The mobile application CHEQ and all other associated/ancillary applications, products, and services (“Platform”) are property of and managed by CheQ Digital Private Limited, a company incorporated under the Companies Act, 2013 having their registered officeaddress at D-254, Regal Garden, Sector 90 Gurgaon, Haryana 122001 (hereinafter referred to as "Company” which expression shall, unless it be repugnant to thecontext thereof,bedeemed to include permitted successors and assigns). For the purposes of Privacy Policy, accessing of and/or using the Platform to avail various offers and services as provided on the app or accessing the credentials and/or information of the offers made available or disseminated or uploaded therein,including all information,tools and services made available shall hereinafter be collectively be referred to as the “Services". As used herein, “Users” shall mean anyone who uses or accesses the Services /Platform on any mobile phone, tablet, console or other device (hereinafter collectively referred to as “Device”). You are encouraged to read this Privacy Policy regarding the collection, use, and disclosure of your information from time to time to keep yourself updated with the changes & updates that are made to this Policy. This Privacy Policy describes our privacy practices for all products and services that are linked to the Platform. However, this policy does not apply to those affiliates and partners that have their own privacy policy. In such situations, we recommend that you read the privacy policy on the applicable site. By accessing or using any version of the mobile platforms, you signify that you have read, understood and agreed to be bound by this Privacy Policy of the Company and any other applicable law. This Policy forms an electronic contract within the provisions of the Information Technology Act, 2000 (“IT Act”), the rules made thereunder and the amended provisions pertaining to electronicdocuments/records in various statutes as amended by the IT Act,from time to time. This Policy does not require any physical, electronic or digital signature. This Policy shall, at all times be read and construed in consonance and along with the terms and conditions of use and access of the App Platform (“T&C”). The Company shall not differentiate between who is using the device to access the App, so long as the log in/access credentials match with yours. In order to make the best use of the Platform and enable your Information to be captured accurately on the Platform,itisessential that you have logged in using your own credentials. This Policy highlights inter alia the type of data shared/collected from a User in the course of the User’s usage of the Platform. The Policy further intends to apprise the User of the purposes for which the data of the User is collected and the Platform’s policy with regard to sharing such personal information with third party entities. The terms “We”/ “Us”/ “Our” individually and collectively refer to and are synonymous with the term ‘the Company’ and the terms “You”/“Your”/ “Yourself” are to be construed to be synonymous with the term ‘User’. All defined terms used within this Policy but not specifically defined herein shall draw their meaning from the definition ascribed to such term under the T&C.
COLLECTION OF INFORMATION
a)
Personal Information:
Name of the User;
National ID proof with photo
Phone number (mobile and/or residence and/or alternative) of the User;
Gender of the User;
Date of birth of the User;
Address (official/residence/other) of the User;
Email Id (primary/alternative) of the User;
Personal information received from social networking sites through which the User has registered to the Website/Platform including name, profile picture, email address or friends list, and any information made public in connection with that socialmedia service;
Internet protocol (IP) address of the User; and
Sensitive personal data such as App passwords and payment details.
b)
Non-personal information:
Details of internet or telecom service provider of the User;
Geolocation of a User;
Type of internet browser being used by the User and device specifications including Device ID and
Usage and behaviour statistics on the application
Such other information that may be required to access and operate the mobile application.
c) Please note that in addition to the above, the duration of use of the Platform by the User may also be logged and stored by the platform.
d) The Information maybecollectedand/orstoredinelectronicform,however,theCompany is hereby authorized by the User to collect/store such information in physical form as well.
e) The platform may share the Information of a User with any third party entities subject to such entities adopting reasonable safety standards with respect to the use of such Information. Provided the Company shall not share or disseminate any financialsensitive information of the User and shall ensure the utmost protection and safety of such data.
f)
Information received from third parties
The Platform is offering the credit repayment services to the Users. Theeligibilityof theusersisbasedonthecreditproducts.Theusershouldbeholdingatleastonecredit productforusingthefacilitiesofferedbyCheQ.Inordertoevaluatetheeligibility,the user is requested to provide explicit consent to the Company for collection of such information from our partners.
If you choose to link and connect your email account with the Platform, we may access the said account for purposes including collecting your credit bill details such as total amount due, minimum amount dueandduedate,andsuchotherfinancialand transactional information to be able to do the following:
Provide an insight into your spending pattern(s) to ensure you are aware of your spending and can make wiser decisions basis the same; and
Curate specificfinancial/investment/otherproductsforyoubasedonyourfinancial transactions, investments, and past financial behaviour;
Curate offers and rewards customised for you;
Manage all your credit information at one place including reminding you of the payment due before the due date.
The Company’s access to the SMS and email account(s) is authorized through the email provider’s access mechanism. If you permit the Company’s app to track your credit Instruments’ accounts, the app will securely store account details for each of your credit Instruments’ accounts, including your sign-in user name and authorisation tokens for tracked accounts. Further you can also permit the Platform/Application to read SMSs on android phones for the purpose of auto-detecting OTPs for payments. You can choose to enable us to access one or more of your email accounts by explicitly providing consent to each account separately.Please note that your consent to any of the above is purely voluntary. You can de-link the access to your emailand/or SMS service any time you wish. We only read emails from financial service providers including banks, loan providers and credit card issuers and do not open, read or access any personal emails. We hereby confirm that we do not access any other personal information. For the sake of clarity, the Company employs automated processes for accessing and analysing information provided by you; where we may need to use our algorithm to access a password-protected document utilizing information provided by you. We may receive additional information about you, such as information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. We may receive information about you and your activities through partnerships, or about your experiences and interactions from our partner ad networks
REPRESENTATION AND WARRANTIES
Every User hereby represents and warrants to the Company that:
All Information provided by the User is true, correct, current and updated;
All Information provided by the User and the provision of such Information by the User does not in any manner violate any third-party agreement, law, decree, order or judgement;
All Information provided by the User does not belong to any third party, and if it does belong to a third party,the User is duly authorized by such Third Party to use,accessand disseminate such Information;
The officers, directors, contractors or agents of the Company shall not be responsible in any manner whatsoever with regard to the authenticity or veracity of the Information that a User may provide to the Platform; and
The User shall indemnify and hold harmless the Company and each of its officers, directors, contracts or agents and any third party relying on theInformationprovidedby the User in the event the User is in breach of this Policy.
The Company represents and warrants to every User that:
It shall not collect the User’s sensitive personal data unless such sensitive personal data is necessary for the usage of the App.
It shall not retain any sensitive personal data for longer than such sensitive personal data is required or can be lawfully used;
In the event the Company collects Information directly from the User,theCompany shall make reasonable effort to apprise the User of the purpose of such collection of Information, the intended recipient of the Information and the details of the agencies collecting and retaining the Information; and
It has in place the security practices and procedures prescribed under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (“IT Rules”).
PURPOSE AND USE OF INFORMATION
All Information collected/stored by the Platform shall be used for:
Curating various personalised offers for the User
Keeping track of the User Expenditure to provide customised suggestions for managing Expenses.
Manage all your Credit Instruments at one place including reminding you of the payment due before the due date.
To inform you of promotions, offers, surveys, events, products and services, which may be of interest to you;
To continually improve the existing Platform and service offerings;
To conduct research and surveys;
To implement the necessary security practices to ensure that all personal data are protected;
To administer the User accounts in normal course of business;
To contact the Users in case where fraud, illegal activities or breach of privacy is recorded;
To enable the employees of or persons acting on behalf of the Company to communicate with the User, as and when necessary, in order toprovidetheservices requested by such User;
Such other purposes that the Company ,at its sole discretion,however subject to the principles contained in this Policy, may deem fit.
SHARING OF INFORMATION
Every User hereby expressly agrees that the Company may share the Information collected from such User with its affiliates, employees, and such other individuals and institutions located within or outside India from time to time to ensure efficient management of Platform traffic, to detect and prevent identity theft and other illegal acts, and to respond to legal, judicial, quasi-judicial law enforcement agencies or in connection with an investigation on matters related to public safety, as required and permitted by law and for such other purposes that the Company may deem fit from time to time.
It is further agreed that in the event that the Company sells any of its business or assets to any third party, it may disclose your personal data to the prospective buyer of such business or assets. The same shall also be applicable if the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
As required by law, at times we might be required to disclose your personal information including personal, transactional and financial information to relevant regulatory, and governmental authorities and also to our advisors such as law firms and audit firms while responding to requests from the regulatory authorities. In some cases, when we believe that such disclosure is necessary to protect our rights, or the rights of others,ortocomplywitha judicial proceeding, court order, or legal process served on our app we would share such information pursuant to a lawful request from law enforcement agencies
Subject to explicit and prior consent from you, we may use information created by your use of our App services, not including information collected from other sources such as e-mails etc. for marketing purposes.This consent is purely voluntary and you may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each email you may receive, by indicating so when we call you, or by contacting us directly. Further, if you want to remove your contact information from all our lists and newsletters, please click on the unsubscribe button on the emails or send an email request to unsubscribe@cheq.one
Subject to explicit and prior consent from you, we may disclose certain information that is created by your use of our Platform services, not including information collected from other sources such as e-mails etc. to other affiliate entities and partners that are not acting as our suppliers or business partners. For the sake of clarity, we do not sell or lease such information.
Some of our campaigns/programmes/related events may be co-branded, that is sponsoredby both the third parties and us. If you sign up for such campaigns/programmes/related events, please note that your information may also be collected by and shared with those third parties. We urge you to familiarise yourself with their privacy policies to gain an understanding of the manner in which they will handle information about you.
We may display targeted or non-targeted third-party online advertisements on the Platform. We may also advertise our activities and organizational goals on another Platform. We may collaborate with other Platform operators as well as network advertisers to do so.We request you to read and understand such concerned third party privacy policies to understand their practices relating to advertising, including what type of information they may collect about your internet usage. No personally identifiable information is shared with any third-party online advertiser or website or app as part of any such activity. The Company does not provide any information relating to your usage to such website operators or network advertisers.
During your use of the App services, you may come across links to third party websites/apps that are not affiliated with the Company. The Company is not responsible for the privacy practices or the content of those other websites, or for any acts/ omissions by such third parties in the course of your transaction with them. During your use of the App services,you may come across links to third party websites/apps that are not affiliated with us.We are not responsible for the privacy practices or the content of those other websites, or for any acts/ omissions by such third parties in the course of your transaction with them.
ACCOUNT/CARD DELETION
We provide all our Users an option to request the deletion of a specific account through the support section on the Platform. Following such a request, we archive your account information subject to the regulatory and operational data retention policies.
In certain circumstances, we may be unable to archive your account, such as if there is any outstanding dispute or unresolved claims pending on your card/account. However, upon resolution of the issue preventing deletion,the information is immediately archived and can’t be actively accessed. Please note that we may retain certain information if necessary for our own legitimate business interests such as fraud prevention and enhancing users’ safety and security or to fulfil our legal obligations and compliance.
You also have the option to request for an account deactivation or unlink a card or credit instrument instead. This will temporarily block your access to your account until you send a reactivation request on support@cheq.one and successfully re-activate your account.
COOKIES AND THIRD-PARTY WEBSITE/PLATFORM LINKS
The Platform sends cookies (small files containing a string of characters) to your mobile, thereby uniquely identifying your browser. Our secure cookies are used to track your preferences, help you login faster, and aggregated to determine user trends.This data is used to improve offerings, such as providing more content in areas of greater interest to a majority of users. Most browsers are initially set up to accept cookies,but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Disclaimer: Some of the Platform features and services may not function properly if your cookies are disabled The Platform may contain links that will redirect the Users to third party websites that may have access to the personal information of the User to which this Policy shall not be applicable. Thereby, every User agrees and acknowledges that accessing third party websites through links provided in the Platform will solely beat the User'sdiscretion.Additionally,the Company shall under no circumstance be held liable for breach of privacy by such third-party website nor shall it be liable for any objectionable content that may be displayed on such third-party website. The Platform may contain links to other websites; however, every User agrees and acknowledges that the Platform shall not be responsible for the privacy practices of other third-party websites which it does not own, manage or control. This Privacy Policy shall not apply to any information voluntarily disclosed by the Users to other Users of the Platform or third parties.
USER INFORMATION PROTECTION AND CONFIDENTIALITY
a) The Users’ information is maintained by the Company in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. The Company takes all necessary precautions to protect your personal information both online and offline, and implements reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of the Company business.
b) No administrator at the Company will have knowledge of your login details. It is important for you to protect against unauthorized access to your login details, your mobile phone. Be sure to log off from the Platform portal when finished. The Company does not undertake any liability for any unauthorized use of the user account and its login details. If the User suspect any unauthorized use of youraccount,the user must immediately notify the Company by sending an email to support@cheq.one. The User shall be liable to indemnify the Company due to any loss suffered by it due to such unauthorized use of the user’s account and its login details.
c) The Company makes all User information accessible to its employees, agents or partners and third parties only on a need-to-know basis and binds only its employees to strict confidentiality obligations.
d) Notwithstanding the above, the Company is not responsible for the confidentiality, security or distribution of the User’s information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, the Company shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of the Company including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User etc.
e) Except as otherwise provided in this Privacy Policy, we will keep the User’s personal information private and will not share it with third parties, unless we believe in good faith that disclosure of the User’s Personal Information or any other information we collect about the User is necessary to:
comply with a court order or other legal process;
protect the rights, property or safety of the Company or another party;
enforce our Terms of Use; or
respond to claims that any posting or other content violates the rights of third-parties.
f) Notwithstanding anything to the contrary, the Company shall not be held responsible for any loss, damage or misuse of the Information caused to the User, if such loss, damage or misuse is attributable to an event beyond the control of or attributable to the Company or a force majeure event.
g) The Company shall use the Information collected from the Users in accordance with applicable laws including but not limited to the IT Act and the rules made thereunder and use the Information only for the purpose for which it was furnished.
UPDATION OF POLICY
The Company reserves the right to change or update this Policy at any time. The User shall be notified of any change to the Policy having the effect of curtailing or limiting the existing User rights under the Policy. Any such changes or updating of the Policy shall be immediately effective upon posting to the Platform and your continued use is deemed approval of all such changes.
COMPLIANCE
We are a PCI DSS and CICRA certified company and have implemented the Information Security Management System policies and procedures in order to maintain industry standards and best practices.
We are complied with “Data Localization” requirements as per Reserve Bank of India(RBI) guidelines. This means all our customer data securely resides inside one or more data centres located within India.
(CheQ’s) use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy , including the Limited Use requirements.
GRIEVANCE REDRESSAL
The User may report violation or breach of privacy, Information or identify theft or grievances in relation to the Information shared, collected, stored or disseminated by the Company in relation to the Platform. Please reach out at support@cheq.one. The grievances shall be redressed within one month from the date of receipt.
GOVERNING LAW AND JURISDICTION
In the event of any dispute arising between the parties with respect to this Policy, the same shall be referredtoasolearbitratormutuallyappointedbythePartiesandthearbitrationshall be in accordance with Arbitration and Conciliation Act of 1996. The language of arbitration proceedings shall be English. The seat and place of arbitration shall be Bangalore,Indiaand the decision of the Arbitrator shall be final and binding on both parties herein.
This contract shall be subject to the exclusive jurisdiction of courts in Bangalore, India and shall be governed by the Indian laws.
