PRIVACY POLICY

THIS PRIVACY POLICY IS AN ELECTRONIC RECORD IN THE FORM OF AN ELECTRONIC CONTRACT FORMED UNDER THE INFORMATION TECHNOLOGY ACT, 2000 AND THE RULES MADE THEREUNDER AND THE AMENDED PROVISIONS PERTAINING TO ELECTRONIC DOCUMENTS/ RECORDS IN VARIOUS STATUES AS AMENDED BY THE INFORMATION TECHNOLOGY ACT, 2000. THIS PRIVACY POLICY DOES NOT REQUIRE ANY PHYSICAL ELECTRONIC OR DIGITAL SIGNATURE. THIS PRIVACY POLICY IS A LEGALLY BINDING DOCUMENT BETWEEN YOU AND ITSL (BOTH TERMS DEFINED BELOW). THE TERMS OF THIS PRIVACY POLICY WILL BE EFFECTIVE UPON YOUR ACCEPTANCE OF THE SAME (DIRECTLY OR INDIRECTLY IN ELECTRONIC FORM), BY CLICKING ON THE I ACCEPT TAB OR BY USE OF THE APP AND WILL GOVERN THE RELATIONSHIP BETWEEN YOU AND ITSL FOR USE OF THE APP (DEFINED BELOW). THIS DOCUMENT IS PUBLISHED AND SHALL BE CONSTRUED IN ACCORDANCE WITH THE PROVISIONS OF THE INFORMATION TECHNOLOGY (REASONABLE SECURITY PRACTICES AND PROCEDURES AND SENSITIVE PERSONAL DATA OF INFORMATION) RULES, 2011 UNDER INFORMATION TECHNOLOGY ACT, 2000; THAT REQUIRE PUBLISHING OF THE PRIVACY POLICY FOR COLLECTION, USE, STORAGE AND TRANSFER OF SENSITIVE PERSONAL DATA OR INFORMATION.

Paytrack (hereinafter referred to as “App”) is an application developed and owned by India Transact Services Limited (hereinafter referred to as “ITSL”) a company incorporated under the provisions of the (Indian) Companies Act, 1956 and having its registered office address at 601 – 602, B – Wing, Trade World, Kamala City, Kamala Mills Compound, Senapati Bapat Marg, Lower Parel (W), Mumbai – 400 013. This Privacy Policy shall be part of terms and conditions mentioned in this App (Insert hyper link).

ITSL is concerned about the privacy of the data and information of users (including merchants and buyers/customers whether registered or non-registered) accessing, offering, selling or purchasing products or services on ITSL's App, and otherwise doing business with ITSL. Through this Privacy policy ITSL disclose to the users of this App the mode of utility of information of users of the App or for use of services mentioned in the App. Please read the following statements to learn about our information gathering and dissemination practices.

ITSL is committed to protecting the confidentiality and integrity of Personal Information (as defined below) about you that we collect, use, or disclose or otherwise Process (as defined below), including Personal Information to which ITSL has access in connection with the provision of products and services to our customers (in this Privacy Policy, “you” includes any individual about whom ITSL collects, uses, or discloses Personal Information). ITSL takes reasonable and appropriate steps to safeguard this information in accordance with the applicable laws of the countries in which we conduct business and our contractual requirements.

Scope of this Privacy Policy

This Privacy Policy applies to any Personal Information that ITSL collects, uses, or discloses regardless of how or where that information was obtained, or where it is stored or used, unless otherwise noted either in this Privacy Policy, in a supplement, or in a separate policy that we make available to you.

Definitions

“Account” means Paytrack account or any account with the App from time to time.

“Contract Data” means to include Personal Information about you and your customers or your personnel that ITSL Processes in connection with providing products and services to a customer under a customer contract.  Contract Data is a subset of “Personal Information.”

“Personal Information” means information relating to an identified or identifiable natural person to the extent such information is afforded the protection of law. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural, or social identity.

“Process” means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure, or destruction.

Collection of Personal Information

The Personal Information ITSL may collect about you includes, but is not limited to, the following:

  1. Your user IDs and passwords; demographic information; contact details, such as your name, age, gender, address, email address, or telephone number; PIN Code, geo-location data; or education data relating to your occupation, payment card details and any proof of your identity and/or address that we may request.
  2. Details of any transactions you carry out through our App using your Account and of the fulfillment of your requests.
  3. Details of any bank account (including but not limited to, account holder, account name, account number, Transaction Authentication Number "TAN", available balance and transaction history of your bank account), ITR, TAX certificates or any other income documents as necessary by us.
  4. Details of any credit, debit or other card used by you for transactions.
  5. Your participation in any promotion sponsored by us.
  6. Correspondence that you send us.
  7. Calls that we make to you or you make to us.
  8. Surveys that you complete through the App or based on our request.
  9. Information collected through cookies.
  10. Your IP address, log-in times, operating system and browser type.
  11. Details of your visits to our App including, but not limited to, traffic data, location data, logs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access whilst using our App.
  12. Any other items of 'sensitive personal data or information' as such term is defined under the Information Technology (Reasonable Security Practices And Procedures And Sensitive Personal Data Of Information) Rules, 2011 enacted under the Information Technology Act, 2000; and
  13. Such Personal Information may be collected in various ways including during the course of you.

You may provide Personal Information to ITSL in a variety of ways, which includes ways such as by registering for an on-line account or event, joining a mailing list, purchasing a product or service, applying for employment, filling out an information form, or otherwise contacting us with a question, comment, or request. Additionally, ITSL may collect information about you or obtain Personal Information from third parties. ITSL may also use certain technologies to collect information about you while you are visiting an ITSL website or using our App.

With respect to Contract Data, it is your responsibility to ensure that ITSL‘s collection and processing of their customers’ Personal Information is consistent with the terms of such customers’ own privacy policies.

Use of Personal Information

ITSL will use Personal Information covered by this Privacy Policy in a manner that is consistent with applicable law and that is reasonably necessary to fulfill its business needs, including facilitating ITSL’s compliance with regulatory and legal requirements. ITSL may combine Personal Information it obtains about you from various other sources to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with you. ITSL will retain Personal Information only for so long as it is helpful to support the overall purpose(s) for which ITSL has collected the information. ITSL’s use may include, but is not limited to, making sales calls, sending marketing communications, delivering or completing requested services or transactions, and analyzing a series of transactions.

ITSL will use Contract Data consistent with applicable contractual obligations and applicable law.  ITSL also may use Contract Data to facilitate compliance with regulatory and legal requirements.

In addition to the aforesaid ITSL may use Contract Data and Personal Information for (1) To operate and administer your Account and to provide services that you have requested (2)To carry out your instructions to make and receive payments and undertake transactions using our services, including verifying that you have sufficient funds in your Account to make payments for the goods purchased/ services received by you (3) To allow you to participate in interactive features of the App (4) To notify you about changes to our service(s) (5) To improve our internal customer training (6) To comply with financial services regulations including retention of financial information and transactions (7) For financial and identity checks, fraud prevention checks, anti-money laundering and credit checks (8) For customer service, including answering questions and responding to feedback and complaints (9) To enhance the security of our Services (10) To ensure that content on our App is presented in the most effective manner for you and for your handheld device (11) To personalise your experience on the App by presenting advertisement, products and offers tailored for your preference (12) To improve the services, content and advertising on the App (13) To facilitate various programmes and initiatives launched by ITSL or with its third party service providers and business associates, and (14) To provide you with information, products or services that you request from us or which we feel may interest you.

Data Retention

We are required under applicable laws to retain certain records for a period of at least 5 (five) years after closure of your Account or till such time as is required by applicable law, whichever is longer and will include your personal data such as your name, contact details, customer number and transaction history, and such other data as may be required. ("Retained Data"). Other than the Retained Data, we will delete and destroy all Personal Information that we hold about you when you (or we) terminate your Account. We do not store your online banking login PIN, TAN, password and or your credit card information.

Please note that we will never ask you to disclose your personal or security details by e-mail or sms. If you receive any e-mail/sms purportedly from Account requesting your personal or security details, please do not respond to such communications. Please forward any Such E-mail/ sms to us and thereafter delete the e-mail/ sms immediately.

Sales and Marketing: ITSL may use your Personal Information for sales and marketing purposes, including contacting you for feedback in customer satisfaction surveys or for market research purposes, providing you with marketing literature on products and services, notifying you of events, and providing you with information about ITSL. From time to time, ITSL may co-brand an offering or a communication with a third party, which may also collect your Personal Information or with whom we may share it.  In such cases, the use of your Personal Information by such third parties is covered by their respective privacy policies, and not this Privacy Policy. If those cases where you choose to forward a page to another individual (where such option is available), ITSL may request certain Personal Information about that individual to complete your request, such as their name and e-mail address.

Social Networking Tools: If ITSL uses social networking tools to provide information to you, your information will be governed by the terms of use and the privacy policy for the applicable social networking tool.

Fulfilling Business Transactions: ITSL may use your Personal Information to fulfill business transaction requests with you or your organization. With respect to our customers, such requests may include, but are not limited to, providing products or services, such as delivering notifications of product fixes and updates, or contacting you in response to your questions, comments, or requests. With respect to our suppliers, such requests may include issuing purchase orders, receiving invoices, or providing other information such as forecasts. If, in providing support (including support to assist you with the use of our App), we engage you telephonically through tools such as online chat, we may monitor or record our interaction for purposes of quality assurance, training, or to document the details of a transaction.

Recruitment.If you seek employment with ITSL, you may provide us with information about yourself in many ways including through a resume. We may use this information throughout ITSL in order to consider you for employment purposes, and may keep your information on file for future consideration and to support ITSL’s compliance with applicable legal requirements

Disclosure of Personal Information

We may share Personal Information (including Contract Data) within ITSL and transfer it to countries around the world in which we operate in connection with the uses described in this Privacy Policy and in accordance with its terms.

We may share Personal Information with third-party suppliers and service providers that help us Process Personal Information.

ITSL also may provide information that identifies you at an individual level to third-party business partners. ITSL does not, however, sell or rent such information to these third parties.

From time to time, ITSL may contemplate entering into various business development activities which may include the sale, purchase, merger, or reorganization of one or more of its businesses.  These business development activities may require the disclosure of Personal Information to the prospective or actual purchaser(s). When such disclosures are required, ITSL will seek appropriate protections of your Personal Information.

We also reserve our right to use or provide your Personal Information to third parties, including law enforcement, judicial proceeding, court order, subpoena, auditors, consultants, and government officials, to protect ITSL’s rights or property, and/or the rights or property of our customers, business partners, suppliers, or other third parties.

We also use Information in aggregate form for marketing and strategic development and for audit of usage of App.

Use of Cookies and other Technologies

As described in more detail below, ITSL App may employ a variety of tools to help us improve your experience on our App and determine the effectiveness of certain of our marketing initiatives.

Cookies. A cookie is a small element of data that a App can send to a Web browser, which is then stored on the browser user’s computing device/ handheld device. We may use cookies, alone or in combination with other data we may collect from other technologies (such as server logs) to make our App work or operate more efficiently, to personalize a user’s experience, or to make our App more useful to our visitors.

Other Technology ITSL may use to improve your Experience. ITSL may also use other technology to improve your experience.

Log File Information: ITSL records log file information whenever you access our App. Examples of log file information include your IP address, your browser type, the page from which you accessed our App, the pages you viewed while visiting our App, the last page you viewed before you exited our App, and the page you accessed after leaving our App. We use this data in the aggregate and do not use it to identify you individually.

Web Beacons: This Privacy Policy covers web beacons placed by ITSL. A web beacon is an electronic (and usually transparent) image that is placed on a App.  Web beacons recognize certain information on your device such as cookies, the time and date of a page you viewed and the length of time you viewed the page, the IP address of the device that retrieved the image, the time the web beacon was viewed and for how long, and the type of browser that retrieved the image.  We may use web beacons, for example, to determine whether you have opened, or accessed links included in, a marketing communication from ITSL. Web beacons often work with cookies; therefore, if you do not want us to associate your cookie information with your visits to our App, you must turn off cookies in your browser.

Web Links: This App may contain links that are designed to take you to a third party web page after redirection through ITSL’s servers (or those of its suppliers). We use the information we obtain during the redirection process to determine whether a particular marketing initiative is effective, and may collect information connected to your identity. Such third party sites are governed by their respective privacy policies, which are beyond our control. Once you leave our servers, use of any information you provide is governed by the privacy policy of the operator of the third party site you are visiting. That policy may differ from ours. If you can't find the privacy policy of any of these sites via a link from the site's homepage, you should contact the site directly for more information. ITSL does not assume any liability, responsibility or obligation by virtue of you using web links of third parties.

Local Shared Objects (“Flash Cookies”): ITSL may use Adobe Flash Player® to deliver multimedia content, such as a video, to you.To improve your user experience, ITSL may use Flash local shared objects (LSOs) – sometimes called “flash cookies” – to store your flash content information and preferences, similar to other types of cookies ITSL employs. 

Online Advertising: Third parties may advertise on ITSL’s App, however, ITSL does not assume any obligation or responsibility on behalf of such third parties in any manner. ITSL may also contract with third parties who collect information about your online activities over time and across different sites (including ITSL websites and App). We engage with these third parties to help us deliver targeted advertisements about ITSL on other sites you visit. These third parties use cookies or web beacons across multiple sites, including ITSL’s web sites and App, to collect certain information about you to provide you with targeted ads based on your interests. Your name, address, and other contact information are not collected.

Protection of your Personal Information

ITSL takes data security seriously. We have implemented reasonable and appropriate physical, technical, and organizational measures that are designed to protect Personal Information covered by this Privacy Policy, including Contract Data, from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. ITSL is not responsible for, nor can it guarantee, the security of any Personal Information transmitted over the Internet. There is no guarantee that Personal Information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational measures. It is your responsibility to protect the security of your login information.

Children’s Information

ITSL’s applications and App are not directed to, nor do we knowingly collect Personal Information from, children under the age of 18. By your use of our App you affirm that you are at least 18 years of age. ITSL does not knowingly solicit data from or market to children under the age of 18. If you are a parent or a guardian, and you believe your child has provided ITSL with Personal Information without your consent, please contact us. ITSL absolves itself from any liability, damage, harm or loss, if the children falsely represent as being over the age of 18.

Changes to this Privacy Policy

As we will attempt to constantly upgrade our App, the Terms and Conditions and Privacy Policy will appropriately change. To be abreast about the latest Terms and Conditions and Privacy Policy, we expect that you check and visit our App frequently. 

Security Checks, Review and Releases

transactions and further document your consent to this Agreement. To facilitate these security checks, you agree to provide such identification or other information or documentation as we, in our sole and unfettered discretion, deem necessary. If you fail to comply with any security request, we reserve the right to void your account if any with us. You will be notified of such verification request by e-mail or telephone and your account balances with us will be forfeited if you fail to provide us with such requested documentation and information within the time period reasonably specified by us. Such request for documentation and information may include a sworn affidavit of identity and eligibility, release of liability in favour of us and publicity authorization.

User choice & Prohibitions

You may choose not to provide us with any Personal Information while accessing the App. In such an event, you can still access much of the App subject to terms of the terms and conditions of this App; however you will not be able to access and use those portions of the App that require your Personal Information.

Further to protect your privacy, safety and safety of other users of this App you shall not to host, display, upload, modify, publish, transmit, update or share any information that —

  1. belongs to another person and to which the you does not have any right to;
  2. is grossly harmful, harassing, blasphemous defamatory, obscene, pornographic, pedophilic, libelous, invasive of another's privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever;
  3. harm minors in any way;
  4. infringes any patent, trademark, copyright or other proprietary rights;
  5. violates any law for the time being in force;
  6. deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;
  7. impersonate another person;
  8. contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource;
  9. threatens the unity, integrity, defense, security or sovereignty of India, friendly relations with foreign states, or public order or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting any other nation

App posting made by you

Any information that you may reveal in a review posting or other online discussion or forum is intentionally open to the public and is not in any way private. You should think carefully before disclosing any personally identifiable information in any public forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.

Confidentiality and Security

Except as otherwise provided in this Privacy Policy and Terms and Conditions, we will keep your Information private and will not share it with third parties, unless we believe in good faith that disclosure of your Information or any other information we collect about you is necessary to (1) comply with a court order or other legal process (2) Protect the rights, property or safety of ITSL or another party (3) Enforce our Terms and conditions or (3) Respond to claims that any posting or other content violates the rights of third parties.

Reporting phishing attempts

Phishing is the name given to attempts to steal personal details and financial account details from a user. "Phishers" use fake or "spoof" emails to lead users to counterfeit websites where the user is tricked into entering their personal details, such as credit card numbers, user names and passwords.

If you receive such an e-mail or are asked for your password by anyone claiming to work for us do not respond to such emails and forward such e-mail(s) or report the incident by e-mail to us.

Contacting us

We want to address any concerns you may have. You may send any comments or questions regarding this Privacy Policy or ITSL’s handling of your Personal Information by email to India Transact Services Limited, or by mail to:
India Transact Services Limited
Attn:
601 – 602, B Wing, Trade World,
Kamala City, Kamala Mills Compound,
SenapatiBapatMarg, Lower Parel (W),
Mumbai – 400 013.
Working days: Monday to Friday
Working hours: 9:30 am to 6:00 p.m.
We will endeavor to address your feedback and concerns in a timely and effective manner.