1. Other applicable terms
2. Policy changes
3. Links to Third Party Websites
4. Competency to contract
5. Collection of information
The Company collects two basic types of information from a User in conjunction with a User’s use of the Application i.e. personal information, which is any information that exclusively identifies a User (e.g., the User’s name, email address, telephone number, postal address amongst others) and non-personal information, which is information that does not exclusively identify a User but is related to User nonetheless such as, information about a User’s interests, demographics and use of the sites. The Company may also receive personal information regarding a User as shared by third parties who maybe our clients or otherwise avail Services from the Company. Please note that in such instances the Company is acting on the instructions provided by such client or user and the Company does not separately verify the right of the client or user to provide User Information to the Company. In case User is not the intended recipient of the Services and Application, User should contact the Company and at the earliest.
Towards the provision of the Services by the Company and the use of the Application, the Company shall in addition to the information described above, collect the following information from a User (“User Information”):
6. Usage of User Information
User Information will be used by the Company for the purposes which the Company considers necessary for achieving a seamless, efficient and safe experience, customized to User’s needs and use the information to provide Services to User, enhance the operation of the Services and improve the Company’s marketing and promotional efforts. The processing of User Information is for the purposes of:
to provide, maintain and enhance User experience in relation to the Application;
to send technical notices, updates, security alerts, and support and administrative messages to User;
to take up and investigate any complaints/ claim/ disputes;
to respond to User’s queries or feedback submitted by the User;
to monitor and analyze trends, usage, and activities in connection with the Services;
to link or combine with information the Company receives from others to understand User’s needs and provide better service;
to carry out any other purpose for which the information was collected; and
to share the data such as back testing, user action and processed data for internal and external services with the third parties without User’s consent.
7. Information collected by Cookies and other tracking technologies
The Company shall use various technologies to collect information, including cookies and web beacons. Cookies are small data files typically stored on User’s computer’s hard drive or in device memory that help us improve our Services and User’s experience, see which areas and features of our Services are popular and count visits, manage the registration process for accounts, remember User’s site preferences, retain certain information to process orders for exchange transactions, and retain information to provide User with support.
Information collected from cookies is used by us to evaluate the effectiveness of our site, analyse trends, see what difficulties our visitors may experience in accessing our site, and administer the platform.
8. Storage of User Information
User Information in the possession and control of the Company is stored in accordance with Applicable Laws. Whenever a User changes or access the User’s account information, the Company offers the use of a secure server. However, the User acknowledges that transacting over the internet has inherent risks which can only be avoided by the User following reasonable security practices, such as not revealing account/login related information to any other person and informing the Company’s customer care team about any suspicious activity or where the User’s account has/may have been compromised.
Please note that the Company does not guarantee that there will be no unintended disclosures of the User Information and data provided by a User on account of a data breach, unauthorized access, security failure etc. the Company cannot guarantee, give no warranties, and shall not be liable for breach of the security of User Information through the Services of the Company due to malicious attacks, errors, commission or omissions not wilfully initiated by the Company and any transmission is at the risk of the User.
9. Sharing and Disclosure of User Information
User information shared with the Company shall not be shared or disclosed with any other user or third party except when the anonymous information is used for analysis and to make payment. The information can be disclosed, if necessary, in accordance with the applicable laws. User information shall be disclosed to external service providers such as payment providers, executors of the Services and/ or Google Analytics etc., to assist the Company in providing the Services or collating and analysing User information for making the Services more user-friendly. The payment and transaction details shall not be shared with other users or third parties under any circumstances.
10. Retention of User Information
11. Communication policy
When the User sets up an account or receives any request pursuant to the provision of the Services, the User is deemed to have opted in to receive emails and messages from the Company and its service providers in connection with the provision of the Services as well as any marketing and promotional agencies. While User may opt out of promotional messages, the User cannot opt out of receiving certain administrative, financial, technical and legal information from the Company in connection with the Services.
12. Alteration of User Information
In case the User requests any change or deletion of User Information of the User, or permanently delete the User’s, the User must contact the Company at email@example.com or contact the Data Protection and Grievance Officer. Do note that the Company is not obligated to alter or vary or delete any User Information which it is required to maintain under applicable laws or pursuant to contractual requirements of the Company.
13. Cross border transfer and maintenance of User Information
User Information may be required to be transferred or retained in locations other than the location of residence of the User. Such other countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality and protection of the User Information. In case of any transfer of User Information, the Company will use best endeavors to put in place appropriate controls and safeguards to ensure that User Information is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is absolutely necessary.
14. Data breach and disclosure notification
In case of a data breach or an unauthorized disclosure of User Information which is likely to result in a high risk to the rights and freedoms of the User, unless the Company has appropriately mitigated the risk arising from such incident, the Company shall, within notify the affected Users of such breach with the details of the breach or incident, the consequences of such breach and the contact personnel of the Company in case of any queries by the User pertaining to such breach.
In case any governmental or regulatory authority requires the Company to provide any User Information, unless specifically directors by the governmental or regulatory authority, the Company shall disclose to the User, the details of the request for the User Information.