1.2. The terms “we/us/our” shall refer to Accountmein Fintech Solutions Private Limited, having our registered office at Plot no.- 48, 4th Floor, Sector-44, Haryana 122003-India, and the terms “you/your” shall refer to the users and any other persons accessing or seeking to use the Platform (defined herein below).
1.5. We value the relationship we have with you, and we are committed to responsible information handling practices. We take your privacy very seriously and want you to feel comfortable whenever you visit the Platform with your PII and/or NPI. We recognize the importance of privacy as well as the importance of maintaining the confidentiality of PII and/or NPI.
2. OPERATING SYSTEM PERMISSIONS
2.1. Android mobile platforms have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. Android devices will notify you of the permissions that our App seeks before you first use the App, and your use of the App constitutes your consent. Sometimes these permissions require more explanation than the Platforms themselves provide, and the permissions we request will change over time.
2.2. Android permissions:
(a) Device and App history: We need your device permission to get information about your device, like OS name, OS version, mobile network, hardware model, preferred language, installed apps etc. Based on these inputs, we intend to optimize your overall experience by understanding your preferences and by using OS specific capabilities.
(b) Contacts: If you allow us to access your contacts, it enables us to make it easy to get referred by your friends and also send across referral links to your friends. This information will be stored on our servers and synced from your phone.
(c) Camera: We need access to your camera for the purposes of our services including for determination of your attendance at a store.
(d) Location: Please note that the App collects background location data to enable store geofence, data submission and store action even when the app is closed or not in use. Users are aware that we are getting their location and this feature is built in the App to monitor their presence in the stores. Managers manually check the users’ location from the Platform/portal and ensure that users are working from their designated locations. Whenever a user submits data from the operations, we receive the address of the said user from a nearby location. It is mandatory for the user to provide location access to the App for smooth functioning.
(e) Wi-Fi: When you allow us the permission to detect your Wi-Fi connection, we optimize your experience based on the connection speed.
(f) Device ID & call information: This permission is used to detect your Android ID through which we can uniquely identify users. Please note that the App requires phone number for account management and user verification. Please note your phone number is stored by us is shared with our group companies and affiliates. For the said purposes, by using the Platform, you hereby give your consent to such sharing and/or usage of your phone number.
3. TYPES OF INFORMATION COLLECTED BY US
3.1 Personally Identifiable Information (“PII”)
(a) PII, as used in information security and privacy laws, is information that can be used on its own or with other information to identify, contact, or locate a single person and/or an entity, or to identify an individual and/or entity in context and includes information such as name, email address, phone number, information about your mobile device, cardholder name and information linked to a business transaction.
(b) When you use our Platform, we collect information regarding your computer and mobile device such as internet protocol address, domain, host, mobile status and anonymous site statistical data. As part of our KYC process we capture your name, phone number and email id. These PII are essential for rendering our services to you. We may also use this information to customize our services based on such information as provided by you.
(c) Our Platforms are particularly designed for electronic commerce (e-commerce) and are predominantly used by business entities to facilitate transactions and orders on e-commerce platforms and such business use does not generally involve the collection of PII of individuals unless it is provided voluntarily by you. By using the Platform, you hereby represent, confirm and acknowledge that any PII of third party/individual provided by you has been provided with due consent from such third party/individual. Please note that PII submitted by you of such third party/individual who are not the users of this Platform, are retained by us for purposes of enhancing our services.
(d) We also collect any information exchanged by you with us in the form of written communication, responses to emails, feedback provided, etc.
(e) You have the right to request to discontinue our use of your PII and/or any third party/individual’s PII provided by you. To withdraw your consent to our collection and processing of such information in future, you may do so by sending an email to firstname.lastname@example.org.
3.2 Non-Personal Information (NPI)
(b) If we do combine NPI with PII, then the combined information will be treated as PII for as long as it remains combined.
(c) We use various technologies and/or third-party tools to collect NPI, including without limitation:
II. Location: Please note that the App collects background location data to enable store geofence, data submission and store action even when the app is closed or not in use. Users are aware that we are getting their location and this feature is built in the App to monitor their presence in the stores. Managers manually check the users’ location from the Platform/portal and ensure that users are working from their designated locations. Whenever a user submits data from the operations, we receive the address of the said user from a nearby location.
III. Log File Information: Our servers automatically collect limited information about your device’s connection to the internet, including your IP address, when you visit our Platform. We automatically receive and log information from the Platform including but not limited to IP address, your device or computer’s name, and your operating system. We may also collect log information from your device, including but not limited to your system, device’s name, device’s serial number or unique identification number (e.g., Android ID or ADID on your android device) and your device operating system,. This information helps us facilitate the provision of software updates and other services to you. We may use this information, among other things, to improve our services or technologies
IV. Web beacon or other technologies: We often use web beacon in conjunction with cookies, to enhance our services on a number of pages of the Platform. A non-identifiable notice of a visitor’s visit to a page on the Platform is generated and recorded. Such notice may be processed by us or our third-party associates. To disable some of these features, you may disable cookies in your web browser’s settings. Web beacon and other technologies will still detect visits to these pages, but the notices they generate are disregarded and cannot be associated with other non-identifiable cookie information.
V. Google Analytics or other tools: Our Platform uses certain third-party tools (including but not limited to Google Analytics), in order to evaluate your use of our Platform, and to provide other services relating to the Platform activity, among other things.
(d) We may also collect other non-specific information to provide you better access to our services each time, such as preferences and interests and other non-personal details via the Platform, any application form or email or any other medium. We may also store and publish such information to assist us in making the Platform better and easier to use.
4. INFORMATION USAGE AND SHARING
4.3. We are both a data controller and a data processor.
4.4. We may share your PII and/or NPI with third parties in the following circumstances:
(a) To enable business entities or persons to process PII and/or NPI on our behalf or in connection with our services. We require that these parties agree to process such information based on our instructions and with appropriate confidentiality and security measures;
(b) We have a good faith belief that access, use, preservation or disclosure of such PII and/or NPI is reasonably necessary to: (i) satisfy any applicable law, regulation, legal process or enforceable governmental request including to law enforcement and in response to a court order, (ii) detect, prevent, or otherwise address fraud, technical or security issues, (iii) enforce applicable Policies of the Platform, which may be further extended to investigation of potential violations thereof, or (iv) protect against harm to our rights, safety or property, our users or the public as required or permitted by law;
(c) To protect ourselves against third-party claims;
(c) To protect ourselves against third-party claims;
(d) Is necessary for performance of a contract between you and us;
(e) To any member of our related or group companies including our subsidiaries, our ultimate holding company and its subsidiaries, as the case may be.
(f) In the event that we sell or buy any business or assets, we may disclose your PPI and/or NPI to the prospective seller or buyer of such business or assets. User, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate re-organization. Corporate divestitures, mergers, acquisition, sale of business and/or dissolution.
(g) We may partner with third-party entities to provide you with additional services related to our business or other programs that involve third parties, and this impliedly authorizes us to share your PII and/or NPI with those parties. A third party’s use of your information is bound by contracts and agreements between us and the third party. We only share information reasonably needed to provide the additional services/benefits. By sharing information with us, you agree that we are not liable or responsible, directly or indirectly, for the actions or inactions of third parties;
(h) We may disclose/share information to third-parties who support our business, such as those providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertisements, providing customer support and business support services, facilitating payments, or conducting research and surveys, and the information will be used for the limited purposes of such services received by us.
(i) We may also provide your information to our partners, associates, advertisers, service providers or other third parties to provide, advertise or market their legitimate products and/or services which may be of your interest. You will have the choice to ‘opt out’ of such marketing or promotional communications at your will.
(j) We also use your contact information to send you offers based on your previous orders and interests.
(k) We use PII to provide you with services you explicitly request for, to resolve disputes, troubleshoot concerns, help promote safe services, collect payment, measure interest of various users of our services, send important information, services, updates, customize your experience, detect and protect against error and fraud, enforce our terms and conditions, etc.
5. LINKS TO/FROM THIRD-PARTY WEBSITES
5.2 We may have presence on social networking websites including but not limited to LinkedIn, Facebook, Twitter, YouTube, Telegram, Instagram and blogs which are promotional and business initiatives to attract, engage and connect to a larger group of people. The domain links contained therein may either direct you to our Platform or request your participation by way of feedback, suggestions, etc. We, in this regard, fully disclaim any liability (is) or claim(s), which may arise by use/misuse of your feedback, suggestions, views, etc. on any of the aforementioned networking websites or blogs, by any third party whether or not known to us.
6. INFORMATION SECURITY & RETENTION
6.1. We take precautions including without limitation, administrative and technical measures to safeguard your personal information against loss, misuse or theft, as well as against destruction, alteration, disclosure and unauthorized access.
6.2. For this purpose, we adopt internal reviews of the data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems, where we store your PII. Specifically, while we will ensure our best efforts to protect your information in line with commercially reasonable efforts and general industry standards; however, we do not represent, warrant, or guarantee that your information will be protected against unauthorized access, loss, misuse or alterations.
6.3. We recognize industry standards and employ security safeguards to protect PII from unauthorized access and misuse. All information you provide to us is stored on secure servers. Any payment transactions will be protected and safeguarded by encryption during data transit and storage by specific safeguards and security measures. We will not disclose to third parties any PII that you provide without your consent, except as necessary to provide services you have specifically requested and as specifically mentioned in this Policy. Once we have received your information, we will use industry standard procedures and security features to try to prevent unauthorized access to that information.
6.4. When you use our services or the Platform, some of the PII you share may be visible to other users and can be read, collected, or used by them. You are responsible for such PII you choose to submit in these instances. Further, you are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer/mobile systems, and you agree to accept responsibility for all activities that occur under your account or password.
6.6. A “Force Majeure Event” shall mean any event that is beyond our reasonable control and shall include, without limitation, sabotage, fire, flood, earthquakes, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorized access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided it is beyond our reasonable commercial control), power or electricity failure or unavailability of adequate power or electricity
6.7. While we will endeavor to take all reasonable and appropriate steps to keep secure any PII and/or NPI which we hold about you and prevent unauthorized access, you acknowledge that the internet or computer networks are not fully secure and that we cannot provide any absolute assurance regarding the security of your PII. Please exercise reasonable caution when determining what information you disclose via the Platform. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Platform. Any transmission of data is at your risk.
6.8. You understand and agree that we may continue to store your information after you cease to use the services or disable your use of, or access to the services or the Platform. Please note that we may, share and/or disclose your PII with third parties, after you cease to use our services or disable your use of, or access to the services or the Platform. NPI will be retained indefinitely, and we may continue to use, share and/or disclose your NPI in furtherance of our Policies.
6.9. You acknowledge and agree that we reserve the right to remove or edit content, refuse services, terminate accounts, or cancel plans at our sole discretion.
7. YOUR RIGHTS RELATING TO THE INFORMATION
7.1 The right of access – this is your right to see what information is held about you by us.
7.2 The right to rectification – this is your right to have your information corrected or amended if what is held is incorrect in some way.
7.3 The right to erasure – this is your right to ask for your personal information to be deleted under certain circumstances. This applies if the personal information is no longer required for the purposes it was collected for, or your consent for the processing of that information has been withdrawn, or the personal information has been unlawfully processed. We will usually inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to disclose any of your information to any third party for such purposes.
8.1. In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you.
Grievance Officer Name: Shefali Sharma
Address: 4th Floor, Plot no. 48, Sector -44, Gurgaon, Haryana-122003
Email address: email@example.com
8.3. The Grievance Officer can be contacted between 10am to 5pm from Monday to Friday except on public holidays.
9. GOVERNING LAW
9.1. We are incorporated in, and based out of the Republic of India, and we are duty bound to abide by Indian laws. We may not have complied with some privacy laws of other countries and further represent to be unaware of such other legal requirements.
10. QUESTIONS AND CONTACT INFORMATION
12. THIRD PARTY SITES