Privacy Policy

Introduction

ElpeeCo. (collectively, “we,” or “us”) are a legal and regulatory consulting firm dedicated to providing high-quality legal and compliance services, while ensuring the privacy and security of personal data related to our clients, staff, agents, lawyers, law students, job applicants, and other third parties (collectively referred as “you” or “your”). We recognize the increasing importance of safeguarding both privacy and digital infrastructure that supports our operations. As such, we are committed to upholding the highest standards of Information and Cyber Security.

This Privacy Policy (“Policy”) is a part of our Information & Cyber Security Framework (“Framework”), established in accordance with the Information Technology Act, 2000 (“IT Act”), the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“SPDI Rules”), the Information Technology (Guidelines for Intermediaries and Digital Media Ethics Code Rules, 2021), and the Digital Personal Data Protection Act, 2023 and Rules framed thereunder.

The Policy, being a part of the bigger Framework is constituted to ensure that our practices comply with legal obligations while mitigating risks to both personal data and organizational assets.

We may occasionally update this Framework and encourage you to periodically review our website to be updated on our practices in this regard.

Preamble

We are committed to safeguarding and respecting your privacy. As a data controller, we process personal data in compliance with the applicable laws. This Privacy Policy details our practices regarding the collection, use, and processing of your Personal Data, which may be accessed by us or shared with us when you interact with our services or visit our website at https://www.elpee.co.in (“Platform”).

Scope and Applicability

1. This Privacy Policy applies to any person or entity that accesses the Platform or shares Personal Data with us, including data related to an identified or identifiable natural person.
2. The collection and processing of information in connection with the services we provide, or any other contractual or commercial engagement, shall be governed by the specific terms applicable to those engagements and not by this Privacy Policy. This Privacy Policy governs the handling, storage, usage, and disclosure of Personal Data and outlines the choices available to you regarding your Personal Data, including how you can access and update it.
3. We may modify this Privacy Policy from time to time, and your continued interaction with the Firm after any changes shall be deemed as your acceptance of the updated policy. If you disagree with any part of this Privacy Policy, you are advised not to provide us with your information.
4. If you are interacting with the Firm from a place outside the territorial jurisdiction of India, you do so at your own risk and are responsible for compliance with any applicable local laws of that your territorial jurisdiction.
5. By continuing to interacting with the Firm or use the Platform, you agree to be bound by this Privacy Policy, as well as the Platform’s Terms of Use (Annexure 1) and any other applicable legal agreements.
6. In case of any disputes related to this Privacy Policy, the laws of India shall apply, with exclusive jurisdiction resting with the competent courts in Mumbai, Maharashtra.

Objectives

The objectives of ElpeeCo. through this Policy and the Framework are as under:

1. To ensure compliance with the relevant legal and regulatory requirements concerning data privacy, information security, and cyber security, including the IT Act, SPDI Rules, Digital Personal Data Protection Act, and other applicable laws, as amended from time to time;
2. To safeguard personal and sensitive data of our clients, Employees, agents, job applicants, law students, and other third parties, minimizing the risk of unauthorized access, loss, alteration, or disclosure;
3. To establish a robust information security posture that protects the assets, intellectual property, and confidential data of the Firm from cyber threats, data breaches, and other potential security incidents;
4. To foster a culture of privacy awareness and cyber security among staff, lawyers, and other stakeholders, ensuring that they understand and comply with relevant policies and procedures;
5. To define clear guidelines for the collection, storage, processing, and sharing of personal and sensitive data, ensuring that all practices adhere to legal requirements and industry best practices;
6. To implement proactive measures for risk assessment, vulnerability management, and incident response, ensuring swift and effective action in case of security incidents or breaches;
7. To continuously monitor, audit, and review the information security and privacy practices of the Firm to adapt to evolving cyber threats, technological advancements, and changes in legal framework;
8. To provide a framework for addressing any third-party risks, including the security and privacy practices of vendors, partners, or other external entities with access to the data of the Firm;
9. To promote transparency and accountability in how we handle personal and sensitive data, ensuring that stakeholders are informed about their rights, obligations, and protections under the firm’s policies.

Definitions

The following terms for purpose of this policy shall carry the meaning as provided hereunder:

Methods of Collecting Personal Data

1. We collect Personal Data through various means as part of our professional services, agreements, and interactions with clients, staff, law students, and other stakeholders. The data we gather may include personal information related to an identified or identifiable individual. This information may be provided directly by individuals or collected through various interactions and other communication channels.
2. We may collect technical data, including IP addresses, browser types, website usage information, device details, and data gathered through third-party applications that use Cookies and other online technologies.
3. We may collect client-specific data, including information provided by our clients or generated during the course of delivering legal services. Additionally, in the context of recruitment, we may collect resumes, professional qualifications, work history, and other related information. We also gather data from individuals attending events, meetings, or webinars hosted by us. This Personal Data is collected directly through documentation or indirectly through our interactions on the Platform.
4. The processing of Personal Data is always aligned with the purpose of fulfilling our professional and legal obligations. This may inter-alia include providing legal services, complying with applicable laws and regulations, managing business development, handling recruitment processes, improving the functionality and security of our website, statistical analysis and risk Management.
5. Data processing is carried out based on consent, performance of a contract, legal compliance, or legitimate interests relevant to our operations as a law firm.

Purposes for the Collection and Use of Personal Data

1. We use Personal Data in accordance with applicable laws and for legitimate business purposes.
2. We use Personal Data inter-alia for the following purposes:
   • To engage with individuals and deliver our legal services;
   • To manage relationships, including notifying about changes to services or agreements;
   • To enhance and customize the Platform for relevance and ease of use;
   • To conduct compliance checks, as required by law;
   • To manage and safeguard our business operations, including troubleshooting and system testing;
   • To analyze trends and improve the platform and services;
   • To fulfill contractual obligations and manage recruitment processes, including job applications and internships;
   • To facilitate marketing and business development activities such as invitations to seminars, webinars, and legal briefings;
   • To comply with legal obligations, respond to court orders, and defend against legal claims;
   • To perform due diligence and background checks as part of client engagement;
   • To detect and prevent fraud, money laundering, and other unlawful activities;
   • To respond to cybersecurity incidents and ensure data protection;
   • To monitor compliance with laws and regulations relevant to our operations.
3. Where applicable laws allow, we process Personal Data based on consent, the necessity of performing a contract, compliance with legal obligations, or our legitimate business interests. Specifically, these include:
   • The legitimate interest in conducting and managing business to provide services and enhance security;
   • The performance of a contract when necessary for providing services or taking pre-contractual steps;
   • The necessity of processing Personal Data to comply with legal obligations.
4. Any change in the purpose of processing shall be communicated, and individuals shall be notified if the use diverges from the original intent.
5. Individuals have the right to opt out of communications, including updates and invitations, by contacting us at our designated email address Elpeeco@elpee.co.in.
6. If interactions with us occur via social media platforms like LinkedIn, the terms of service and privacy policies of those platforms shall apply.
7. Processing Personal Data related to Platform usage and business development activities is based on our legitimate interest in operating and improving our services, providing relevant legal updates, and strengthening our client relationships.

Sharing of Personal Data

1. You acknowledge and agree that we may share your Personal Data with third parties, in accordance with applicable laws and your consent wherever necessary. Such third parties may include:
   • Agents, contractors, or service providers of ours, who process your data on behalf of ElpeeCo.;
   • Service Providers or third parties who collect and process your Personal Data for purposes consistent with the ones outlined in this Privacy Policy;
   • Regulatory authority to the extent required under applicable laws or to provide our services.
2. Except any regulatory authority, we require all third parties with access to your Personal Data to uphold its security and comply with legal requirements. These third parties are prohibited from using your data for their own purposes and are only permitted to process it for specific purposes based on our instructions.
3. We may disclose your Personal Data when required by law or by order of a court, government agency, or other authority. Such disclosures shall be made in good faith, believing it is necessary to comply with legal obligations, enforce this policy, or protect legal rights.
4. Your Personal Data may be disclosed in response to legal obligations, such as:
   • Conforming to legal requirements or processes;
   • Protecting our rights or property;
   • Preventing crime or safeguarding national security;
   • Protecting the personal safety of users or the public.
5. We may also share aggregated information about you with our team, other platform users, and third parties for the purpose of improving the Platform’s features and services.

Your Rights Regarding Your Personal Data

As a data subject, you are entitled to legal rights under applicable data protection laws. For the purpose of this Privacy Policy, you may:

1. request information about the Personal Data we hold concerning you;
2. request that any inaccurate or incomplete Personal Data about you be corrected or updated;
3. request the erasure of your Personal Data where there is no legitimate reason for us to continue processing it;
4. withdraw your consent for processing your Personal Data, where applicable;
5. object to or request restrictions on the processing of your Personal Data under specific circumstances;
6. request the transfer of your Personal Data to another organization in a structured, commonly used, and machine-readable format;
7. object to profiling based on your Personal Data;
8. lodge a complaint with a supervisory authority if you believe your rights have been violated.

If you wish to exercise any of these rights, please contact ElpeeCo. at:
Email: Elpeeco@elpee.co.in

Security of Your Personal Data

1. We implement appropriate technical and organizational measures to protect your Personal Data from loss, misuse, destruction, alteration, or unauthorized access.
2. We have established security protocols to prevent unauthorized access, accidental loss, or disclosure of your Personal Data. We also have procedures in place to respond to any actual or suspected data breaches, and where required by law, we shall notify you and the relevant regulatory authorities.
3. We have implemented appropriate security and confidentiality obligations in the non-disclosure agreements (NDAs) with Employees/staff contractual agencies/consultants/advisors and other personnel handling Personal Data.
4. We have adopted physical, technical, and procedural safeguards to secure your Personal Data from risks such as loss, misuse, alteration, or unauthorized access. Specific security measures include:
   • Regular reviews of our information collection, storage, and processing practices, including physical security, to prevent unauthorized access to our systems.
   • Restricting access to your Personal Data to Employees, staff, agents, and service providers who need it to process your data on our behalf. These individuals are bound by strict confidentiality agreements, and failure to comply may result in disciplinary action or termination of their relationship with us.
5. We shall not be responsible for any security breaches caused by third parties or events beyond our reasonable control, including acts of government, hacking, unauthorized access, data storage device breaches, or failures in encryption or security measures.
6. Only authorized individuals are allowed to access authentication application, audit logs, authentication servers, application, source code, information security infrastructure. An access control list is maintained and regularly updated by ElpeeCo.

Data Retention and Destruction

1. We retain your Personal Data only for as long as necessary to fulfil delivery of our services and the purposes for which it was collected, including meeting any legal, regulatory, or reporting requirements. If a complaint is lodged or if we reasonably anticipate litigation regarding our relationship with you, we may retain your data for a longer period.
2. Once the retention period for each category of Personal Data has ended, we shall delete or destroy your data or anonymize it to ensure it no longer qualifies as Personal Data, where technically feasible.
3. We ensure that your Personal Data in our possession or control is either destroyed or anonymized within five years, assuming that:
   • The purpose for which the Personal Data was collected is no longer being served.
   • Retention is no longer necessary for any other reason, including legal or regulatory obligations.
4. The authentication transaction logs shall be stored for a period of two years subsequent to which the logs shall be archived for a period of five years or as per the regulations governing the entity, whichever is later. Upon expiry of such period, barring the authentication transaction logs required to be maintained by a court order or pending dispute, the authentication transaction logs shall be deleted.
5. Please note that withdrawing consent for the use of your Personal Data may result in our inability to provide you our services or lead to the termination of any existing relationship we may have with you.

Indemnification

You agree to indemnify and hold us harmless from any claims or disputes brought by third parties arising from the information you disclose to us, either through our Platform or otherwise, and from your use or access of third-party websites, applications, and resources. We take no responsibility for any actions of third parties regarding your Personal Data or information that you may have shared with them.

Grievance Officer and Contact Information

If you wish to report a security breach, face any unresolved issues, or need assistance regarding the website and privacy policy, please contact our Grievance Officer at:

Grievance Officer
C-1219, ONE BKC, Plot no. C-66, G-Block,
Bandra Kurla Complex, Bandra (East), Mumbai – 400 051

Email: Elpeeco@elpee.co.in

Review of the Framework

We shall conduct a comprehensive review of the Privacy Policy along with the Information & Cyber Security Framework on an annual basis or as may be required, to ensure its continued effectiveness, relevance, and alignment with evolving legal, regulatory, and technological developments.

Annexure 1 – Terms of Use for Website of ElpeeCo.

1. Introduction

1. By accessing or using the website of ElpeeCo. (“Platform”), you agree to comply with and be bound by these Terms of Use, along with our Privacy Policy, which governs the collection, use, and processing of Personal Data. If you do not agree to these terms, you should not use the Platform.
2. These Terms of Use apply to any person or entity that accesses the Platform or interacts with our services. You may use the Platform only in accordance with these Terms of Use and the applicable laws.

2. Use of the Platform

You may access and use the Platform for lawful purposes only. You agree not to use the Platform to:

1. Violate any applicable local, national, or international laws or regulations.
2. Infringe upon the intellectual property rights of ElpeeCo. or any third parties.
3. Post or transmit any content that is offensive, illegal, defamatory, abusive, obscene, or harmful.

You agree to use the Platform in a manner that does not disrupt, interfere with, or degrade the quality of the Platform’s performance or accessibility, including but not limited to actions such as distributing malicious software or viruses.

3. Intellectual Property

1. All content on the Platform, including but not limited to text, graphics, logos, images, and software, is the property of ElpeeCo. or its licensors and is protected by copyright, trademark, and other intellectual property laws.
2. You may not copy, reproduce, distribute, or otherwise use any content from the Platform without the prior written consent of ElpeeCo.

4. User-Generated Content

1. You may be able to submit content (including comments, feedback, or other materials) to the Platform. By submitting content, you grant ElpeeCo. a non-exclusive, worldwide, royalty-free, transferable license to use, reproduce, distribute, and modify such content for any purpose.
2. You represent and warrant that any content you submit does not infringe upon the rights of third parties and complies with applicable laws.

5. Privacy and Data Protection

Your use of the Platform is also governed by our Privacy Policy, which details how we collect, use, and protect your personal data. By using the Platform, you consent to the collection and processing of your personal data as described in the Privacy Policy.

6. No Legal Advice

1. The content provided on the Platform, including legal information, is for general informational purposes only and does not constitute legal advice. By using the Platform, you acknowledge that you should seek professional legal counsel before acting on any legal matters.
2. ElpeeCo. is a law firm, and the services provided through the Platform do not create an attorney-client relationship unless expressly agreed upon in writing.

7. Disclaimer of Warranties

1. The Platform is provided “as is” and “as available” without any warranties of any kind, either express or implied. ElpeeCo. makes no representations or warranties regarding the accuracy, reliability, or completeness of the content on the Platform.
2. ElpeeCo. does not warrant that the Platform will be uninterrupted, error-free, or free from viruses or other harmful components. You are responsible for ensuring that your device has appropriate safeguards in place to protect against such risks.

8. Limitation of Liability

To the fullest extent permitted by law, ElpeeCo. shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages arising from your use of the Platform, including but not limited to any loss of data, loss of profits, or interruption of business.

9. Indemnity

You agree to indemnify and hold harmless ElpeeCo., its management, employees, staff, and affiliates, from any claims, damages, losses, liabilities, or expenses (including legal fees) arising from your use of the Platform or your violation of these Terms of Use.

10. Termination

ElpeeCo. reserves the right to suspend or terminate your access to the Platform at any time and for any reason, including but not limited to violation of these Terms of Use.

11. Changes to the Terms of Use

ElpeeCo. may update or modify these Terms of Use at any time without prior notice. Any changes will be posted on this page, and your continued use of the Platform constitutes acceptance of the modified Terms of Use.

12. Governing Law

These Terms of Use shall be governed by and construed in accordance with the laws of India. Any disputes related to these Terms of Use shall be subject to the exclusive jurisdiction of the courts in Mumbai, Maharashtra.

13. Contact Information

If you have any questions or concerns regarding these Terms of Use, please contact us at:

Email: Elpeeco@elpee.co.in

Website: https://www.elpee.co.in

By using the Platform, you acknowledge that you have read, understood, and agree to these Terms of Use.