Privacy & Security Policy

VALUE GROWTH FINTECH SOLUTIONS PRIVATE LTD. (“FlexiPayment” or “we” or “us”) respects your privacy and we are committed to protect your privacy through our compliance with this Privacy and Security Policy (“Privacy Policy”).

This Privacy and Security Policy (“Privacy Policy”) describes how We protect information about Our users. For the purposes of this Privacy Policy, the capitalised term: (a) used herein shall have the meaning as described hereunder; and (b) used herein but not defined shall have the meaning so ascribed under the Terms and Conditions.

This Privacy Policy applies to information we collect:

• On FlexiPayment Website;
• On FlexiPayment Application; and
• In email, text, and other electronic messages between you and this Website or Application.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by VALUE GROWTH FINTECH SOLUTIONS PVT. LTD or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application of FlexiPayment

FlexiPayment has adopted this Privacy Policy to inform You of what information We collect from You through the Website, how We collect the information, how We may use it and the steps We take to protect it. For the purposes of this Privacy Policy, any information that uniquely identifies Our users (“User” / “You” / “Your”) such as Your name, address, contact number or email address, is referred to as “Personal Information”. We lay great emphasis on Our privacy and security standards to guard against identity theft and provide security for Your personal information. We regularly re-evaluate Our privacy and security policies and adapt them as necessary to respond to new challenges.

• CONSENT:

You acknowledge that this Privacy Policy is a part of the Terms of Use of the Website or Application and the other services, and by accessing the Website or Application or by otherwise providing us personal information yourself or through a primary user or by making use of the services provided by the Website or Application, you unconditionally signify your (i) assent to the Privacy Policy, and (ii) consent to the utilisation and processing of your personal information in accordance with the provisions of this Privacy Policy;

By using the Website, you unconditionally agree to the terms and conditions of this Privacy Policy and consent to usage, storage and handling of the information submitted by You in accordance with the terms contained hereunder. If You do not agree with the terms and conditions of this Privacy Policy, please do not proceed further to use the Website.

2.0          User Information

FlexiPayment collects Your Personal Information when You successfully submit information while filling any form or survey on the Website, or while creating Your User account (“User Information”). User Information is the data that can be used to uniquely identify or contact a person and/or the business entity that a person represents and shall include, but not be limited to, information regarding Your Personal Information, information associated to Your social networking platform and such other information for the purposes of identification and verification. When You submit User Information on the Website, it shall be deemed that You have granted Us the right to collect, store, process, handle and use such User Information, in accordance with this Privacy Policy (as amended from time to time).

You may visit and browse the Website without having to provide User Information. Where possible, we indicate which fields are mandatory and which fields are optional to be filled on the Website. You always have the option to not provide information by choosing not to submit particular information or feature on the Website. When you visit the Website, we may collect certain non-personal information such as Your internet protocol address, operating system, browser type, and internet service provider. This type of information does not identify You personally during Your visit to the Website. We can identify You only after You submit User Information voluntarily on the Website.

By using this Website, you consent to the collection, storage and use of the User Information that You provide for any of the services that We offer and You consent to Our collection of any changes or updates that You may provide to the User Information. We collect only such User Information that We believe to be relevant for the purpose of identification and verification and is required to understand You or Your interests. We clarify that We shall not be liable, for any reason whatsoever, for the authenticity of any User Information provided by You to Us. You hereby confirm that the User Information provided by You is and shall continue to be valid, true and accurate to the best of Your knowledge.

3.0          Collection of information

To enhance Your use of the Website, we may collect technical and navigational information each time You visit the Website, which are saved in server logs. These are encrypted statistics, which help Us in improving the efficiency of the Website by giving Us information relating to Your use of the Website. Such information may include details of:

• the server (Internet Protocol Address) from where the Website is being accessed;
• the browser and operating system used to browse the Website;
• links clicked, scrolled and pages visited;
• details of Your last visit to the Website, including time, date and the duration of Your session
  on the Website; etc.

This information may be used by FlexiPayment, for example, to understand the number of users visiting the Website, to alert You to any software compatibility issues, or it may be to gather broad demographic information for aggregate use of the Website in improving Our functionality. While collecting such information, your anonymity is maintained at all times and, at no time can We identity You personally, unless You submit the User Information on the Website or through the e-mail feature.

The data so collected by FlexiPayment, shall be stored for 8 years from the end date of relationship with customer.

FlexiPayment may make anonymous or aggregate personal information and disclose such data only in a non-personally identifiable manner to: advertisers and other third parties for their marketing and promotional purposes, such as the number of Users and how many users clicked on a particular product, services, third party links or any other Content available on the Website. Such information does not identify You individually. Access to Your User Information, account credentials, account information and any other personal information You provide is strictly restricted and used in accordance with specific internal procedures and safeguard governing access, in order to operate, develop or improve the services provided by Us. These individuals have been selected in accordance with our security policies and practices and are bound by confidentiality obligations. They may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

We may also use third party vendors or service providers to help Us provide various services to You, such as sending e-mail messages on Our behalf or hosting and operating a particular feature or functionality of Website. Our contracts with these third parties outline the appropriate use and handling of Your information and prohibit them from using any of Your Personal Information for purposes unrelated to the product or service they provide. We require such third parties to maintain the confidentiality of the information We provide to them.

You acknowledge that apart from Your User Information, if You upload or exchange any data, content, information, pictorial representations and/or images (i.e. User Content) including comments on the Website, such User Content may contain information including User Information and the same may be available to the other Users of the Website. FlexiPayment will not be liable for the disclosure and dissemination of such User Information on the Website.

4.0          Cookies

Like most other sites, we use data collection devices known as “cookies” to collect and store information of Users visiting the Website. A cookie is an alpha-numeric identifier, which is small amount of data that is sent to a user’s browser from a web server and is eventually stored on a User’s computer hard drive. Cookies are a reliable mechanism to remember the activities of the User on the Website and help in improving Your experience on the Website.

FlexiPayment may set and access cookies on Your computer to track and store preferential information about You. We may gather information about You through cookie technology. For example, we may assign a cookie to You, to help better determine which of FlexiPayment’s news stories appeals to your interests. This anonymous information is maintained distinctly and is not linked to the User Information You submit to Us. The option of accepting cookies is up to You, however certain features of the Website including Content and the forms may not be accessible without accepting cookies. Please note that most Internet browsers will allow You to stop cookies from being stored on Your computer and to delete cookies stored on Your computer. If You choose to eliminate cookies, the full functionality of the Website may be impaired for You.

To browse anonymously, you may set Your browser to disable cookies or delete cookies. Most cookies are session cookies that are automatically deleted from Your hard drive when You close the browser. Additionally, you may encounter cookies or other similar devices on certain pages of the Website that are placed by third parties. We do not control the use of cookies by third parties and shall not be liable for any reason whatsoever for these third-party cookies.

We may use third party service providers to help Us analyse certain online activities. For example, these service providers may help us measure the performance of Our online campaigns or analyse visitor activity on the Website. We may permit these service providers to use cookies and other technologies to perform these services for FlexiPayment. We do not share any Personal Information with these third party service providers, and these service providers do not collect such information on Our behalf. Our third party service providers are required to comply fully with this Privacy Policy.

5.0          Use of User Information

User Information provided by You is used by Us only to provide information that You request. We do not and will not sell or rent User Information to anyone, anytime for any reason. Our use of User Information includes the following:

• verifying Your identity;
• facilitating Your use of the Website;
• responding to Your queries or complaints or to fulfil Your requests for information about the
  services and solutions that We offer and the process relating to the same;
• providing You with information about FlexiPayment and to deliver to You any administrative
  notices, notifications regarding your subscription and other materials, news updates and
  campaigns supported by FlexiPayment;
• fulfilling your requests for certain services and providing You with related customer service;
• sending You surveys and marketing communications that FlexiPayment believes may be of interest to You;
• personalizing Your experience on the Website by presenting news & stories of interest to You;
• help You address trouble-shooting problems, detecting and protecting against error, fraud or other criminal activity;
• conducting internal reviews and data analysis for the Website (e.g., to determine the number of visitors to specific pages on the Website);
• sharing such information with third party contractors that provide services to FlexiPayment and are bound by the same privacy restrictions;
• improving the Content on the Website;
• protecting the integrity of the Website;
• responding to judicial process and provide information to law enforcement agencies or in relation to an investigation on matters concerning public safety, as permitted by law; and
• as otherwise set forth in the Privacy Policy.

We shall always seek your explicit consent for collecting your specific personal information and you shall always have an option to not to consent the information collection and not to go forward with website usage. You may also revoke your consent once given and you may also request FlexiPayment for “full Wipe” of your data already collected.

6.0          Sharing of User Information

User Information may be shared with such third parties as are required for: (a) the purposes of providing You with the services on the Website, and may be subject to the practices of such third parties; or (b) facilitating subscription for FlexiPayment content and services on the Website by You; or (c) to grow Our business which may include our affiliates, strategic partners, investors, suppliers and service providers, as the case maybe. The User Information may be saved in servers, at Our sole discretion.

Except as provided in paragraph above, we shall disclose the User Information only in circumstances where:

(i) The User has provided instructions or consent towards such disclosure;
(ii) We, in good faith, believe that access, use, preservation or disclosure of such information is reasonably necessary to:

(a) satisfy any applicable law, regulation, legal process or enforceable governmental or regulatory request; (b) enforce the applicable User Agreement or Privacy Policy; (c) detect, prevent, prohibit or otherwise address fraud, security or technical issues, (d) enforce Our rights against You or in connection with a breach by You of this Privacy Policy; or (e) protect against imminent harm to the rights, property or safety of FlexiPayment, its Users or the public as required or permitted by law; and

(iii) If We sell or transfer any of Our business or assets, certain User Information may be a part of that sale or transfer.

7.0          Security Precautions

To prevent any form of unlawful interception or misuse of User Information, we use reasonable physical, electronic and managerial procedures to safeguard and secure the User Information collected. We use reasonable secure and technologically appropriate measures, in compliance with the Information Technology Act, 2000 and the rules related thereto to protect You against loss or misuse of Your User Information including internal reviews of data collection, storage and processing practices and other reasonable security measures which are equivalent to security measures that FlexiPayment uses to protect its own confidential information. We have in place a secure server for all Your transactions on the Website, which, if required to be accessed, are accessible only by the authorised personnel of FlexiPayment. However, as You are aware, no internet site is completely free of security risks and We do not make any representation in respect of the same.

We do not warrant that Our Website or any electronic communication made by Us is free from virus or other harmful effects. In the event of any errors in transmission or due to an act of a third party, we shall have no liability. You explicitly agree that Your use of the Website and/or services provided by Us is at Your own individual risk. You agree and confirm that Your User Information may be transferred, processed and stored. You hereby confirm that You have been made aware of the security measures undertaken by Us and You expressly consent to Us storing, handling, using Your User Information.

8.0          Blogs and other Forums on the Website

If You use a bulletin board, blog or chat room on the Website, you should be aware that any information You submit there can be read, collected or used by other users and could be used to send You unsolicited messages. We are not responsible for Personal Information You choose to submit in these forums. These forums may be hosted by FlexiPayment or by one of Our third party service providers or featured individuals or organisations on FlexiPayment’s behalf.

9.0          Change in Privacy Policy

We reserve the right to update, modify and amend any of the terms of Our Privacy Policy, at anytime without prior intimation to You. We will post these changes on the Website for Your information. These changes will become effective immediately on posting. We shall not be liable for any failure or negligence on Your part to review the updated Privacy Policy before accessing or availing the Website. Your continued use of the Website, following changes to the Privacy Policy, will constitute Your acceptance of those changes.

10.0        THIRD PARTY LINKS:

During your interactions with us, it may happen that we provide/include links and hyperlinks of third-party websites not owned or managed by us (“Third-party Websites”). It may also happen that you or other users may include links and hyperlinks of Third-party Websites. The listing of such Third-Party Websites (by you, other users or by us) does not imply endorsement of such Third-party Websites by FlexiPayment. Such Third-party Websites are governed by their own terms and conditions and privacy policies and when you access such Third-party Websites, you will be governed by the terms and policies of such Third-party Websites. You must use your own discretion while accessing or using Third-party Websites. We do not make any representations regarding the availability and performance of any of the Third-party Websites. We are not responsible for the content, terms of use, privacy policies and practices of such Third-party Websites. We do not bear any liability arising out of your use of Third-party Websites.

11.0        Compliance with Laws:

You are not allowed to use the services of the Website or Application if any of the terms of this Privacy Policy are not in accordance with the applicable laws of your country.

12.0        Contacting Us

If You have any questions about (i) this Privacy Policy; (ii) practices of this Website, or (iii) Your
dealings with this Website or believe that We have not adhered to it, you may contact
info@FlexiPayment.in.

 

13.0        Email Opt-Out

You can opt out of receiving our marketing and update emails. To stop receiving our promotional emails, please email to marketing@FlexiPayment.in. It may take about 7-10 days to process your request.

14.0        Data Wipe-out

You may at any time seek complete “Wipe-out” of your data / information with FlexiPayment. We shall action your request within 7 working days – except for the data which is required to be maintained for any regulatory or Legal requirements. To request for data wipe-out, please email to marketing@FlexiPayment.in.

15.0        Revoking the Consent for “Collection of Data”

You may at any time revoke your consent for “collection of data” by FlexiPayment. We shall action your request within 7 working days. This action shall apply only to future collection of data. Data which is already collected previously shall still remain in our data base/servers/record. In case you wish to completely wipe-out the previously collected data, please refer to section titled – “Data Wipe-Out”.

To revoke your consent for data collection, please email to marketing@FlexiPayment.in.

<<XX>>