Your User Account and all your personal information will be deleted within a period of sixty (60) days from the date on which you request deletion thereof.
(b) Deletion on Account of Non-Use In the event you do not use/ access the Services or your User Account for a period of twelve (12) months, we will delete your User Account and all your personal information. If you wish to avail of the Services once your User Account is deleted pursuant to non-use or pursuant to your request, you will have to sign-up as a new User.

(ii) Rectification of Inaccurate or Incomplete Information
You can change, alter, modify your Account Information (including User Information) at any time by emailing us at [email protected]. However, please note that in the event you alter, or update or delete your account information, we cannot ensure the continuity or quality of the services being provided to you.
Find Your Path may permit or deny modification of any Information, to the extent such information is required by it in order to be compliant with and observe applicable laws. You have the right to ask us to correct inaccurate or incomplete personal information concerning you (which you cannot update yourself using your User Account).

(iii) Data Portability Data portability is the ability to obtain some of your information in a format you can move from one service provider to another. Depending on the context, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

(iv) Withdrawing Consent and Restriction of Collecting Data. Where you have provided your consent to the collecting of your personal information by Find Your Path, you may withdraw your consent at any time by sending a communication to Find Your Path at [email protected] specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. However, please note that in the event you withdraw your consent, we cannot ensure the continuity or quality of the Services being provided to you.

(v) Complaints If you wish to place a complaint with regard to privacy requirements or laws, access any of your Information or would like to update or correct any errors in your User Information or if you have any questions about this Privacy Policy or Find Your Path handling practices, you may send email to [email protected].

(vi) RESTRICTIONS The Services are only intended for Users who are of 18 (Eighteen) years of age or older. If you are not of the requisite age you are not to provide any user information or other information. Find Your Path shall have the right to revoke the provision of Services and delete accounts of Users below the age of 18 without notice.

(vii) AMENDMENTS This Privacy Policy is subject to change from time to time. If we make changes to this Privacy Policy, we will update the “Last Updated” date at the top of this Privacy Policy column. If you disagree with the revised Privacy Policy, you may delete your User Account.

(viii) TERMS OF USE This Privacy Policy shall form a part and shall be read in conjunction with the Terms of Use that you may enter into with Find Your Path in respect of Services. All capitalized terms used in this Privacy Policy, unless otherwise defined, shall have the meaning set forth in the Terms of Use.