We, RemitCircle Inc., incorporated under the laws of India, including our affiliated entities, group companies or permitted assigns, (“Company”, “we” or “us”) recognize that user’s (“you” or “user”) privacy is very important and it is our endeavour to protect your data and privacy in compliance with applicable laws and as per the details outlined in this Privacy Policy (“Privacy Policy”). Privacy Policy describes Company’s policies and procedures relating to collection, use, processing and disclosure of your information pursuant to your use of our website https://remitcircle.com desktop or mobile application, any software application and related applications (collectively, the “Online Platform”). This Privacy Policy is part of and is to be read along with the Terms of Service (“TOS”) document as available on our Online Platform.
For the purposes of this Privacy Notice, “Personal Data” means data relating to you that is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of your identity or any combination of such features with any other information. Personal Data does not mean information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force.
We advise you to read this Privacy Policy and TOS before using our Online Platforms, using any of our services or submitting any personal data. By using the Online Platforms, it shall be deemed that you are expressly consenting to be bound by the terms and conditions described in this Privacy Policy and TOS.
Please note that our services offered through the Online Platform are not intended for minors below the age of 18 years and individuals who are incapacitated because of disability. We do not knowingly collect data relating to minors and such persons with disability.
A.INTRODUCTION
1.We reserve our right to change and update this Privacy Policy from time to time, therefore, you should regularly check for any changes in our Privacy Policy. We will notify all users of any material changes, to the extent feasible, to this Privacy Policy and the Privacy Policy document will also signify the date of Last update for user’s convenience. Your continued access to or use of our Online Platform and services after the date of the update in Privacy Policy constitutes your acknowledgment and agreement that you have read, understood and accepted the terms of the updated Privacy Policy. If you do not agree to the updated Privacy Policy, you must stop accessing or using our Online Platform and/or our Services.
B.INFORMATION WE COLLECT
2.We may collect and process the range following data about you depending on the nature of and purposes of rendering Our services:
a) You may be required to give us sensitive personal data about the ultimate beneficial owners and other relevant stakeholders of the entity before, during or after creating an Account, or while corresponding with us through any means of communications. Sensitive personal data that you will voluntarily provide us may include information such as name, photograph, postal address, e-mail address, phone number, details/copy of Govt. Issued National Identity documents (i.e. Passport, Aadhaar Card etc.), details/copy of documents used as proof of address (i.e. Driving licence, utility bills, bank passbook etc.), details/copy of your Tax Identification Details (i.e. Permanent Account Number - PAN card) and other identification documents.
b) Your financial and credit card information, details of your Bank Account, location details or other information requested by us to detect and protect against frauds and similar criminal activity and such other information required by us from time to time for providing the Services.
c)Details of all your transactions or activities performed and carried out on or through our Online Platform.
d)Technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, material or information that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-hovers), and methods used to browse away from the page and any phone number used to call our customer service number.
e)Cookies: Our Online Platform uses Cookies and tracking technology in order to distinguish you from other Users of our Online Platform and enables us to serve you better and provide you a customised and personalised user experience. Cookie and tracking information collected by us may be shared with third-parties which directly support our services and are involved in development/ improvement of our Online Platform.
C.USE OF INFORMATION
3.The Information that we collect from or about you may be used and/or processed:
- to verify, maintain, update and retain your personal details and details relating to your identity, address, financial information and other aspects as may be required as per our Company’s policy or to comply with applicable laws and regulations;
- to facilitate and provide the services offered through the Online Platform;
- to inform you of our products, services, promotions, offers, surveys and events which may be of interest to you;
- to carry out update, upgrade, maintenance, customization and other changes in our products and services to serve you better;
- to provide you with the information and Services, that you request from us;
- to enhance the security and user experience of our Online Platform;
- To track and remember information and details relating to the transactions executed by you on or through our Online Platform;
- to prevent and identify suspicious / other illegal transactions in order to mitigate risks relating to money laundering and other illegal activities;
- to provide you, or permit selected Third Parties to provide you, with information about Services we feel may interest you or for the purposes of verification and authentication of your identification documents;
- to send you Service related notices or emails and other non-essential promotional material (you will be provided an option to unsubscribe to such email or other communications);
- for KYC verification, ourselves or through a selected Third Party, of the details of Tax Identification and other Identification documents provided by you. You understand that in order to verify that such information belongs to you, we may send you a verification email/one-time password.
D.SHARING OF INFORMATION
Third-Party Sharing
4.We reserve the right to share any Information that we collect from you, as prescribed above with third parties in the course of Our business. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your Personal Data.
5.Our services may include links to other websites or applications when you visit our Platform. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser or on the m-site you are redirected to), use of any Personal Information that you provide on these websites or applications is governed by the privacy policy of the operator of the application/website, you are visiting. That policy may differ from ours and you are requested to review those policies or seek access to the policies from the domain owner before proceeding to use those applications or websites. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.
6.We further reserve the right to share your personal data to any third party when we are under obligation to share such information under applicable laws or under the order of any competent authority/court. We may also disclose and share your personal data with third parties to detect, prevent or investigate any actual or potential occurrence of identity theft, fraud, money laundering, abuse of Services and other illegal acts.
7.We may share your personal data with selected business partners, service providers and third parties including Banks, payment processing companies, KYC verification service providers and third party virtual digital asset service providers (“Third Parties”).
Cross-border transfer/processing
8.Your personal data may be processed and stored in a foreign country or countries. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to provide at least the same standard of protection to your personal data that we are obliged to under applicable laws. However, in case of such processing or transfer, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your personal data under relevant foreign laws.
Non-Personal Data
9.The Company reserves the right to share current and historical volume of transactions, market trends, historical volume data, estimated and actual transaction volumes and other aggregate data and information relating to the user behaviour pattern or trend of transaction executed on our Online Platform. This information shall be shared in a non-personal format and no person shall be identifiable by processing such information.
E.YOUR CONSENT
11.By using any of the Online Platform, you agree and consent to the collection and use of information collected to the extent and in the manner described above and in accordance with this Privacy Policy. You also agree and consent to any changes made to this Privacy Policy in due course and without notice. If you do not agree with the terms and conditions of this Privacy Policy, please do not provide any information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any information as required by us, we may not be able to provide you with the Services that are being offered through the Online Platform.
12.You also agree that all your data and/or information shared with us is accurate, correct and complete, at all times. You understand that you must promptly inform us of any changes to your data and/or information which may impact your use of our Services.
F.WITHDRAWAL OF CONSENT
13.You may disable or delete your account maintained with us at any point of time by making and completing verification of such request to us, through Our website, subject to the applicable terms and conditions. With this, we will no longer share your Personal Data with any Third-Parties or process it for any purpose save as otherwise required under applicable law. Specifically, we retain your Personal Data as long as the purpose for its usage exists, after which the same is disposed of by us unless retention is required for compliance with any Applicable Law.
G.ASSIGNMENT
14.We may assign, novate, or transfer any or all rights and obligations that accrued in our favour under the Privacy Policy, at our sole discretion, to our subsidiaries, affiliated entities, or any selected Third Party to offer you a full suite of services globally through our subsidiaries or affiliates.
SECURITY PRACTICE
15.Your Personal Data is accessible only by our authorized employees and selected Third Parties, and is otherwise kept secure.
16.We have in place appropriate technical and security measures to prevent unlawful access to or accidental loss of Personal Data collected by us. We have taken the following steps to ensure data security:
- All the user information can only be accessed by authorized users;
- Users need to authenticate themselves with a username-password combination; and
- All data is hosted on the servers of Amazon Web Services. For more information, please refer to the details of the security standards and compliance policies of the hosting service provider.
17.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, give no warranties, and shall not be liable for breach of the security of your data transmitted through the Online Platform due to malicious attacks, errors, commission or omissions not willfully initiated by us. Any transmission is at your own risk. Once we have received your information, we will use reasonable standards and practices to strict physical, electronic, and procedural safeguards to try to prevent unauthorised access.
I.DATA RETENTION
18.We retain Personal Data provided by you for as long as your Account is active, unless you specifically withdraw consent and stop using Our services. We shall subsequently retain your Personal Data as required to comply with Applicable Laws, for resolution of disputes, for the purpose of investigations or ongoing prosecutions or in case of any suspicious/ illegal transactions, for enforcement of any agreements, and/or as necessitated under applicable laws.
19.We make no warranties and shall not be liable regarding non-availability or non-retention of any Personal Data provided by you beyond the deletion of your Account.
J.YOUR RIGHTS
20.The right to access – You have the right to request our Company for copies of your personal data including summary of personal data processed or identities of all other Data Fiduciaries and Data Processors with whom the personal data has been shared, etc. We may charge you a small fee for this service.
21. The right to rectification – You have the right to request that our Company correct any information you believe is inaccurate. You also have the right to request our Company to complete the information you believe is incomplete.
22.The right to erasure – You have the right to request that our Company erase your Personal Data, under certain conditions.
23.The right to restrict processing – You have the right to request that our Company restrict the processing of your Personal Data, under certain conditions.
24.The right to object to processing – You have the right to object to our Company’s processing of your Personal Data, under certain conditions.
25.The right to nominate- You may also nominate any individual who shall be authorized to take actions on your behalf in case of your death or incapacitation.
You may exercise any or all of the above-mentioned rights by contacting Our Data Protection Officer. If you make a request, we have one month to respond to you.
K.CONTACT INFORMATION
27.The data fiduciary responsible for your personal data is Purple Pixel Private Limited. In case you have any queries, please write to our Data Protection Officer at admin@remitcircle.com