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Section: 1. Introduction

Privacy Policy

Last Updated: May 17, 2025

1. Introduction

1.1 Overview of the Policy

This Privacy Policy ("Policy") is issued by FileSure India Private Limited, a company duly incorporated under the Companies Act, 2013, bearing Corporate Identification Number (CIN) U62013MH2023PTC411571, having its registered office at Sambhaji Nagar No2, St. Antony Road, Chembur, Mumbai, Maharashtra 400071, India (hereinafter referred to as "Filesure", "we", "us", or "our"). Our corporate office is located at 6th Floor, Rahimtoola House, Homji Street, Near Horniman Circle, Fort, Mumbai, Maharashtra - 400001.

Filesure acknowledges and respects the importance of safeguarding your privacy and is committed to protecting the confidentiality, integrity, and security of all personal data collected from individuals ("you" or "your") in connection with your use of our website, mobile applications, and other online or offline services (collectively, the "Services").

To Communicate with You: We may use your information to respond to your inquiries, provide customer service support, send you important information about the services, and send you marketing communications (with your consent) via different channels, including but not limited to SMS, Email, WhatsApp, and Voice. This Privacy Policy provides details about how we collect, use, disclose, and safeguard your information when you access our services.

1.2 Effective Date

This Privacy Policy shall come into effect on 17 May 2025 ("Effective Date"). Filesure reserves the right to modify, amend, or update this Policy at any time in accordance with applicable laws and regulations. Any such changes shall be effective immediately upon posting the revised Policy on the Filesure website or through other appropriate communication channels.

1.3 Definitions

For the purposes of this Privacy Policy, key terms include:

  • Personal Data: means any information relating to an identified or identifiable natural person, as defined under the Digital Personal Data Protection Act, 2023, including but not limited to name, contact details, identification numbers, IP address, and any other information that can be used to directly or indirectly identify an individual.
  • Sensitive Personal Data: refers to personal data that relates to financial information, health data, sexual orientation, biometric data, or any other category of data deemed sensitive under applicable laws.
  • Data Fiduciary: means FileSure India Private Limited, the entity that determines the purpose and means of processing Personal Data in relation to the Services provided.
  • Data Principal: means the individual to whom the Personal Data relates and who can be identified, directly or indirectly, from such data.
  • Processing: refers to any operation or set of operations performed on Personal Data, including collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, or erasure.
  • Services: refers to the website, mobile applications, and any other online or offline platforms or services provided by Filesure that collect or process Personal Data.
  • Cookies: means small text files placed on a user's device by websites to store information to enhance user experience and enable certain functionalities.
  • Companies: shall mean all types of business entities registered in India, including but not limited to Private Limited Companies, Public Limited Companies, Limited Liability Partnerships (LLPs), Foreign Companies, and any other legal entity types registered under applicable Indian laws.
  • Data Protection Officer: means the designated individual responsible for overseeing Filesure's data protection strategy and implementation to ensure compliance with applicable data protection laws.
  • Digital Personal Data Protection Act, 2023: means the Indian legislation titled Digital Personal Data Protection Act, 2023, governing the processing of personal data.
  • Information Technology Act, 2000: means the Indian legislation titled the Information Technology Act, 2000, relating to cyber activities, electronic governance, and data security.
  • Effective Date: means the date on which this Privacy Policy comes into effect, specifically 17 May 2025.
  • User: means any individual who accesses or uses the Services provided by Filesure.
  • Consent: means explicit, informed, and unambiguous agreement by the Data Principal to the processing of their Personal Data for specified purposes.
  • Contact Information: means the details provided for communication purposes related to privacy and data protection queries, including email address, telephone number, and postal address of the Data Protection Officer.
  • Data Protection Inquiry: means any communication, request, complaint, or concern raised by a Data Principal regarding the processing of their Personal Data.
  • Business Days: means any day other than a Saturday, Sunday, or public holiday when Filesure is open for business.
  • Ministry of Corporate Affairs: means the governmental authority in India responsible for administering company law and maintaining corporate data, including official portals V2 and V3.
  • Master Data: means foundational corporate data such as company registration details, identification numbers, and basic profile information, sourced from MCA portals.
  • Director Data: means personal and professional details of company directors obtained from MCA portals and other authorized sources.
  • Charges Data: means information relating to charges, mortgages, or securities registered against Companies as recorded with the MCA.
  • Public Filings: means documents and disclosures submitted by Companies to the MCA, including financial statements, annual reports, and other statutory filings.
  • Annual E-filings: means electronic submissions made by Companies to the MCA on an annual basis as required by law.
  • Goods and Services Tax: means the indirect tax system administered by the Government of India, and its associated data portal.
  • GST Suvidha Provider: means an authorized intermediary providing APIs and services to access GST data on behalf of entities like Filesure.
  • Publicly Available Data: means personal data accessible in the public domain, including data from government portals such as MCA, which may be processed without explicit consent under applicable laws.
  • User-Provided Data: means personal information voluntarily submitted by users during registration, login, or interaction with Filesure's Services.
  • Third-Party Authentication Providers: means external services (e.g., Google) used to facilitate user login and authentication, which share limited user data with Filesure based on user consent.
  • Website Interaction Data: means technical and usage information collected automatically during a user's interaction with Filesure's platform, including IP addresses, browser type, device identifiers, and similar data.
  • Legitimate Business Purposes: means activities related to the operation, provision, and improvement of Filesure's Services, including but not limited to due diligence, compliance verification, research, and authorized commercial activities.
  • Terms and Conditions of MCA Portals: means the legal agreements and usage policies governing access to and use of data from the Ministry of Corporate Affairs portals (V2 and V3).
  • Due Diligence: means the investigation or exercise of care that Filesure performs to verify corporate information and compliance status.
  • Compliance Verification: means the processes through which Filesure and its users confirm adherence to applicable laws, regulations, and corporate governance standards.
  • Commercialization: means the authorized sale, licensing, or distribution of data for commercial purposes.
  • Marketing Communications: means messages or materials sent to individuals for the purpose of promoting products, services, or events.
  • User Authentication: means the process of verifying the identity of a user to grant access to Filesure's Services.
  • Industry-Standard Security Measures: means accepted technical, organizational, and procedural safeguards widely recognized and adopted in the data protection and cybersecurity field.
  • Lawful Governmental Requests: means demands, orders, or inquiries issued by competent governmental or regulatory authorities in accordance with applicable laws.
  • External Sources: means third-party data providers, including governmental portals such as the Ministry of Corporate Affairs ("MCA") V2 and V3 portals, and other authorized repositories from which Filesure sources data.
  • Good Faith Efforts: means reasonable actions taken by Filesure to ensure data accuracy and timeliness consistent with technical capabilities and legal constraints.
  • Data Synchronization: means the process of updating Filesure's database to reflect the most current information available from external sources.
  • Liability Disclaimer: means Filesure's explicit statement denying responsibility for any inaccuracies, delays, or errors arising from external factors beyond its control.
  • User Responsibility: means the obligation of Users to independently verify critical data and bear risks associated with reliance on Filesure's data.
  • Warranty Disclaimer: means Filesure's declaration that it makes no guarantees or representations regarding the completeness or accuracy of the data.
  • Authoritative Sources: means official and legally recognized sources of data, including but not limited to MCA portals and other government-maintained registries.
  • Contractual Necessity: means processing of Personal Data required to perform or enter into a contract involving the Data Principal.
  • Legal Obligation: means processing Personal Data to comply with statutory, regulatory, or governmental requirements imposed on Filesure.
  • Legitimate Interests: means processing Personal Data based on Filesure's or a third party's lawful interests balanced against the Data Principal's fundamental rights.
  • Balancing Test: means an assessment conducted to ensure that Legitimate Interests do not override the rights and freedoms of the Data Principal.
  • Data Retention Period: means the duration for which Personal Data is retained by Filesure to fulfill processing purposes or comply with legal requirements.
  • Data Anonymization: means the process of removing or modifying Personal Data so that individuals cannot be identified.
  • Good Faith Implementation: means adherence to retention and deletion practices consistent with applicable laws and internal policies.
  • Legal Proceedings: means any ongoing investigations, disputes, or enforcement actions involving Filesure that necessitate extended data retention.
  • Service Providers: means third-party vendors, contractors, or agents engaged by Filesure to perform specific functions or services on its behalf, including but not limited to data hosting, IT support, payment processing, customer service, and marketing.
  • Business Partners: means entities with which Filesure collaborates for research, analytics, or service improvement by sharing aggregated, anonymized, or de-identified data.
  • Aggregated Data: means data compiled from multiple sources and combined in such a way that it does not identify any individual Data Principal.
  • Anonymized Data: means Personal Data that has been processed to irreversibly prevent identification of the individual Data Principal.
  • De-identified Data: means data from which personal identifiers have been removed, reducing the possibility of linking data to a specific individual.
  • Lawful Requests: means legally valid demands, subpoenas, court orders, or other judicial or governmental directives requiring disclosure of Personal Data.
  • Explicit Consent: means a clear, specific, and informed agreement by the Data Principal authorizing Filesure to share Personal Data with third parties.
  • Unauthorized Third Parties: means any entities or persons who do not have the legal right or consent to access or use Personal Data.
  • Data Breach: means any incident resulting in unauthorized access, disclosure, alteration, or destruction of Personal Data.
  • Technical Safeguards: means measures such as encryption, access controls, and intrusion detection systems implemented to protect Personal Data.
  • Administrative Safeguards: means policies, procedures, and training programs designed to govern data handling and ensure privacy compliance.
  • Organizational Safeguards: means structural and management practices ensuring accountability and privacy governance.
  • Encryption: means the process of encoding data to prevent unauthorized access during storage or transmission.
  • Access Controls: means mechanisms such as role-based permissions and multi-factor authentication restricting data access to authorized personnel.
  • Security Audits: means systematic evaluations of security policies, procedures, and controls.
  • Incident Response: means the procedures implemented to detect, investigate, and remediate security breaches.
  • Data Portability: means the right to receive Personal Data in a structured, commonly used format and transfer it to another entity.
  • Withdrawal of Consent: means the revocation by a Data Principal of previously given consent to process Personal Data.
  • Restriction of Processing: means limiting the use of Personal Data in accordance with a Data Principal's request or legal requirement.
  • Grievance: means a formal complaint or concern raised by a Data Principal regarding the processing of their Personal Data.
  • Data Protection Board of India: means the regulatory authority established under the Digital Personal Data Protection Act, 2023, responsible for oversight and enforcement.
  • International Data Transfer: means the transfer of Personal Data to entities or servers located outside India.
  • Standard Contractual Clauses: means legally binding data protection clauses approved by regulators to govern international data transfers.
  • Session Cookies: means temporary cookies that expire when the browser session ends.
  • Persistent Cookies: means cookies that remain on a device for a specified period until deleted.
  • Children: means individuals under the age of eighteen (18) years.
  • Material Changes: means significant updates or amendments to the Privacy Policy that affect user rights or data processing practices.

2. Identity and Contact Details

2.1 Identity of the Data Fiduciary

The Data Fiduciary responsible for the collection, processing, and protection of Personal Data is:

FileSure India Private Limited
Corporate Identification Number (CIN): U62013MH2023PTC411571
Registered Office: Sambhaji Nagar No2, St. Antony Road, Chembur, Mumbai, Maharashtra 400071, India
Corporate Office: 6th Floor, Rahimtoola House, Homji Street, Near Horniman Circle, Fort, Mumbai, Maharashtra - 400001

2.2 Contact Information for Privacy and Data Protection Queries

For any queries, concerns, or requests related to this Privacy Policy or the processing of your Personal Data, you may contact our designated Data Protection Officer ("DPO") at:

Email: dpo@filesure.in
Phone: +91 8104946419
Postal Address: Data Protection Officer, FileSure India Private Limited, Sambhaji Nagar No2, St. Antony Road, Chembur, Mumbai, Maharashtra 400071, India

We endeavor to respond to all data protection inquiries, requests, or complaints promptly and in accordance with the timelines prescribed under applicable laws and regulations. Specifically, we commit to acknowledging receipt of your communication within seven (7) business days and providing a substantive response or resolution within thirty (30) calendar days from the date of receipt. Where such timelines cannot be met due to exceptional circumstances, we shall inform you accordingly and provide an estimated timeframe for resolution. Our commitment is to address your concerns regarding your personal data comprehensively, ensuring confidentiality and security throughout the process. Please do not hesitate to contact us using the details provided above for any assistance related to your personal data. All communications will be handled with the utmost professionalism and discretion.

3. Categories of Personal Data Collected

3.1 Types of Personal Data Collected

Filesure collects and processes various categories of Personal Data in connection with the provision of its Services. The primary sources and types of data include, but are not limited to, the following:

  • Data obtained from the Ministry of Corporate Affairs (MCA) portals:
    • Master data relating to Companies as defined in clause 1.3.8.
    • Director data associated with such Companies.
    • Charges data registered against such Companies.
    • Public filings submitted by such Companies.
    • Annual e-filings data accessed from both MCA V2 and V3 portals.
  • Data obtained from the Goods and Services Tax (GST) portal:
    • GST registration details and GST filings data accessed via Application Programming Interface (API) provided through an authorized GST Suvidha Provider (GSP).
  • Publicly available data on directors:
    • Contact details such as mobile phone numbers and email addresses sourced from publicly accessible information on the internet, which Filesure processes and may commercialize.
  • User-provided data:
    • Personal data collected when users log into Filesure, including name, photograph, email address, and mobile phone number.
    • Filesure does not collect residential addresses.
    • Users may also log in via third-party providers such as Google, and personal data shared through such third-party authentication mechanisms are collected and processed.
  • Website interaction data:
    • Technical information such as IP addresses, browser details, device identifiers, and usage data automatically collected via cookies and similar tracking technologies during user interaction with Filesure's platform.

3.2 Data Sources

  • Filesure primarily obtains corporate and director-related data from official MCA portals (V2 and V3), covering all Companies as defined in clause 1.3.8, ensuring compliance with applicable legal frameworks governing data access and use.
  • GST registration and filing data is sourced from the GST portal via APIs provided by authorized GST Suvidha Providers (GSPs) in accordance with applicable laws and agreements.
  • Additional contact details of directors, including mobile and email information, are sourced from publicly available data on the internet, which Filesure aggregates and processes.
  • User-related personal data is collected directly from users during account registration, login, or interaction with Filesure’s Services, including through third-party authentication providers.

4. Purposes of Data Processing

4.1 Use of Data Sourced from MCA Portals

  • Filesure processes data obtained from the Ministry of Corporate Affairs (“MCA”) portals (V2 and V3) solely for legitimate business purposes, including but not limited to providing comprehensive corporate information, director details, and statutory filings related to Companies as defined in clause 1.3.8.
  • All MCA data processing activities are conducted in strict compliance with the terms and conditions governing the use of MCA portals, applicable Indian laws, and regulatory guidelines. Filesure does not use MCA data beyond the scope authorized by such terms.
  • Filesure commits to regularly synchronize with MCA portals to ensure that data reflected on its platform is up-to-date and accurate to the extent possible. However, Filesure explicitly disclaims liability for any inaccuracies, omissions, or delays in data updates originating from MCA sources.
  • Filesure restricts the use of MCA data to the provision of services facilitating due diligence, compliance verification, business research, and other authorized purposes. Redistribution, resale, or unauthorized commercial exploitation of MCA data is conducted only within the limits permitted by law and applicable agreements.

4.2 Use of Publicly Available Director Contact Data

  • Filesure collects and commercializes director contact details, including mobile phone numbers and email addresses, sourced from publicly accessible internet resources. Such processing is undertaken in compliance with applicable data protection laws and ethical standards.
  • Filesure ensures that any marketing communications or data commercialization activities are conducted only after obtaining necessary consents where required and provide recipients with mechanisms to opt-out.

4.3 User Data and Authentication

  • Filesure processes user-provided personal data, including login credentials and profile information, to enable user authentication, access management, and customer support.
  • Third-party authentication providers, such as Google, may share limited personal data with Filesure pursuant to user consent during login.

4.4 Data Security and Integrity

  • Filesure employs industry-standard security measures to safeguard the integrity, confidentiality, and availability of data obtained from MCA portals, users, and other sources against unauthorized access, alteration, or disclosure.

5. Data Accuracy and Update Limitations

  • Filesure obtains personal data from external sources, including the Ministry of Corporate Affairs (“MCA”) portals (V2 and V3) and other authorized repositories, and processes such data in accordance with this Privacy Policy.
  • Filesure makes reasonable and good faith efforts to ensure that the data displayed on its platform is accurate and current to the best extent technically and legally feasible.
  • Notwithstanding such efforts, Filesure does not warrant, guarantee, or represent, either expressly or impliedly, that the data provided through its Services is, at all times, accurate, complete, error-free, or up to date.
  • Users acknowledge and agree that Filesure’s ability to update and synchronize data depends substantially on the availability, performance, and reliability of third-party systems, including but not limited to MCA portals, over which Filesure has no control.
  • Consequently, Filesure expressly disclaims any liability for any errors, omissions, delays, or inaccuracies in data updates arising from external technical failures, system outages, network issues, or any other circumstances beyond its reasonable control.
  • Users expressly assume full responsibility and risk for any use of or reliance upon the data provided by Filesure, including but not limited to any decisions or actions taken based on such data.
  • Filesure does not undertake any obligation to update or correct data continuously and disclaims liability for any damages, losses, or expenses incurred as a result of outdated or incorrect information.
  • Nothing in this Privacy Policy shall be construed as creating a warranty or representation by Filesure regarding the accuracy, completeness, or timeliness of data, nor as a waiver of any statutory rights or defenses available to Filesure under applicable laws.
  • Users are strongly advised to verify any critical data or information directly with official MCA portals or other authoritative sources prior to relying on such data for legal, financial, or business decisions.

7. Data Retention Period

  • Filesure shall retain Personal Data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, and contractual obligations.
  • Retention periods vary depending on the category of Personal Data, the nature of the Services provided, and applicable statutory or regulatory requirements.
  • Filesure undertakes periodic reviews of stored Personal Data and shall securely delete, anonymize, or otherwise render such data irrecoverable once it is no longer necessary for the purposes stated herein or required by law.
  • Notwithstanding the foregoing, Filesure may retain Personal Data beyond the applicable retention period where necessary to comply with ongoing legal proceedings, investigations, disputes, or enforcement actions.
  • Users acknowledge and agree that Filesure’s data retention practices are designed to comply with applicable laws and that Filesure shall not be liable for any damages arising from such retention or deletion policies implemented in good faith.

8. Data Sharing and Disclosure

8.1 Circumstances for Sharing Personal Data

Filesure may share Personal Data collected in connection with its Services only in the following circumstances and subject to applicable legal and contractual safeguards:

  • With Service Providers: Filesure may disclose Personal Data to trusted third-party service providers, contractors, or agents engaged to perform functions on its behalf, including but not limited to data hosting, IT services, payment processing, customer support, and marketing. Such parties are contractually obligated to process Personal Data solely in accordance with Filesure's instructions and applicable data protection laws.
  • With Business Partners: Filesure may share aggregated, anonymized, or de-identified data with business partners for research, analytics, or service improvement purposes, provided that such data does not identify any individual Data Principal.
  • As Required by Law: Filesure may disclose Personal Data in response to lawful requests, subpoenas, court orders, or other legal processes issued by competent authorities, or to protect its legal rights, safety, or property.
  • With Consent: Filesure may share Personal Data with third parties where the Data Principal has provided explicit consent for such sharing.

8.2 Third-Party Due Diligence

  • Filesure maintains due diligence procedures to ensure that any third parties receiving Personal Data implement appropriate technical, organizational, and contractual measures to safeguard the data and comply with applicable privacy and security standards.

8.3 Restrictions on Data Sales

  • Filesure shall not sell, rent, or trade Personal Data to unauthorized third parties.

8.4 Security Acknowledgment

  • Users acknowledge that despite reasonable security measures, Filesure cannot guarantee absolute security of data transmitted to third parties and agrees to hold Filesure harmless for any unauthorized access or data breach occurring beyond its reasonable control.

9. Data Security Measures

9.1 Security Implementation

  • Filesure implements and maintains reasonable technical, administrative, and organizational safeguards designed to protect Personal Data against unauthorized access, disclosure, alteration, destruction, or loss.

9.2 Security Measures

Such security measures include, but are not limited to:

  • Encryption: Encryption of Personal Data both in transit and at rest, where applicable.
  • Access Controls: Secure access controls, including role-based permissions and multi-factor authentication.
  • Security Audits: Regular security audits, vulnerability assessments, and penetration testing.
  • Employee Training: Employee training and awareness programs focused on data privacy and security best practices.
  • Incident Response: Incident response procedures to promptly address and mitigate any data security breaches.

9.3 Third-Party Security Requirements

  • Filesure requires all third-party service providers and partners who process Personal Data on its behalf to implement adequate security measures consistent with industry standards and applicable laws.

9.4 Security Limitations

  • Despite these efforts, Filesure cannot guarantee absolute security of Personal Data and disclaims liability for unauthorized access or breaches resulting from factors beyond its reasonable control.

10. User Rights Under the DPDPA

10.1 Available Rights

In accordance with the Digital Personal Data Protection Act, 2023 ("DPDPA") and other applicable laws, Data Principals ("Users") are entitled to exercise the following rights with respect to their Personal Data processed by Filesure:

  • Right to Access: Users have the right to obtain confirmation of whether their Personal Data is being processed and to request access to such data.
  • Right to Correction: Users may request correction or rectification of inaccurate, incomplete, or outdated Personal Data.
  • Right to Erasure: Users have the right to request deletion or removal of their Personal Data, subject to applicable legal obligations or legitimate grounds for retention.
  • Right to Data Portability: Users may request to receive their Personal Data in a structured, commonly used, and machine-readable format for transmission to another Data Fiduciary.
  • Right to Withdraw Consent: Where processing is based on consent, Users may withdraw such consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
  • Right to Object: Users may object to the processing of their Personal Data on grounds relating to their particular situation, including for direct marketing purposes.
  • Right to Restrict Processing: Users may request limitation of processing of their Personal Data under certain circumstances as prescribed by law.

10.2 Process for Exercising Rights

  • To exercise any of these rights, Users may contact Filesure's Data Protection Officer using the contact details provided in Section 2 of this Policy.

10.3 Response Timeline

  • Filesure shall respond to such requests promptly and within the timelines prescribed under applicable laws, subject to verification of identity and the applicability of exemptions or restrictions under the law.

10.4 Request Limitations

  • Filesure reserves the right to refuse or limit requests that are manifestly unfounded, excessive, or repetitive, in accordance with applicable legal provisions.

10.5 Legal Limitations

  • Users acknowledge that certain rights may be subject to limitations or exceptions under law, including where retention or processing is necessary for compliance with legal obligations or the establishment, exercise, or defense of legal claims.

11. Grievance Redressal Mechanism

11.1 Commitment to Addressing Concerns

  • Filesure is committed to addressing all concerns, complaints, or grievances raised by Data Principals ("Users") relating to the processing of their Personal Data in a fair, transparent, and timely manner.

11.2 Grievance Submission Process

  • Users may submit grievances or complaints by contacting Filesure's designated Data Protection Officer ("DPO") at the contact details provided in Section 2 of this Policy.

11.3 Acknowledgment Timeline

  • Upon receipt of a grievance, Filesure shall acknowledge the complaint within seven (7) business days and undertake a thorough investigation to address the issue.

11.4 Resolution Timeline

  • Filesure aims to resolve grievances expeditiously and, wherever possible, within thirty (30) calendar days of receipt, subject to the nature and complexity of the complaint.

11.5 Notification of Delays

  • In cases where resolution within thirty (30) calendar days is not feasible, Filesure shall notify the User of the delay, the reasons thereof, and the expected timeframe for resolution.

11.6 Escalation Process

  • If a User is dissatisfied with Filesure's resolution, they may escalate the grievance to the Data Protection Board of India or any other competent regulatory authority as provided under the Digital Personal Data Protection Act, 2023 ("DPDPA").

11.7 Record Maintenance

  • Filesure maintains records of all grievances and the actions taken in response, demonstrating accountability and compliance with applicable legal requirements.

11.8 Preservation of Legal Rights

  • Nothing in this section shall limit any other legal rights or remedies available to Users under applicable law.

12. International Data Transfers

12.1 Transfer Overview

  • Filesure may transfer Personal Data to countries outside India ("International Transfers") for purposes consistent with this Privacy Policy and in compliance with applicable data protection laws, including the Digital Personal Data Protection Act, 2023 ("DPDPA").

12.2 Adequate Safeguards

International Transfers shall only occur where adequate safeguards are in place to protect Personal Data, such as:

  • Adequate Jurisdictions: Transfer to countries or entities recognized by Indian regulators as providing an adequate level of data protection.
  • Contractual Safeguards: Implementation of legally binding agreements, including Standard Contractual Clauses (SCCs), to ensure compliance with data protection standards.
  • Other Safeguards: Other appropriate safeguards approved under applicable law.

12.3 Third-Party Obligations

  • Filesure shall ensure that any third parties receiving Personal Data abroad agree to uphold confidentiality and security obligations consistent with this Policy and Indian data protection requirements.

12.5 Protection Measures

  • Filesure shall implement reasonable measures to protect Personal Data during transfer and storage in foreign jurisdictions.

13. Cookies and Tracking Technologies

13.1 Purpose and Utilization

  • Filesure utilizes cookies and similar tracking technologies ("Cookies") on its website and Services to enhance user experience, analyze usage patterns, and deliver personalized content and advertisements.

13.2 Definition of Cookies

  • Cookies are small data files placed on a user's device that store information related to browsing behavior, preferences, and session details.

13.3 Types of Cookies

  • Filesure employs both session cookies, which expire when the browser is closed, and persistent cookies, which remain on the device for a defined period.

13.4 Cookie Categories

Cookies used may include:

  • Essential Cookies: necessary for the operation and security of the website.
  • Analytical and Performance Cookies: to collect anonymous data on website usage and improve functionality.
  • Functional Cookies: to remember user preferences and settings.
  • Advertising and Targeting Cookies: to deliver relevant marketing content and track advertising effectiveness.

13.5 Cookie Notice

  • Users are informed at the point of first visit about the use of Cookies and are provided with options to manage or disable Cookies through a consent banner or settings interface.

13.6 User Controls

  • Users may control or disable Cookies via browser settings, though such actions may affect the functionality and user experience of the Services.

13.7 Legal Compliance

  • Filesure ensures compliance with applicable laws governing Cookies and online tracking, including obtaining consent where required.

14. Children's Privacy

  • Filesure’s Services are not directed to, nor intended for use by, individuals under the age of eighteen (18) years (“Children”).
  • Filesure does not knowingly collect, store, or process Personal Data of Children without verifiable parental or guardian consent, as required under applicable laws.
  • If Filesure becomes aware that it has inadvertently collected Personal Data of a Child without such consent, it shall take prompt measures to delete or anonymize such data in accordance with applicable legal requirements.
  • Parents or guardians who believe that Filesure has collected Personal Data of a Child without appropriate consent may contact Filesure’s Data Protection Officer as specified in Section 2 to request deletion or exercise other applicable rights.
  • Users affirm that they are not Children or have obtained necessary parental or guardian consent to use Filesure’s Services.

15. Changes to This Policy

  • Filesure reserves the right to modify, amend, or update this Privacy Policy at any time in its sole discretion to reflect changes in legal, regulatory, operational, or technological developments.
  • Material changes to this Privacy Policy will be communicated to Users via prominent notices on Filesure’s website, email notifications, or other effective communication channels prior to the implementation of such changes, where feasible.
  • Continued use of Filesure’s Services following the posting or notification of any updated Privacy Policy constitutes acceptance of the changes.
  • Users are encouraged to review this Privacy Policy periodically to stay informed about how Filesure collects, uses, and protects Personal Data.
  • If Users do not agree to the updated Privacy Policy, they should discontinue use of the Services and may contact Filesure’s Data Protection Officer to address any concerns.

16. Contact Information

16.1 Data Protection Officer Contact Details

For any questions, concerns, or requests regarding this Privacy Policy or Filesure's data processing practices, Data Principals ("Users") may contact the designated Data Protection Officer ("DPO") at:

  • Email: dpo@filesure.in
  • Phone: +91 8104946419
  • Postal Address: Data Protection Officer, FileSure India Private Limited, 6th Floor, Rahimtoola House, Homji Street, Near Horniman Circle, Fort, Mumbai, Maharashtra - 400001, India

16.2 Response Commitment

  • Filesure is committed to addressing all communications promptly, professionally, and in accordance with applicable data protection laws.

16.3 Encouragement to Contact

  • Users are encouraged to use these contact channels to exercise their data protection rights, report concerns, or seek further information about their Personal Data.