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Truecaller Pay Privacy Policy

Issued April 16, 2018
 
Thank You for choosing to use Truecaller Pay Facility (“Facility”).
 
As You use the Facility, We want You to be clear on how We’re using Your
information and the ways in which You can protect Your privacy.
 
This privacy policy (“Pay Privacy Policy”) supplements Our Privacy Policy, which applies to the use of Our Services. All defined terms not defined in this Pay Policy will have the meaning ascribed to them in the Truecaller Terms of Service, Pay Terms and the Privacy Policy (collectively, “Truecaller Policy”).
 
This Pay Privacy Policy is published in compliance with  inter alia:
 
a. Section 43A of the Information Technology Act, 2000 (“IT Act”);
b. Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (“SPDI Rules”); and
c. Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011.
 
GENERAL
 
BY ACCESSING OR USING OUR FACILITY OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE THE CAPACITY TO ENTER INTO A LEGALLY BINDING CONTRACT AS PER APPLICABLE LAW APPLYING WITHIN THE JURISDICTION OF THE REPUBLIC OF INDIA, IN PARTICULAR, THE INDIAN CONTRACT ACT, 1872, AND CONSEQUENTLY, WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PAY PRIVACY POLICY AND AGREE TO BE BOUND BY IT.
 
YOU HEREBY CONSENT TO OUR COLLECTION, USE, SHARING, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PAY PRIVACY POLICY.
 
IF YOU DO NOT AGREE WITH THIS PAY PRIVACY POLICY AT ANY TIME, IN PART OR AS A WHOLE, DO NOT USE THE FACILITY, OR PROVIDE US WITH ANY OF YOUR INFORMATION.
 
1. INFORMATION COLLECTED AND METHOD OF COLLECTION
 
To enable use of the Facility, You are required to provide Us with the following information:
 
(a) Information from Truecaller Account: Your name and mobile number;
(b) Information for the transaction: Your Aadhaar number, Name of the beneficiary, beneficiary UPI ID, mobile number of beneficiary, IFS Codes of the bank accounts, transaction amount. The particular information collected for the transaction is dependent on the mode through which You wish to conduct the transaction. Further, You will be required to create a UPI ID with one of our partner PSP banks before being able to use the Facility for transaction;
(c) You will be required to create a UPI PIN with the bank with whom You have the account being
used for the transaction be conducted through the Facility
 
(Collectively, “Account Information”).
 
Additionally, We collect the following information through automated means upon the occurrence of a transaction by You through the Facility: transaction status, date and time of the transaction, transaction reference number, CBS name of the beneficiary (Collectively, “Automated Information”).
 
We also receive information about You from Our partner payment service providers (“PSPs”) and other third party service provider in relation to Your use of the Facility (“Other Information”).
 
Account Information, Automated Information and Other Information are collectively referred to as“Facility Related Information”
 
All Account Information is provided by You to Us voluntarily and You consent to Our collection, use and disclosure of the same in accordance with the terms of Truecaller Policies.
 
If You are the sender of monies through the Facility, You represent that You have obtained all requisite prior consents and waivers necessary from any third party or the recipients of the monies and have provided such third parties including the recipient with notice to permit Us to use the information as contemplated herein. If You are the recipient of monies through the Facility, You hereby consent to permit the sender to store Your bank account details, Your name, transaction details, Aadhaar numbers on Our Application for making payments to You.
 
You may choose to not provide Us with any or all information included under Account Information, but in the event that You do so, We will be unable to provide You with Our Facility.
 
Further, in the event of a change in the law applicable to data protection in India, You hereby expressly consent to Our continued use, storage, collection and disclosure of Your information including Personal Information to the fullest extent permitted under such applicable law. We may reach out to You for obtaining additional consents and approvals as required under the amended law and You will be required to comply with such requests. Should You choose to not provide Us with such additional consents and approvals, We may have to discontinue provision of the Facility to You.
 
2. USE OF INFORMATION
 
We use Facility Related Information for the following purposes:
(a) To provide the Facility to You and enable its use;
(b) To facilitate the transactions on the Facility;
(c) Communicating the Facility Related Information to Our partner PSPs for processing the transactions;
(d) To provide You with customer support;
(e) To operate and improve the Facility in order to foster a positive User experience and to improve Our business as a whole;
(f) Analysing data, tracking trends, building algorithms, creating databases for rating systems, recommendations engines, etc.;
(g) Research;
(h For non-targeting reasons such as frequency capping, compliance, billing, ad reporting or delivery, market research or product development purposes;
(i) To conduct audits and quality assessment procedures;
(j) To analyse the use of Our resources, troubleshooting problems and improving Our Facility;
(k) To comply with applicable law;
(l) Contacting You for offering new products or services;
(m) To investigate, prevent, or take action regarding illegal activities, suspected fraud or as otherwise required by law;
(n) To respond to any queries that You may have, and to communicate information to You, including notifications of any promotions or alerts, any updates to the Facility, or the introduction of any
future fees or charges that We may collect at the time for the use of the Facility by You; and
(o) For any other purposes that are permitted under applicable law.
 
3. DISCLOSURE OF THE INFORMATION
 
We disclose Your Facility Related Information to the following third parties:
 
(a) PSPs for processing the transaction;
(b) Regulatory authorities as and when required under applicable law or pursuant to an order form a court of competent jurisdiction;
(c) companies and individuals who are authorised by Us to perform functions in relation to the Facility; and
(d) Our affiliates in accordance with applicable law.
 
4. STORAGE AND SECURITY OF YOUR INFORMATION
 
The provision of the Facility is governed by the Unified Payments Interface Procedural Guidelines
issued by National Payments Corporation of India’s (“NPCI”) and other rules, regulations, circulars and guidelines issued by it.
 
We collect, store, process, use and retain all Facility Related Information in accordance with applicable law including NPCI circular No. NPCI/UPI/OC No. 32/2017-18 dated September 2017 (“Circular”) and all other rules, regulations, circulars and guidelines issued by NPCI pertaining to the Facility.
 
We do not store any customer payment sensitive data (as defined in the Circular), the last 6 digits of Your debit card or its expiry date, the UPI PIN, and Issuer OTP.
 
While We have implemented all reasonable security procedures to safeguard Your Facility Related Information as specified above, We cannot guarantee that such information will never be disclosed. We shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Our reasonable control 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, etc.
 
5. INDEMNITY
 
You agree and undertake to indemnify Us in any suit or dispute by any third party arising out of disclosure of information by You to third parties either through Our Facility or otherwise and Your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to Your Facility Related Information which You may have disclosed to such third parties.
 
6. RESPONSIBILITY FOR TAXES
 
The reporting and payment of any applicable taxes arising from the use of Facility is your responsibility. You hereby agree to comply with any and all applicable tax laws in connection with your use of Facility, including without limitation, the reporting and payment of any taxes arising in connection with Payments made through Facility, or funds/income received through the Facility.
 
 
R
Rohit is the author of this solution article.

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