This is the Privacy Policy (“Policy”) of VARIGNON TECHNOLOGIES PRIVATE LIMITED (subsidiary of Finoramic Inc.), a company incorporated under the laws of India and having its registered office at 502, 3rd  Floor, Sharp Bhawan, Azadpur, New Delhi-110033 (“Company”). The Privacy Policy explains our policy regarding the collection, use, disclosure and transfer of your information by the company.

The Company respects the privacy of the users of the company’s services and is committed to reasonably protect it in all respects. The information about the user as collected by the Company is: (a) information supplied by users and (b) information automatically tracked while using a mobile device having mobile applications (collectively referred to as Information).

 

1. The Platform and Clients

Our services (the “Services”), which are made available to you (“Clients”) through our website located at www.finoramic.com (the “Website”) and/or through mobile software applications that we license to you (the “App”). The Website and the App are collectively referred to herein as the “Platform.” By signing up, accessing and/or using the Platform, you agree to be bound by terms of this policy.

 

2. Personal Information

2.1. “Information” for the purposes of this Policy means following information

• Name, Email and mobile phone number of clients
• Any financial information collected by user’s consent
  
  
  • Bank/Credit card statements
  • Account / Card Numbers
  • Investment Information
  • Permanent Account Numbers
  • Information related to the transaction in question including identity of the service or product and the price or fee paid or payable in respect thereof.
  • Information from user’s shopping transactions

 

3. Purpose of Collection and Use of Personal Information

Your privacy is our priority. We will use your Personal Information, Billing Information, Geolocational Information and Other Information (collectively, the “Information”) for the following purposes:

• to provide you with the Services and enable you to use the Services;
• to improve and customize your experience on the Platform;
• to retrieve your User Accounts statements and information regarding your transactions in order to provide you with the Services.
• to provide you with support, handle complaints and collect fees and to conduct administrative activities necessary to maintain and provide our Services;
• to send you Services-related updates, notices and announcements;
• to provide you with information related to the Services;
• to conduct surveys and questionnaires;
• to enforce Company’s Terms of Use;
• to contact you regarding service and administration related issues as and when Company believes it to be necessary;
• to comply with any applicable law and assist law enforcement agencies under any applicable law, when Company has good faith to believe that Company’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards;
• to prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
• to take any action in any case of dispute, or legal proceeding of any kind between you and Company, or between you and any other third parties or users with respect to, or in relation with the Services;
• for any other purposes disclosed at the time the Information is collected or to which you consent; and
• as otherwise specifically described in this Policy.

 

4. Non-Personal Aggregated Information?

We may aggregate your Information (including data regarding activity in your User Accounts) in a form that does not identify you personally (“Aggregated Non-Personal Information”). We may use such Aggregated Non-Personal Information to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, for further internal, commercial and statistical purposes.

 

5. Usage of Android advertising ID

As per the terms of Google Play Services version 4.0, the Company shall use the Android advertising ID when available on a device, only for advertising and user analytics purposes. The Company shall not connect the advertising ID it to any personally-identifiable information without the explicit consent of Clients. The Company shall abide by reset and “Opt out of Interest-based Advertising” settings of Clients.

 

6. Sharing of Personal Information with Third Parties

The company does not publish, sell, give on rent, trade, share or otherwise transfer any sensitive information with companies, organizations, or individuals outside our platform, except in the following cases:

Legal Reasons

It is required by law, or pursuant to the order of a court or regulatory authority, or in order for Company to enforce its rights.

With your consent

The platform may provide features/services (from time to time) which allows you to share limited aggregated processed information with individuals, on other platforms & third parties which allows you to acquire certain services. You have complete control over what you share. For example, some users may want to share information like (not limited to) “Finoramic score“ with lending companies to get a better deal on interest rates. To ensure the security of the data, Finoramic doesn't allow you to share raw data with any external party even with explicit user consent. Any sharing request will be the result of an action initiated by you and we’ll ask for your explicit consent to share any sensitive information.

 

7. Choice

Company reasonably presumes that Clients who transmit Personal Information to Company are doing so out of their own volition. Company does not compel Clients to disclose Personal Information. At any time, Clients may opt not to provide Personal Information by deleting any installed application and informing the Company via an email to [email protected].

 

8. Correctness and Integrity of Personal Information

Company accesses Personal Information as aforesaid from SMS and Email messages on an ‘as is’ basis. Therefore, Company shall not be responsible in any way for the correctness, completeness and integrity of any Personal Information collected hereunder.

 

9. Security

Company shall take all reasonable precautions by way of using current industry standard encryption technologies to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

 

10. Limit of Liability

Notwithstanding anything to the contrary in this Policy or any other terms of service or use applicable as between Company and Clients, Company’s aggregate liability hereunder shall be limited to Rs.1000 only and shall not extend to any indirect or remote damages whatsoever, including but not limited to special, incidental, consequential, or punitive damages or loss of profits.

 

11. Information Storage and Backup

From time to time, we take backup of users’ data on our Cloud database. This is done for the purpose of enabling users to get their data back in case their phone’s data becomes unusable, or phone gets lost, or the user moves to a new phone device. We also use this backup to provide useful  insights and information related to their spends such as weekly spends in a month, insights related to spend behaviour, etc., and to provide information related to user spends, patterns and user data in the form of aggregated and anonymized statistics on data such as user spends by category, date, time, bank balances, etc.

 

12. Data Retention

When your account is terminated, we will use commercially reasonable efforts to delete your Personal Information and discontinue any connection with your financial institution regarding your account. Naturally, once disconnected, you will no longer have access to your account or the Service. However, due to periodical backups and safety mechanisms meant for your information protection and for our administrative purposes, certain Personal Information from your account may remain in our systems for an indefinite time. We will not knowingly keep this in a way that could identify you. If you have a query about any such Personal Information that we may be storing, please email us at [email protected]. Your email should include adequate details of your query.

 

13. Information Security

We use commercially reasonable efforts to safeguard your Information from any unlawful interceptions or access, or other kinds of abuse and misuse. We implement a variety of systems, applications and procedures to do this. Among such security methods is the storing of your Information on cloud services, firewalls, encryption codes, authentication procedures and multi layer passwords. Furthermore, we implement employee supervision and prevent unnecessary access to data. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please also be aware that certain Personal Information and other information provided by you in connection with your use of the Platform may be stored on your mobile device (even if we do not collect that information). You are solely responsible for maintaining the security of your mobile device from unauthorized access.

 

14. Children’s Privacy

We do not knowingly collect Personal Information from children under the age of 18 through the Platform. If you are under 18, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Policy by instructing their children never to provide Personal Information through the Platform without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

 

15. Enforcement

For any inquiries and complaints, the following email address may be used: [email protected]. All inquiries and complaints shall be looked into promptly and without charging any fee to the inquirer / complainant.

 

16. Compliance

Company shall always cooperate with regulatory authorities and investigating agencies in India in the matter of treatment of Personal Information.

 

17. Amendments

Company may modify this Policy in its sole discretion at any time. While Company shall make best efforts to notify Clients of any such modification, it shall be Clients’ responsibility to read and understand the Policy as prevalent from time to time. Installation of the Platform shall be deemed to constitute acceptance of the Policy as amended.

Effective date of this policy: September 11, 2017