Anosales (referred to as “Anosales” “we” “our” “us”) is committed to protecting and respecting the privacy of its Customers/ Clients (jointly & separately referred to as “You” or “you”) by maintaining the confidentiality of your Personal Data. Anosales’ Privacy Policy (hereinafter referred to as “Policy”) is in compliance with the General Data Protection Regulation (GDPR), EU-US Privacy Shield Framework, the Swiss-U.S. Privacy Shield Framework and other applicable laws of India, USA and UK [collectively referred to as “Data Protection Laws”]. We encourage you to review this Policy carefully as by using the Anosales community, you provide consent to this Policy and the practices followed by us.

1. GENERAL

  • Scope: This Privacy Shield Policy sets forth the Privacy principles that Anosales follows with respect to transfers of Personal Data between member states of the European Union, Iceland, Liechtenstein and Norway (the European Economic Area or EEA), Switzerland and the United States. Anosales is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
  • This Policy applies to all the services, websites, portals and Apps (hereinafter referred to as “Services” in this policy) offered by Anosales, except where otherwise noted.
  • Your privacy is important to us, therefore, we take the protection of your Personal Data very seriously
  • 2. PURPOSE

    Everyone expects their Personal Data to remain confidential. This includes anything that can identify them—name, work and home address, family information, employment or financial details, or more sensitive health information. We strongly condemn the disclosure of any information that could lead to any form of discrimination, as well as the use of identifiable genetic data without informed consent.

    We adhere to all privacy laws and enforce clear policies on protecting Personal Data, including genetic data. Our data privacy program includes a global organisation and infrastructure as well as procedures and trainings to support local activities and ensure compliance, Anosales has a system of principles, rules and tools to ensure effective levels of data protection, in particular relating to transfers of Personal Data outside Europe and Switzerland.

    The purpose of this Policy is to provide consistent standards to ensure that your Personal Data which is under the custody of Anosales remains protected. All your Personal Data is treated with complete confidentiality and IS NOT shared with anyone who does not have the right to access.

    3. DEFINITIONS

    We maintain adequate documentation for all the processing activities in electronic form which includes :

    3.1 Processing: Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

    3.2 Personal Data: It means any of your information including but not limited to:

  • name, mailing address, personal number, date of birth, family information, email ID;
  • educational, financial, criminal or employment history;
  • race, national or ethnic origin, colour or religious beliefs or associations; and
  • sensitive health information
  • Personal Data can be recorded in any format, including books, documents, letters, vouchers, papers, forms and any other thing on which Personal Data is recorded or stored by graphic, electronic, mechanical or other means.

    3.3 You: You/you means:

  • any data subject who has received a request to share their Personal Data with Anosales; or
  • any data subject who has signed up and agreed to use the Services of Anosales; or
  • any data subject who is visiting one of our websites because they are Curious!
  • 4. PROTECTION OF YOUR PERSONAL DATA

    The following Rules or Principles shall apply:

    4.1 Your Personal Data shall be processed fairly and lawfully;

    4.2 Your Personal Data shall be obtained only for specified and lawful purposes, and must not be processed in a manner which is incompatible with those purposes;

    4.3 Your Personal Data must be adequate, relevant and not excessive in relation to the purposes for which it is processed;

    4.4 You must, as and when requested, review your Personal Data and ensure that your Personal Data is accurate and, where necessary, keep it up to date;

    4.5 Your Personal Data processed for any purpose shall not be kept for longer than is necessary or is otherwise required under any other law for the time being in force;

    4.6 Appropriate measures shall be taken against unauthorised or unlawful processing of your Personal Data and against accidental loss or destruction of, or damage to, or theft of, Personal Data; and

    4.7 Your Personal Data shall not be transferred to a third party unless the transferee entity ensures the same level of protection of Personal Data that is adhered to by Anosales. Personal Data shall be transferred only if it is necessary for the performance of a lawful contract between Anosales and the transferee entity, subject to your prior permission.

    5. COLLECTION & USE OF PERSONAL DATA

    Generally, we only process your Personal Data as described in this Policy. However, we reserve the right, to conduct additional processing to the extent permitted or required by law, or in support of any legal or criminal investigation.

    Your Personal Data collected & processed by us is limited to what is required in order to fulfil the required purposes. Most of our Services do not require any form of registration and allows you to visit our website without telling us who you are. However, some services may require you to provide us with Personal Data. In these situations, if you choose to withhold any Personal Data requested by us, it may not be possible for you to gain access to certain parts of the website and for us to respond to your query.

    We may also collect and use Personal Data to provide you with products or services, to bill you for products and services you request, to market products and services which we think may be of interest to you, or to communicate with you for other purposes which are evident from the circumstances or about which we inform you when we collect Personal Data from you.

    6. NON-DISLOSURE OF PERSONAL DATA

    We do not sell, share, or otherwise distribute your Personal Data to third parties except as provided in this Privacy Policy. However, we may disclose your Personal Data to other affiliates of Anosales worldwide that agree to treat it in accordance with this Privacy Policy. Personal Data may also be transferred to third parties who act for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed, such as services delivery, evaluating the usefulness of this website, marketing, data management or technical support. These third parties have contracted with us to only use Personal Data for the agreed upon purpose, and not to sell your Personal Data to third parties, and not to disclose it to third parties except as may be required by law, as permitted by us or as stated in this Privacy Policy. Even before sharing your Personal Data with any third party, your prior consent will be obtained.

    Personal Data collected from you may also be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat Personal Data in accordance with this Privacy Policy.

    Please note that all your Personal Data remains protected with us. However, we may need to disclose your Personal Data when we believe such disclosure is required in good faith and necessary to comply with judicial proceeding, court order, legal process or when needed to investigate, act against any illegal, suspected or fraudulent activity.

    7. Data Protection Compliances

    7.1 High Level Security Policy Anosales recognizes and places strong emphasis on your service & satisfaction, by ensuring that all the procedures, Personal Data & data management systems conform to the legal requirements. To ensure the security and confidentiality of Personal Data that we collect online, we use data networks protected, by industry standard firewall and password protection. In the course of handling your Personal Data, we take measures reasonably designed to protect that Personal Data from loss, misuse, unauthorised access, disclosure, alteration or destruction.

    7.2 Data Transfer Abroad Anosales has its clients globally and transfers databases in different countries. However, Anosales has adopted Binding Corporate Rules, a system of principles, rules and tools, provided by European law, in an effort to ensure effective levels of data protection, in particular relating to transfers of Personal Data outside the EEA and Switzerland.

    7.3 Accountability for Onward Transfer The EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework allows the transfer of Personal Data to a third party, who acts as a service provider or a vendor, if certain steps are taken to assure privacy and security protections. Under these circumstances, we will take all reasonable steps to require any third-party recipient to protect your Personal Data relevant to the Privacy Shield Framework. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, Anosales is potentially liable.

    8. YOUR RIGHTS

    You have certain legal rights to obtain information about whether we hold Personal Data about you, to access Personal Data we hold about you, and to obtain its correction, update, amendment or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations. Your Principal rights under data protection laws are as follows:

    8.1 Right to access, rectify or delete the Personal Data:
    You have the right to request from Anosales to access, rectify or delete your Personal Data stored with Anosales. You can ask us to verify whether we are processing Personal Data about you. You can ask us to rectify our records if you believe that it contain incorrect or incomplete information about you. Lastly, You can ask us to delete your Personal Data if you withdraw your consent or when Anosales no longer need it for the purpose it was originally collected for.

    8.2 Right to erasure
    You have the right to erase/ delete your Personal Data without undue delay in circumstances where:
    i) Personal Data is no longer necessary in relation to the purpose for which it was collected or processed;
    ii) you withdraw consent on which processing is based;
    iii) you object to the processing under certain data protection rules; and
    iv) Personal Data has to be erased for compliance with a legal obligation.
    Please note that there are certain exclusions of the right to erasure. Such exclusions include where processing is necessary:
    i) for exercising the right of freedom of expression and information;
    ii) for compliance with a legal obligation; or
    iii) for the establishment, exercise or defence of legal claims.
    How to delete your Personal Data:
    You can delete your Personal Data by sending your request at privacy@anosales.net.

    8.3 Right to restrict and object to processing
    Restrict Processing:
    You have the right to restrict processing of your Personal Data in circumstances where you:
    i) contest the accuracy of your Personal Data;
    ii) prefer to restrict its use rather than having us erase it;
    iii) believe we no longer need the Personal Data for the purpose of processing, but you require Personal Data for establishment, exercise or defence of legal claims;
    iv) have objected to processing, pending the verification of that objection.
    Please note that Anosales will duly inform you before lifting the restriction of processing.
    Objection to Processing:
    You have the right to object to processing of your Personal Data on grounds pertaining to the particular situation, but only to the extent that the processing is necessary for:
    i) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or ii) the purposes of the legitimate interests pursued by us or by a third party.
    If you make such an objection, we will cease to process the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is for the establishment, exercise or defence of legal claims.
    How to restrict and object to processing:
    You can restrict and object to processing of your Personal Data by sending your queries at privacy@anosales.net.

    8.4 Right to object to processing for direct marketing purpose:
    You have the right to object to our processing of your Personal Data for direct marketing purposes including profiling. If you make such an objection, then we will cease to process your Personal Data for this purpose.
    How to make an objection:

    You can object to processing by sending your objections at privacy@anosales.net.

    8.5 Right to object for scientific or historical research purposes or statistical purposes:
    You have the right to object to our processing of your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
    How to make an objection:
    You can object to processing by sending your objections at privacy@anosales.net.

    8.6 Right to data portability: Where you have provided Personal Data to us, you can ask us to transmit that Personal Data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.

    8.7 Right to withdraw consent
    You can withdraw your consent from sharing your Personal Data with Anosales anytime. Withdrawal of consent will not affect the lawfulness of any processing carried out before you withdraw your consent.
    You can withdraw your consent by sending your request at privacy@anosales.net.
    Anosales will retain your Personal Data for the establishment, exercise or defence of legal claim. Even after you withdraw your consent, Anosales will continue to protect such Personal Data in accordance with this Policy.

    8.8 Right to complaint to Grievance Officer
    If you are of the opinion that there is any infringement of your Personal Data at our end, then you have a legal right to lodge a complaint with the Grievance Officer responsible for protection of Personal Data. The Grievance Officer responsible for protection of your Personal Data is:

    Girish Misal
    CEO,
    Anosales, LLC 1 Radisson Plaza, Suite 800, New Rochelle,
    New York 10801
    Contact no.: (845) 915-4660
    Email: privacy@anosales.net

    9. COMPLIANCE WITH EU-US PRIVACY SHIELD FRAMEWORK AND SWISS- U.S. PRIVACY SHIELD FRAMEWORK

    As set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. Anosales has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ or https://www.commerce.gov/tags/eu-us-privacy-shield (U.S. Department of Commerce’s Privacy Shield).

    10. COOKIES

    We may collect and process information about your visit to our website, such as the pages you visit, the website you came from and some of the searches you perform. Such information is used by us to help improve the contents of the site and to compile aggregate statistics about you using our site for internal, market research purposes. In doing this, we may install “cookies” that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. A “cookie” is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a “cookie,” this will enable you to decide if you want to accept it or not. If you do not want us to install cookies, please email us at privacy@anosales.net. We would like to inform you, however, that if you do not accept you may not be able to use all functionality of your browser software. We may obtain the services of outside parties to assist us in collecting and processing the information described in this Section.

    Occasionally, we may use internet tags (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) and cookies at this site and may deploy these tags/cookies through a third-party advertising partner or a web analytical service partner which may be located and store the respective information (including your IP-address) in a foreign country. These tags/cookies are placed on both online advertisements that bring users to this site and on different pages of this site. We use this technology to measure the visitors’ responses to our sites and the effectiveness of our advertising campaigns (including how many times a page is opened and which information is consulted) as well as to evaluate your use of this website. The third-party partner or the web analytical service partner may be able to collect data about visitors to our and other sites because of these internet tags/cookies, may compose reports regarding the website’s activity for us and may provide further services which are related to the use of the website and the internet. They may provide such information to other parties if there is a legal requirement that they do so, or if they hire the other parties to process information on their behalf. If you would like more information about web tags and cookies associated with on-line advertising or to opt-out of third-party collection of this information, please visit the Network Advertising Initiative website http://www.networkadvertising.org (link is external).

    11. GOOGLE ANAYTICS

    We use Google Analytics to rationalize our portfolio of websites by (i) optimizing traffic to and between corporate websites, and (ii) integrating and optimizing web pages where appropriate “Google Analytics” is a service offered by Google Inc. “Google” that generates detailed statistics about a website’s traffic and traffic sources and measures conversions and sales. Google Analytics uses “cookies” stored on your computer to help analyze how users use our website.

    The information generated by the cookies about your use of our website, including your IP address, will be anonymized by use of the appropriate settings (“_anonymizelp()” function or equivalent) and transmitted to Google servers in the United States. For more information on how IP anonymization works please see https://support.google.com/analytics/answer/2763052 (link is external) On behalf of us, Google will use the information generated by the cookies for the purpose of evaluating the use of our website, compiling reports on website activity providing us with these reports for analytical purposes.

    Google may transfer this information to third parties in case of a statutory obligation or if a third party processes data on behalf of Google. Under no circumstances, Google will combine or associate your IP address with other data stored at Google. You may prevent or stop the installation and storage of cookies by you browser settings by downloading and installing the free Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout?hl=en (link is external). We inform you that in such case you will not be able to wholly use all functions of our website.

    By using our website, you consent to the processing of any personal data Google will collect on you in the way and for the purpose as described above.

    12. PERSONAL DATA & CHILDREN

    Most of the services available on this site are intended for persons 18 years of age and older. We will not knowingly collect, use or disclose Personal Data from a minor under the age of 18, without obtaining prior consent from a person with parental responsibility (e.g., a parent or guardian) through direct off-line contact. We will provide the parent with
    i) notice of the specific types of Personal Data being collected from the minor, and ii) the opportunity to object to any further collection, use, or storage of such information. We abide by laws designed to protect children.

    13. PERSONAL DATA SHARED BY YOU ON THIRD PARTY WEBPAGE

    Anosales does not control or take any responsibility for the confidentiality of Personal Data shared by you on third party website or web page. We may provide links to other websites which we believe may be of interest to our visitors. We aim to ensure that such websites are of the highest standard. However, due to the nature of the internet, we cannot guarantee the privacy standards of websites to which we link or be responsible for the contents of sites other than this one, and this Privacy Policy is not intended to be applicable to any linked, non-Anosales site. Please always review and share your Personal Data if you consent to their terms and usage of your Personal Data by them.

    14. PRIVACY CONCERNS

    Anosales commits to resolve complaints about our collection or use of your Personal Data. If you have any questions or comments about the privacy of your Personal Data or about this Policy or how we handle your Personal Data, you could direct your correspondence to:
    Girish Misal
    CEO,
    Anosales, LLC 1 Radisson Plaza, Suite 800, New Rochelle,
    New York 10801
    Contact no.: (845) 915-4660
    Email: privacy@anosales.net

    Please note that, we respond within 30 days from the date we receive privacy related communications.

    Anosales has further committed to refer unresolved Privacy Shield complaints to EU Data Protection Authorities (DPAs), and the Swiss Federal Data Protection and Information Commissioner (FDIPIC). If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm for more information or to file a complaint. The services of dispute resolution are provided at no cost to you.

    Anosales commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

    15. VERIFICATION OF ENFORCEMENT

    Anosales uses a self-assessment approach to assure compliance with this Policy and periodically verifies that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons/ you to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Data in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider. It is possible, under certain conditions, for an individual to invoke binding arbitration.

    16. CONFIDENTIALITY

    You must maintain confidentiality, and not disclose to any other person, any information and content that you access or learn in connection with your access to our Services. You are prohibited from sharing with any third party, photographic or other imagery, information, or any other content from any and all activities within or from the Site. You must not use any such information or content for any purpose other than your participation in the Services in accordance with this Agreement. You hereby agree to notify Anosales immediately if you learn of or suspect any use or disclosure of, or access to, any such information or content other than as specifically authorized in this agreement.

    By agreeing to the above-mentioned, You accept this Policy as mentioned on this website. Anosales reserves the right to make changes to this Policy. We encourage you to periodically review this Policy. Your continued participation in Anosales after any revisions to this Policy constitutes your acceptance of this Policy, as amended, modified or updated.

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