Privacy Policy

Reading Time: 15 minutes

About Us

Your privacy is important to us, and we are committed to protect your privacy. #GROWTH is an invite-only, exclusive community aimed at fostering growth & sharing new insights for growth marketers, product owners, entrepreneurs & CRM/analytics professionals from consumer brands.

Customer Engagement Leadership Program (CELP), is a learning program designed to help Customer Engagement and Growth professionals become leaders of tomorrow. It’s a paid cohort-based in-person workshop, following which participants become a part of the CELP Community and get access to other tools they might need, like courses, peer learning events, and 1:1 mentorship, to accelerate their careers.

Scope

#GROWTH is a community for Marketing/Growth Pros, Product Owners/Managers Who want to Network with and Learn from Peers & Leaders On how to Drive Customer led Growth in Digital Products Within Consumer Brands.

Customer Engagement Leadership Program (CELP) is for CRM/Growth/Marketing/Product Managers with at least two years of experience, who are well versed in one or more customer engagement disciplines (like ‘onboarding’ or ‘retention’).

About this Policy

This Policy (the “Privacy Policy”) informs you about what information (“Personal Data” or “Personal Information”) we may collect directly or indirectly from you through the MoEngage platform (the “Platform”), as a part of our Service. It describes how we create, store, transfer, share, collect, organize, use, return or delete (“Process”) personal data with the privacy and security practices we have implemented on the MoEngage Platform. The European Union website visitors should be sure to read the important information provided under the section – “Additional Information for European Union Users” in this Privacy Policy.

If the Use of Your information changes, we will provide You/Your (“Website Visitors, Customers, growth marketers, product owners, entrepreneurs, CRM/analytics professionals from consumer brands) with more information when we are in contact with You, via different modes of communications, through our website or via email. You can check for any updates or amendments to this Policy when You visit our website on – https://www.hashgrowth.org/ Any information that we process is subject to the privacy policy in effect at the time such information is collected.

This Privacy Policy only applies to MoEngage #Growth Community and does not apply to the practices of companies that MoEngage does not own or control, or to people that MoEngage does not employ or manage.

If MoEngage is collecting information directly from You, then MoEngage will act as the Data Controller (defined hereunder). If you have any questions related to handling Your Personal Data by MoEngage or to exercise Your rights to privacy You can contact us at [email protected].

Legal Basis for Processing Your Information

This is a global Policy and shall apply wherever You reside. In this section, we describe our legal justifications (commonly referred to as “legal basis”) for the Use of Your Personal Information related to each of our main processing activities.

Please note: depending on the country where You reside, the law of Your country may not require that We use a specific legal basis to justify Using Your Personal Information, including transfers of Your Personal Information outside Your country of residence (Example : GDPR). If Your jurisdiction requires consent to Process Your Personal Information when You interact with Us, We will obtain Your consent prior to the Use of such Personal Information.

Below, We explain to You MoEngage’s legal basis when processing Your Personal Information:‍

1. Based on Your prior consent (where permitted or required by law upon)

• We collect information about You when navigating on our sites and other features, when You submit queries or interact with Us
• We Use Your information in the context of  marketing and sales to propose  similar offers or inform You about upcoming products and send newsletters; or for statistics purposes.
• Depending on Your country of residence, We may have to request Your prior consent for example:
  • When subscribing to our newsletters;
  • Using forms, when creating Your user account; or when using cookies or similar technologies.‍
• As one of the professionals  applying for a cohort through the #Growth page, we will take your consent while you fill your details on the page.

1. To comply with applicable data protection laws and other legal statutes- In some limited instances, We may have to keep some limited Personal Information about You longer than needed such as for tax or accounting purposes.

Data Collection

Data Collected as a Data Controller

We collect only the information needed for legitimate business purposes.

As a Data Controller, MoEngage collects such data from You for various reasons, such as, #Growth events, marketing purposes or for other purpose(s). As a Data Controller, MoEngage does not collect any sensitive personal data.

When other entities of MoEngage or other third-parties give us Personal Information about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that we have informed You of the personal data processing as per your legitimate interests, and that we have obtained any applicable and necessary permission from you to process that information as described in this Privacy Policy.

This information would be collected by us in a number of ways through multiple channels while joining our community and over time during our relationship with you, which have been informed through the ‘ Privacy Notice’.

Types of Personal Data collected by MoEngage #Growth as Data Controller:

• #GROWTH Community Sign Up Form -To get the details of those contacts who are interested in signing up for #GROWTH Community
  First Name, Last Name, Email ID, Country
• #GROWTH Newsletter Sign Up Form – To sign up for the #GROWTH Newsletter|
  Work Email ID
• #GROWTH Mixer Registration Form – To sign up for #GROWTH Mixer Event
  First Name, Last Name, Email ID, Job Title, City, Company Name, Mobile Number
• #Growth Get Your Invite Registration Form – To sign up for #GROWTH Masterclass Event
  First Name, Last Name, Email ID, Job Title, City, Company Name, Mobile Number
• #GROWTH Summits (Big Events) Registration Form – To sign up for #GROWTH Summits
  First Name, Last Name, Email ID, Job Title, City, Company Name, Mobile Number
• #Growth Join the Waitlist program Registration Form – To sign up for Customer Engagement Leadership Program (CELP) Physical cohort/workshop
  First Name, Last Name, Email ID, Job Title, Company Name, Mobile Number, LinkedIn Profile

• Contributor Sign-up Form – To mentor/participate in podcasts or contribute in some way
  First Name, Last Name, Email, Country

• Acadle Sign up Form – To enroll to learning videos on Acadle
  Customer/Prospect’s First Name, Last Name, Email, LinkedIn Profile
  Employee Name, Email ID

• Data captured by cookies which may include analytical information and information about the date and time of Your request read our cookies section, Internet Protocol (IP) address, geolocation data, Your browser, operating systems, device ID.

Please refer to the ‘Cookie Policy’ for more information.

Please ensure you read, understand, and accept the privacy policies, and any terms of use. By using our Service, you expressly relieve MoEngage #Growth from any and all liability arising from your use of the  #Growth community service. We analyze and use this information to provide and improve the MoEngage Service. You may contact us with your requests at [email protected].

Information Related to Use of the Platform

We gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, to improve marketing, analytics, or site functionality.

Use of Cookies

MoEngage #Growth website uses “cookies,” which are small text files that are placed by web servers and used to remember your preferences and settings. We use cookies for:

• analyzing trends
• administering the site
• tracking users’ movements on the website
• gather demographic information about our user base as a whole
• tracking your login and interaction with our website

We may receive reports based on the use of these technologies on an individual as well as aggregated basis. You can change your browser settings to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If your browser does not accept cookies, you may not be able to easily access all aspects of our Service. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use locally stored objects (LSOs) such as HTML5 to collect and store information. Please refer to the ‘Cookie Policy’ for more details on how we use cookies and other web tracking technologies.

Opting-Out

Our partners may use non-cookie technologies (web tracking technologies) such as pixel tags, that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform: http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

An End User/website user who seeks to opt out must direct their query to us directly, by sending opt-out requests to [email protected].

Sharing and Disclosure of Information

Information Shared with our Subsidiaries

We shall transfer your PII to our Indian subsidiary to provide you with better service or for troubleshooting purposes. Our Indian subsidiary is bound by the principles of Standard Contractual Clauses and the obligations under this Privacy Policy. If you have any questions or concerns related to the transfer of PII to our Indian subsidiary, you contact us at [email protected].

Information Shared with Third Parties

We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling, and other similar purposes. We will not share the End User PII collected from one App Provider with third parties.

We may share and disclose Personal Data to the following types of third parties and for the following purposes:

• To customers – We may disclose information to our customers in the form of aggregated, anonymous data about the way the Services have been used to enable us to provide and improve our Services, to provide strategic advice to our customers, and to further and enhance our role as a thought leader in the industry;
• To vendors, consultants, and other service providers – We may disclose information to third-party vendors, consultants, business partners, and other service providers in connection with our marketing efforts, or in connection with our general business purposes;
• To comply with laws – We may disclose information to a third party where we are legally required to do so in order to comply with any applicable law, regulation, legal process, or governmental request;
• To protect our legal rights – We may also disclose information where we believe it necessary in order to protect or exercise, establish or defend our legal rights;
• Business transfers – We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company;
• To provide our Services – We use sub-processors in our provision of the MoEngage Services to our customers, such as third-party hosting providers and third-party database support services. Some of these third-party sub-processors may have logical access to data about you, but in all cases, any subprocessor to whom we disclose any information will be subject to a written agreement containing confidentiality protections designed to protect any Personal Data that is shared with them;
• To manage events – If you use our Website to register for an event or webinar organized by one of our partners who may be a co-sponsor of the event, we may share your Personal Data with the co-sponsor to the extent this is required to process your registration and ensure your participation in the event; in such instances, our co-sponsor will process the relevant Personal Data as a separate controller and the sponsor’s use and the control over your Personal Data will be governed by the sponsor’s privacy policy;
• To advisors – In individual instances, we may share Personal Data with professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, and insurers based in countries in which we operate, who provide consultancy, banking, legal, insurance, and accounting services, but only to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
• To affiliates – We may share Personal Data with affiliates within the MoEngage group and companies that we may acquire in the future when they are made part of the MoEngage group, to the extent such sharing of data is necessary to fulfill a request you have submitted via our Website or for customer support, marketing, technical operations or account management purposes; and
• Publicly shared data – Any Personal Data or other information you choose to submit in communities, forums, blogs, forms or chat rooms on our Website may be read, collected, and used by others who visit these forums, depending on your account settings.

Information Disclosed for our Protection and the Protection of Others

It is our policy to protect End Users from having their privacy violated through abuse of the legal systems, whether by individuals, entities or government and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about End Users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary:

• to satisfy or comply with any law, regulation or legal process or to respond to lawful requests, including subpoenas, warrants or court orders;
• to protect our property, rights and safety and the rights, property and safety of third parties or the public in general; and
• to prevent or stop activity we consider to be illegal or unethical. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Cross-border Data Transfers

Transferring of personal data out of the European Economic Area (EEA) or US to countries not deemed by the European Commission or US State Laws to provide an adequate level of personal information protection, shall be governed by one of the following safeguards recognized by EU & US data protection legislation respectively.

Kindly note that MoEngage will follow appropriate level of protection and deploy all necessary safeguards for transfer of such data that constitutes confidential information and/or Personal Data, additionally such transfers, to any country(s) which do not ensure an adequate level of data protection, MoEngage will ensure that the transfer is through one of the following mechanisms:

• In accordance with the EU-US Data Privacy Framework
• Data Processing Agreements (DPAs) with Standard Contractual Clauses (SCCs) approved by the European Commission who impose data protection obligations on the parties to the transfer.

For further details, see European Commission Model contracts for the transfer of personal information to third countries. The entity receiving the personal data shall comply with the principles of personal data processing set forth in the agreement.

Personal Data Protection

We are fully committed to Information security and compliance with applicable regulations, by implementing strong security controls for the protection of personal data. We have designed and implemented information security programs in line with International Organization for Standardization (ISO) 27001:2013 standard and Service Organization Controls 2 (SOC). We have put in place appropriate measures to comply with the European Union (EU) General Data Protection Regulation (GDPR).

We take reasonable measures to protect the information that we collect from or receive from App Providers or End Users (including PII) from unauthorized access, use, or disclosure. When you enter sensitive information (such as login credentials) on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL). Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) via email or conspicuous posting on our Platform in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

At any point, if you suspect any security issues or incidents, or you receive any suspicious mail from someone holding themselves out to be a MoEngage employee or from a fake website claiming to be affiliated with MoEngage, you may reach out to us at [email protected]

Privacy by Design

We have established a process to proactively embed privacy at the initial planning/design stages and throughout the complete development process of new processes/ services/ technologies and/or platforms that involve Processing of Personal Data.

Considerations have been made for technical and organizational measures to enhance privacy (e.g. optional data masking, optional data encryption, data minimization).

In addition, We shall take appropriate technical and organizational measures to ensure that Personal Data collected or Processed is adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed.

Social Media Features

Our Platform includes Social Media Features, such as the Facebook button, and widgets, such as the “Share” button, or interactive mini-programs that run on our site. These features may collect your IP address, and which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Platform. Your interactions with these Features are governed by the privacy policy of the company providing them.

Our Policy Toward Children

Our Service is not directed to children under the age of 13. MoEngage users must not be under the age of 13. We do not target any portion of our service to children under the age of 13, and we will delete any accounts or data of users that we believe to be under the age of 13 to be in compliance with the Children’s Online Privacy Protection Act. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at [email protected].

Your Rights

Handling of Data Subject Rights as a Data Controller:

For MoEngage employees, candidates and visitors of the MoEngage website, MoEngage Inc. is the controller of your personal information for purposes of European data protection legislation.

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to the personal information that we hold as a Data Controller  –

• Access: To provide the personal information we hold for you
• Rectify: To rectify the incorrect personal information we are holding for you
• Delete: To erase the personal information.
• Transfer: Send a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict: To restrict the processing of your personal information.

Opt-out: Once you opt-out, we shall stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.

Exercising Your Rights

You can submit these requests by email to [email protected]. We may require some information to authenticate your request. We may reject your request as applicable under law in which case we will inform you of the legal basis for rejecting your request. . If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at [email protected].

Use for a new purpose:

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

California Privacy Rights

The California Consumer Privacy Act 2018 (CCPA) and its upcoming amendments such as the California Privacy Rights Act (CPRA), California residents have specific rights regarding their Personal Information held by private companies. In particular, we do not:

• sell any Personal Information from individuals located in California,
• share any such Personal Information with third parties for their own commercial benefits, nor
• discriminate against you in any manner.

In addition to the above-mentioned rights under California law, You have the right to (subject to statutory or restrictions):

• Request to access/ disclosure of  the Personal Information, that is, disclosure of MoEngage’s collection and use of Your Personal Information over past 12 months from the date We receive the request;
• Request that MoEngage delete all of Your Personal Information collected from You;
• Opt-out from the “sale” of Your Personal Information;
• Opt-out of the “sharing” of your Personal Information for cross-context behavioral advertising (applicable  from 1 January 2023).

All Personal Information that is collected from You is in accordance with this Policy, including the Use of different categories of Your Personal data that has been collected from You, the disclosure of Your Personal Information is as per this Policy.

Response Timing

We endeavor to respond to a verifiable consumer request within 1 calendar month of its receipt. If we require more time (more than 1 calendar month), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Data Retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for Legal and regulatory retention requirements may include retaining information for the following:

• Audit and accounting purposes
• Statutory data retention terms
• The handling of disputes
• and the establishment, exercise, or defense of legal claims in countries where we do business.

We retain any contractual relationship information for administrative purposes, legal and regulatory retention requirements, defending MoEngage rights, and to manage MoEngage’s relationship with you. The information that is provided in a supplementary privacy policy may provide more detailed information on applicable data retention terms.

Please find the data retention schedule below:
ACT – Active, in use + Number of Years
C = End of Contract
E = End of Employment
YR = Creation Date + Number of Years
* = in years, unless otherwise noted

Record Category	Description	Retention Period
Customer Data [Active User Attributes]	SaaS Application Data: Active user attributes used for analysis & generating campaigns	C + 7 Days
Customer Data [Inactive User Attributes]	SaaS Application Data: Inactive/Unreachable user attributes used for analysis & generating campaigns	ACT + 90 Days
Analytics	SaaS Application Data: Generated for Analytics purpose	1 Year

Response to Personal Data Breach Incidents

When we learn of a suspected or actual personal data breach, the Data Protection Officer (DPO) shall lead the investigation along with the Data Privacy team and Information Security team to perform an internal investigation and take appropriate remedial measures in a timely manner, according to the Data Breach Reporting and Notification Policy. Where there is any risk to the rights and freedoms of data subjects, we will notify the relevant data protection authorities/EU representative without undue delay and, when possible, within 72 hours.

These cases shall be managed based on the Information Security Incident Response Procedure & Data Breach Management procedure, which provides the process of handling information security & privacy incidents.

Audit and Accountability

The Data Privacy team is responsible for auditing how well business departments implement this Policy.

Any employee who violates this Policy will be subject to disciplinary action and the employee may also be subject to civil or criminal liabilities if his or her conduct violates laws or regulations.

Legal Notice

MoEngage may need to disclose personal information to legal authorities for compliance, fraud investigation, statutory purposes or for other legal activities as per the local laws and government request.

MoEngage Contact Details

We provide easily accessible information via our Platform or on request. If You have any questions or requests related to this Policy or Your Personal Information, please contact us at the following contact details –

Please contact us at [email protected] if you have any questions about our Privacy Policy.

MoEngage Inc.

315 Montgomery Street, 10th floor,
San Francisco, 94104,
USA

MoEngage India

1st Floor, #32, Salarpuria Tower II,
Chikku Lakshmaiah Layout,
Luskar Hosur Road,
Koramangala,
Bangalore – 560034,
India

Data Protection Officer (DPO)/Grievance Officer

In accordance with Information Technology Act 2000 and the rules made there under, the name and contact details of the Grievance Officer are published herewith.

Data Protection Officer (DPO)/ Grievance Officer: Nitin Kotwal
Email: [email protected] / [email protected]

Changes to this Privacy Policy

We may update this Policy from time to time. You are advised to review the updated Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page and any modifications can be ascertained by referring to the date that is displayed at the top of the page marked as, “ Last updated”.