1. The App and Clients
Company has developed and solely owns a mobile personal finance software application (“App”, which expression shall include future releases of the App). Company makes the App available for download and use on mobile phones to clients (“Clients”). Downloading and installing the App shall be deemed to constitute sufficient proof that Clients have read, understood and accepted this Policy.
2. Personal Information
2.1. “Personal Information” means the Transaction Information as defined in the Terms of Service and includes information that is contained in text messages (that is, SMS) sent by providers of services and/or products (including but not limited to financial institutions, mobile carriers and utility companies) to Clients’ mobile telephone number(s) in connection with one or more transactions across multiple financial accounts (including purchase, payments, billing information and service notifications related thereto). Without limitation, Transaction Information includes:
2.1.1 Mobile phone numbers of Clients
2.1.2 Email addresses of Clients
2.1.3 Partial payment card data only to the extent such card data is disclosed in the said messages
2.1.4 Information related to the transaction in question including identity of the service or product and the price or fee paid or payable in respect thereof.
3. Purpose of Collection and Use of Personal Information
Company may collect, store, access and use Personal Information solely to the extent required for Company to enable Clients to utilize the features of the App and to provide better user experience to Clients. Such use shall expressly include sharing the Personal Information with Affiliates and Lenders.
4. Usage of Google Advertising ID
As per the terms of Google Play Services, the Company shall use the Google advertising ID when available on a device, only for advertising and user analytics purposes. The Company may share this ID with advertising partners only for the purpose of advertising.
The Company shall not connect the advertising ID to any personally-identifiable information without the explicit consent of Clients. The Company shall abide by reset and “Opt out of Interest-based Advertising” settings of Clients.
5. Sharing of Personal Information with Third Parties
Company shall not publish, sell, give on rent, trade or otherwise transfer Personal Information to third parties, except as may be required by law, or pursuant to the order of a court or regulatory authority, or in order for Company to enforce its rights, or as expressly stated by this Policy. In the event Company needs to share Personal Information with third parties, Company shall enter into non-disclosure agreements or equivalent covenants that are, at the least, as protective as the provisions of this Policy.
Company reasonably presumes that Clients who make available Personal Information to Company are doing so out of their own volition. Company does not compel Clients to disclose Personal Information. At any time, Clients may opt not to provide Personal Information by uninstalling the App.
7. Correctness and Integrity of Personal Information
Company accesses Personal Information as aforesaid from SMS messages on an ‘as is’ basis. Therefore, Company shall not be responsible in any way for the correctness, completeness and integrity of any Personal Information collected hereunder.
Company shall take all reasonable precautions by way of using current industry standard encryption technologies to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
9. Limit of Liability
Notwithstanding anything to the contrary in this Policy or any other terms of service or use applicable as between Company and Clients, Company’s aggregate liability hereunder shall be limited to Rs.1000/- (Rupees One Thousand Only) and shall not extend to any indirect or remote damages whatsoever, including but not limited to special, incidental, consequential, or punitive damages or loss of profits.
For any inquiries and complaints, the email address may be used. All inquiries and complaints shall be looked into promptly and without charging any fee to the inquirer / complainant.
Company shall always cooperate with regulatory authorities and investigating agencies in India in the matter of treatment of Personal Information.
Company may modify this Policy in its sole discretion at any time. While Company shall make best efforts to notify Clients of any such modification, it shall be Clients’ responsibility to read and understand the Policy as prevalent from time to time. Installation of the App shall be deemed to constitute acceptance of the Policy as amended