Last update: December 14, 2020
1. About TomorrowMakers®
TomorrowMakers® is a website that provides content and tools about insurance and personal finance that empower people to make an informed decision about their financial future (‘Services’).
The Sites are managed and operated by Transamerica Direct Marketing Consultants Private Limited, its affiliates and/or service providers (collectively referred to as ‘TomorrowMakers®’, ‘we’, ‘our’ or ‘us’).
We want you to know that any Personal Information will only be collected by lawful means and only for the purposes disclosed to you hereunder, and that all reasonably practicable practices are followed to ensure that any Personal Information held by us is maintained in accordance with our security program that is designed to ensure the security and integrity of Personal Information, is protected against threats or hazards to the security or integrity of Personal Information, and to prevent unauthorised access to Personal Information.
3. Grievance Officer
You may contact the Grievance Officer of TomorrowMakers® with questions concerning this Policy at the following address.
Name: Mr Avinash Shroff
Title: Managing Director
Telephone: 91 22 6118 0149
We shall try and resolve your grievance within 15 days and in any event no later than 30 days from the date of receipt of your grievance.
1. Personal Information We May Collect
’Personal Information’ is any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person. Examples of personal information include full name, date of birth, address, email address, and gender.
Your Personal Information that we may collect will vary depending on your use of the particular features on our Sites, and our collection and use of your Personal Information will be limited to the purposes set out in Part 4 – How We May Use Your Personal Information. You hereby represent and warrant that any Personal Information that you submit in connection with your use of the Sites belongs to you.
When you create a TomorrowMakers® Profile, we will collect your e-mail address, gender, date of birth and specific or general location, hardware, software, platform, media, Internet Protocol (IP) address and connection, information about online activity such as feature usage and click paths, passwords and other data that you may provide in surveys or online profiles. If you register for our Services via a social media channels, we will obtain certain Personal Information you have provided to such social media channel (such as first name, last name and e-mail address). The information we obtain may depend on the privacy settings you have with the relevant social media channel.
2. How We May Collect Personal Information
We may collect your Personal Information through a variety of ways, including the following:
- Through the Sites: We may collect Personal Information through the Sites, e.g., when you first register, use calculators, sign up for a newsletter or submit a query using the ‘Contact Us’ form.
- From other sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, social media platforms, or from people with whom you are friends or otherwise connected with on social media platforms.
- Cookies: Our web pages and Services may also utilise ‘cookies’ and other tracking technologies. A ‘cookie’ is a small text file that may be used, for example, to collect information about your activity on our Sites. Some cookies and other technologies may serve to recall personal information previously indicated by you. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
3. Why Does TomorrowMakers® Collect Information?
Our primary goals in collecting information are to improve our services, features, and content, to administer your use of our services, and to deliver content that may be of interest to our users.
We may combine demographic information with Personal Information to tailor our offerings or web pages, including advertising subject matter, to your preferences or interests.
4. How We May Use Personal Information
We may use your Personal Information for the following:
- Respond to your inquiries and fulfil your requests, such as to send you newsletters or to respond to your questions and comments;
- Enable you to participate in social sharing, including live social media feeds;
- Send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies;
- Provide you with updates and announcements concerning our articles, offers, promotions of any products by our partners/affiliates and programs, and to send you invitations to participate in special programs;
- Send you advertising/promotional material from any of our affiliates, and from our promotional and strategic partners;
- Enable you to use Calculators;
- For our business purposes, such as analysing and managing our businesses, market research, developing new features, enhancing our Sites, identifying usage trends, determining the effectiveness of our online activities, tailoring Site experience and Content based on your past activities on the Sites, and gauging users’ satisfaction and providing assistance (including troubleshooting in connection with user issues).
5. How Personal Information May Be Disclosed
Your Personal Information may be disclosed to the following:
- Third-party service providers, to facilitate our Services, provide the Services on our behalf, perform site-related services (including but without limitation, maintenance services, website hosting, data analysis, infrastructure provision, IT services, email delivery services database management, web analytics, and improvement of the Services’ features) or to assist us in analysing how our Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose;
- Third-party service providers who conduct marketing campaigns, surveys, and/or polling through the sites. To the extent that such activities are conducted on the Sites and we are the controllers or users of the data collected, such third-party service providers are contractually bound to preserve the confidentiality, security, and integrity of the Personal Information collected;
- To identify you to anyone to whom you send messages through the Sites;
- By you, on message boards, chat, profile pages, blogs, tools, calculators, YouTube videos, and other services to which you are able to post information and materials (including our Social Media pages). Please note that any information you post or disclose through these services will become public information, and may be available to visitors of the Sites and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Sites;
- If you participate in social sharing. Please refer to the section on ‘Use Of Social Media And Your Personal Information’ below;
- Data may also be disclosed as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit any damages that we may sustain;
6. Where Will Information Be Collected and Stored?
TomorrowMakers® is owned and managed by Transamerica Direct Marketing Consultants Private Limited, a limited liability company incorporated in India. Accordingly, the Personal Information we collect may be transferred to and stored using encrypted Secure Socket Layer (SSL) technology in our servers or those of third parties that act on our behalf (such as hosting providers) with control and access of the data with TDMC. The databases are stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited.
USE OF SOCIAL MEDIA AND YOUR PERSONAL INFORMATION
You may disclose your personal details by connecting your social media account to your Site account or by logging into your Site account from your social media account. If you register on the Sites using a social media account, we may post a generic registration message on your social media profile, and if you use interactive features on social media channels while logged in to your social media account, your actions will be transmitted to the applicable social media provider and may be available on your social media profile. We may also share your information regarding your activities on the Site with third-party social websites to populate your social media wall that is visible to other people; however, you will have the option to control your privacy settings, where you can decide what you would like to share or not to share with others.
Similarly, if you participate in a live social media feed (which you may do, for example, by referencing us in your social media post or ‘liking’ us on a social media platform), your public username and profile photo may be displayed on the Sites along with your post.
Other Information We May Collect
‘Other Information’ is any information other than Personal Information that we may collect in connection with your use of the Site; such as:
- Browser and device information
- Server log file information
- Information collected through cookies, pixel tags, and other technologies
- Demographic information and other information provided by you
- Location information
- Aggregated information
1. How We May Collect Other Information
We may collect Other Information through a variety of ways, including the following:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, type of internet connection, click paths, dates and times that our Site is accessed, duration of use of our Services, and the name and version of the Sites (such as the App) you are using. We use this information for statistical purposes as well as to ensure that the Sites function properly.
- Through server log files: Your IP Address is a number that is automatically assigned by your Internet Service Provider (ISP) to the computer or device that you are using. An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating Site usage levels, diagnosing server problems, and administering the Sites. Please note that we treat IP Addresses, server log files, and related information as Other Information, except where we are required to do otherwise under applicable law.
- Using pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with certain pages on the Sites and HTML-formatted email messages to, among other things, track the actions of the users of the Site and email recipients, measure the success of our marketing campaigns, and compile statistics about Site usage and response rates.
- From you: Information such as date of birth, gender, and PIN code, as well as other information, such as your preferred means of communication, may be collected when you voluntarily provide this information. Unless used in combination with other Personal Information, such information is not meant to personally identify you or any other users of the site.
- By aggregating information: Any information obtained through the Site, whether such information is Personal Information or Other Information, may be aggregated for anonymised statistical analysis. All aggregated information retained by us will not personally identify you or any other users of the Sites.
2. How We May Use and Disclose Other Information
Please note that we may use and disclose Other Information for any purpose, unless prohibited or restricted by any applicable law. If we are required to treat Other Information as Personal Information under applicable law, we will only use such Other Information for the purposes listed in Part 1 – How We May Collect Other Information of the section ‘OTHER INFORMATION’ and Part 4 – How We May Use Your Personal Information of the section ‘PERSONAL INFORMATION’.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your postal code). If we combine any Other Information with Personal Information, the combined information will be treated as Personal Information.
LINKS/ACCESS TO THIRD-PARTY SITES
We are also not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of other organisations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organisations through or in connection with the TomorrowMakers® Apps or our Social Media pages.
When we present information to our advertisers – to help them understand our audience and confirm the value of advertising on our Sites – it is usually in the form of aggregated statistics on traffic within our Sites. We use third-party advertising companies to serve ads when you visit our Sites. These companies may use information (excluding your name, address, email address, telephone number, or other personally identifiable information) about your visits to this and other websites or application, in order to provide advertisements about goods and services of interest to you. We do not provide any personally identifiable information to third-party websites, advertisers, or ad servers without your consent.
We use reasonable organisational, technical, and administrative measures to protect Personal Information in our possession or under our control. We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorised access to systems where we store personal data.
However, while we strive to use commercially acceptable means and appropriate security measures to protect your Personal Information, we cannot guarantee absolute security of our database or your Personal Information, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. No security system is impenetrable, and no method of transmission over the Internet, or method of electronic storage, is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us immediately by contacting us in accordance with the ‘Contact Us’ section at the bottom of the page.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
Our use and disclosure of your Personal Information for marketing purposes is subject to your consent: If you wish to stop subscribing to our newsletters, please go to the bottom page of any email containing such newsletters and click the ‘Unsubscribe’ link, where you will be directed to a new window with an email confirmation addressed to us to remove you from our newsletter feature.
Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) within 60 working days.
How you can access, edit, or delete your Personal Information
To review, edit, or delete your Personal Information that has been previously provided to us, please go to the ‘Account setting’ section of your profile page. Please note that, for a period of 30–45 days from the date that the profile is deleted, there may be residual information that will remain within backup media and servers. The profile data will be completely purged within 45 days after profile deletion as per the backup scheduler run.
We ask that you do not send us nor disclose any sensitive Personal Information (e.g., financial information such as bank account, credit/debit card, or other payment instrument details, information related to sexuality, racial or ethnic origin, political or religious belief, opinions or affiliation, criminal background or trade union membership, health data, biometric data, genetic data) on or through the Sites or otherwise to us.
JURISDICTION IN CASE OF DISPUTES
Disputes, if any, shall be subject to the exclusive jurisdiction of the courts at Mumbai, India.