PayO - All-in-one digital banking and accounting platform

Privacy Policy

Effective Date: 1st March 2020
Last updated: 8th May 2020

Introduction

We place our highest value on your trust and put top priority on protecting your information and your fundamental right towards privacy and this privacy policy describes the information we collect from you, how we use and process that information and our legal basis for doing so in relation to our services.

This Privacy Policy applies to www.payobank.in ("Website"). The Website is owned or controlled by Cubereum Technologies Private Limited ("Owner"). This Privacy Policy only covers information collected at the Website. This Privacy Policy may apply to the information that Owner collects offline, but only if specifically stated at the time of collection or if the information is combined in our databases. Please review this Privacy Policy carefully. In addition, please review our Terms of Use, which governs your use of the Website.

By using the Website, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms of Use.

We fully describe our privacy practices below in this Privacy Policy.

BY VISITING THIS WEBSITE YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE PLEASE DO NOT USE, REGISTER OR ACCESS OUR WEBSITE.

  1. Scope
    1. This Privacy Policy (“Policy”) is an electronic record in the form of an electronic contract formed under the Indian Contract Act, 1872 and this Privacy Policy is published in accordance with the provisions of the Indian Information Technology Act, 2000 and the rules made thereunder, specifically, The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal data or information) Rules, 2011 and the Information Technology (Intermediary Guidelines) Rules, 2011. This Policy does not require any physical, electronic or digital signature. This Policy is a legally binding document between you and the Owner.
    2. We collect and process your personal and third party information carefully, only for the purposes described in this Policy and only to the extent necessary as defined herein and within the scope of the applicable legal regulations. This Policy seeks to ensure that any personal information or third party information handled by us is managed in a way that is ethical, compliant and adheres to best industry practices.
    3. This Policy describes our current data protection policies and practices and may be amended/updated from time to time. Any changes to this Policy will become effective upon posting of the revised Policy on our Website. We suggest that you regularly check this Policy to apprise yourself of any updates. Your continued use of Website or provision of data or information thereafter will imply your unconditional acceptance of such updates to this Policy.

  2. Giving your consent
    1. By mere use of the Website, you expressly consent to our use and disclosure of your Personal Information (as defined below) and third-party information in accordance with this Policy.
    2. The Website may contain content served by third parties, including videos and advertisements, and we work with third party service providers to serve the Owner advertisements elsewhere online. In connection with serving content and providing analytics and advertising services, third parties may collect certain information about your visits to this or other web sites and we may receive information regarding the use of the Website and the effectiveness of our advertisements. We do not share Personal Information with these third parties, but the advertising networks, advertisers, ad agencies, analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you (such as your general interest in certain book genres).
    3. We do not share your Personal Information (information that identifies you as a specific individual, including but not limited to your full name, email address, payment details or street address) with third parties for their marketing purposes without your consent, however, we may share your Personal Information under certain limited circumstances.

  3. What does information mean
    1. Personal Information: Information for purpose of this policy shall include, but not limited to the following:
      1. Personal information retrieved during sign up on the Website such as your first name, last name, entity’s name, contact details, address, e- mail address, financial information details, tax related information inter alia Goods and Service Tax identification number, Aadhaar details and Permanent Account Number.
      2. Your user-id and password details in connection with the account login process. We shall reserve the right to reject usernames that are offensive or are found to be unsuitable by us, at any point of time.
      3. If you transact through us, we collect some additional information, such as a billing address, sensitive information such as account and purchase information, details of user’s customers and vendors, financial data of the business entity, sales invoice details, purchase bills, bank account details, a credit / debit card number, a credit / debit card expiration date and other payment instrument details.
      4. If you choose to post messages on our message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide user support and troubleshoot problems as permitted by law.
      5. Details of any requests or transactions made by you through the Website; and
      6. IP addresses, browser and operating system specifications, location etc.

    2. Non-Personal Information: Non-personal Information means information that does not specifically identify an individual or business, but includes information from you, such as your browser type, the URL of the previous websites you visited, your Internet Service Provider (ISP), operating system and your Internet Protocol (IP) address. We may gather any Non-Personal Information regarding how many people visit this Website, the pages they visit, their IP address, and the type of browser they use while visiting the Website (“hereinafter referred to as “Non-Personal Information”). We may also collect Non-Personal Information that you voluntarily provide, such as information included in response to a questionnaire or a survey conducted by us.
    3. Personal Information, Non-Personal Information and third-party information hereinafter shall be referred to as “Information”.

  4. How to collect and receive information
    1. We may collect information from you when you (i) register as a user on the Website; (ii) update or change personal details in your account; (iii) download or update software; (iv) transact through our Website by using our services listed on the Website; and (v) open a bank account through our Website.
    2. We and our business partners may use cookies to monitor the Website usage including, without limitation, to provide useful features to simplify your experience when you return to the Website, like remembering your login id, Personal Information and third-party information and to deliver relevant content based on your preferences, usage patterns and location.
    3. We may also collect Non-Personal Information based on your browsing activity and in relation to your use or access to the Website like your browser type, your Internet Protocol address, your Operating System, your prior search results etc., which may or may not be publically accessible.
    4. Information collected by us from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected. Personal Information is also collected through social media platforms, from solicited and unsolicited communications, responses to promotional and other materials, among others.
    5. If you choose to import contacts from your email account, including to invite those contacts to use the service on our Website, we will collect the username and password for the linked email account, as well as the contact information of your contacts. We will only use this information for the purposes for which it is shared by you
    6. Details of any requests or transactions made by you through the Website; and
    7. IP addresses, browser and operating system specifications, location etc.

  5. How we use this information
    1. We may use the Information you provide to fulfil your requests for our services, to respond to your inquiries about our offerings, and to offer you other programs or services that we believe may be of interest to you.
    2. We use the Information about others to enable us to procure information about them. From time to time, we also may use this information to offer our programs and services to them.
    3. We may use the Information to monitor your use of the services and may review and analyse the Information provided by you to provide you with customized service.
    4. We may use your Non-Personal Information for internal business purposes, such as data analysis, research, developing new campaigns, enhancing and improving existing services and in identifying usage needs.
    5. We may use the Information that we collect about you to market the service to you, and to communicate with you about our products or features, that may be of interest to you. If we send you a marketing email, we will provide you with information on opting out of future marketing emails or communications from us. We may also use the Information about you for our marketing purposes, including to identify other similar prospective customers who may be interested in our services.
    6. We may use the information that we collect about you as required or permitted by applicable law. Such uses include but are not limited to compliance with anti-money laundering, anti-terrorism laws and “know your customer” regulations.

  6. How we share this information
    1. We may share your Personal Information and usage data, with our banking partners and third party service providers who perform various functions to enable us to provide our services and help us operate our business, such as website design, sending email communications, customer care, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and under our instructions, and not use Personal Information for purposes other than the product or service they are providing to us or on our behalf.
    2. We may share Personal Information with our other corporate entities and affiliates to help detect and prevent identity theft, fraud and other potentially illegal acts; correlate related or multiple accounts to prevent abuse of our services; and to facilitate joint or co-branded services that you request where such services are provided by more than one corporate entity.
    3. We may disclose your Personal Information if required to do so by law or in good faith if such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose Personal Information to law enforcement offices, third party rights owners, or others in good faith if such disclosure is reasonably necessary to enforce our Terms of Use or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public.
    4. We and our affiliates will share some or all of your Personal Information with another business entity should we (or our assets) plan to merge with, or be acquired by that business entity, or in case of re-organization, amalgamation, restructuring of business.

  7. Retention of your personal information
  8. We retain your Personal Information as long as the purpose for its usage exists, after which the same is disposed off by us except for any record retention required as per the Banking Companies (period of preservation of records) rules, 1985 and/or the Prevention of Money-Laundering (Maintenance of Records) Rules, 2005 or any other applicable law in force. The PMLA (Prevention of Money Laundering Act 2002) guidelines i.e. section 12, sub-clause nos. 3 and 4 and PPI guidelines -para 6, sub-clause no. 6.3 require your transaction logs to be stored for a period of up to 10 years post the deletion of an account. In the event of the pendency of any legal/regulatory proceeding or receipt of any legal and/or regulatory direction to that effect, we may be suggested by the law of the land to retain your Personal Information for longer periods.

  9. Cookies
  10. To enhance your experience with our Website, many of our web pages use "cookies" .Cookies are text files we place in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information unless you choose to provide this information to us by, for example, registering on our Website. However, once you choose to furnish the Website with personally identifiable information, this information may be linked to the data stored in the cookie. We use cookies to understand site usage and to improve the content and offerings on our Website. For example, we may use cookies to personalize your experience on our web pages (e.g., to recognize you by your name when you return to our Website), save your password in password- protected areas, and enable you to use various features on our Website. We also may use cookies to offer you products, programs, or services.

  11. How we use your payment details
  12. When you use our services to make or receive payments, we may collect information from you such as details of credit/debit cards, verification of bank account ownership, NEFT, RTGS, Net banking and/ or UPI details, information that you submit while transacting on the Website which goes through the safe and secure transaction process provided by our banking partners which only include the most trusted banking partners in India. Furthermore, you will also be taken through a 3D secure verification such as "Verified by Visa" or “Master Card 3D Secure” password protected process to prevent any misuse of your debit/credit cards.

  13. Minor
  14. We do not intend to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. We do not intentionally or knowingly collect Personal Information through the Website from anyone under that age. We encourage parents and guardians to be involved in the online activities of minor to ensure that no personal information is collected from a minor without their prior consent.

  15. Limitation of liability
    1. We shall not be liable to you for any loss of profit, production, anticipated savings, goodwill or business opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive, exemplary or consequential losses arising out of performance or non-performance of its obligations under this Policy.

    2. At any point of time, our liability for any loss arising from a particular transaction carried out by you on the Website shall not exceed the consideration paid by you to us for that particular transaction.

    3. Notwithstanding anything contained in this Privacy Policy or elsewhere, we shall not be held responsible for any loss, damage or misuse of your personal information, if such loss, damage or misuse is attributable to a Force Majeure Event. “Force Majeure Event” shall mean any event that is beyond the reasonable control of us and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, unauthorised access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided beyond reasonable control of us), power or electricity failure or unavailability of adequate power or electricity.

  16. Opt-out
  17. We provide all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us on behalf of our partnering banks, and from us in general, after setting up an account. All users are also given the option of cancelling/deleting their user accounts and bringing to our attention their desire to discontinue the use of our services. If you want to remove your Personal Information from the Website and our newsletters, please send us an email at info@payobank.in. Even if user opts-out, we reserve a right to notify you about your existing account.

  18. How we protect your information
    1. We have taken adequate measures to protect the security of Information and to ensure that your choices for its intended use are honoured. We take robust precautions to protect your data from loss, misuse, unauthorised access or disclosure, alteration, or destruction.

    2. We consider the confidentiality and security of your information to be of utmost importance. It therefore uses industry standards, and physical, technical and administrative security measures to keep Information confidential and secure and we will not share your Information with third parties, except as otherwise provided in this Policy. Please be advised, however, that while we strive to protect Information and privacy, we cannot guarantee or warranty its absolute security when Information is transmitted over the internet into the Website. We will annually evaluate this necessity considering your privacy and our relation while keeping the applicable legislation in mind. Non-Personal Information will be retained indefinitely.

  19. Link to third party sites
    1. Links to third-party advertisements, third-party websites or any third party electronic communication service may be provided on the Website which are operated by third parties and are not controlled by, or affiliated to, or associated with us unless expressly specified on the Website.

    2. We are not responsible for any form of transmission, whatsoever, received by you from any third party website. Accordingly, we do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such third party websites, nor do we control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such third party websites. The inclusion or exclusion does not imply any endorsement by us of the third party websites, the website's provider, or the information on the website. The information provided by you to such third party websites shall be governed in accordance with the privacy policies of such third party websites and it is recommended that you review the privacy policy of such third party websites prior to using such websites.

  20. Changes to this policy
  21. We reserve the right to update, change or modify this Policy at any time. The Policy shall come to effect from the date of such update, change or modification.

  22. Grievance officer
  23. In accordance with the Information Technology Act, 2000 and Rules made thereunder, the name and contact details of the Grievance Officer are provided below:

    Name: Pratik Mundra
    Address: 175&, 176, Bannerghatta Main Rd, Dollars Colony, Bengaluru, Karnataka 560076
    Contact: +91-8618292495
    Email ID: info@payobank.in

  24. How to contact us
  25. If you have additional questions or concerns about this Policy or want to make any request or suggestions regarding certain Personal Information, please contact us at info@payobank.in.