PRIVACY POLICY

1. Introduction

  1. Savcity Technologies Private Limited, having its registered address at Villa No. 12, P M R Park Wood, Laxmi Nagar, Gundlapochampally, Hakimpet, Hyderabad, Tirumalagiri, Telangana, India, 500014 (hereinafter referred to as the “Company”, “Truupe” “We”, “Us”, “Our”), owns and operates this website registered at “www.truupe.com” (“Platform”). The Platform aims to facilitate provision of digital escrow services (collectively “Services”). The Company recognizes the need for appropriate protection and management of Personal Data (as defined below) and is committed to safeguarding and upholding the legal rights of privacy and data protection of an individual who browses, accesses or uses the Platform or provides information on or through it (hereinafter, collectively referred to as “You”, “Your” or “User”).
  2. This privacy and data protection policy (“Policy”) explains Our practices concerning the collection, storage, utilization, processing, disclosure, and transfer of Personal Data; the types of Personal Data being collected from the Users by the Company; the purpose of collecting Personal Data; the recipients of Personal Data; and how Personal Data is processed, stored and protected, through the Platform in relation with Our Services (as defined below). The Policy also provides guidance on how You can reach out to Us regarding Our privacy and data protection practices.
  3. This Policy should be read together with the Terms of Use, as it is an integral part of them, incorporated here by reference. If any terms used here are not defined, please refer to the Terms of Use.

2. Applicability, effect and acceptance

  1. This Policy extends to any User, as a natural person, who uses, accesses or browses the Platform, or makes use of the Services offered on or through the Platform.
  2. By accessing or browsing the Platform, registering on the Platform or availing the Services, You expressly accept, without limitation or restriction or reservation, the terms and conditions of this Policy which is part of Our Terms of Use. Furthermore, You give Your consent and grant authorization for Us to collect, use, process, transfer or disclose such Personal Data for the purposes provided in this Policy and the Terms of Usage, and in accordance with applicable laws.
  3. This Policy establishes a legally binding agreement between the Company and You. Upon Your acceptance (whether directly, indirectly through electronic means, by utilizing the Platform, or through other channels), the terms outlined herein shall take effect and govern the ongoing relationship between the Company and You throughout Your usage of the Platform and the Services
  4. Capitalised terms in the Policy shall have the same meaning ascribed to them in the Terms of Use. To the extent not defined therein, the following terms as used in this Policy shall have the meaning ascribed to them below:
    • “Buyer” a User who intends to purchase goods and/or services from the Sellers by use of the Platform;
    • “Deal Agreement” means an agreement executed between the Buyers and Sellers for the sale of goods and/or services;
    • “Facility Document” means the documents as may be executed between the User, the Company, the Escrow Agent and the Escrow Bank, pertaining to the Deal Agreement(s) to be consummated;
    • “Locational Information” means and includes data obtained through GPS or other means, providing details regarding the geographical location of the User;
    • “Non-Personal Data” means and includes any information that is not Personal Data;
    • “Personal Data” means and includes any data about an individual who is identifiable by or in relation to such data, such as the name, contact details, email address, gender, age, organisation name, organisation email id, or any other relevant material provided by a User, including but not limited to information gathered through the Services and the Platform; Personal Data includes Sensitive Data, Technical Information and Location Information;
    • “Seller” means a User offering goods and/or services for sale to the Buyer(s) and proposes to use the Platform to close the sale;
    • “Sensitive Data” means and includes such Personal Data relating to passwords, financial information, biometric information, sexual orientation, physical, physiological and mental condition, medical records or medical history, and any detail relating to the aforementioned grounds as provided to the Company for providing Services; However, it does not include any information or data which is already available in the public domain, information publicly available in the government records, or furnished Right to Information Act, 2005 or any other applicable laws;
    • “Technical Information” means and includes any information gathered through the use of different technologies that may employ cookies, web beacons, or similar technologies to automatically record certain information from Your device through which You use the Platform. This Technical Information may include but is not limited to Your Internet Protocol (IP) address, Internet service provider (ISP), hardware model, device or browser type, operating system, referring or exit pages, clickstream data, operating system version, unique device identifiers, and Wi-fi and mobile network.

3. Amendment

  1. We regularly review Our Policy and may modify or amend this Policy periodically to align with Our present privacy and data protection practices and applicable laws. It is recommended that You periodically review this Policy for any modifications. Changes to the Policy become effective upon publication on the Platform.
  2. Any alterations to this Policy that may impact You will be communicated through an appropriate channel, based on Our usual mode of communication with You. Your ongoing use of the Platform and the Services following any modifications indicates acceptance of those changes.

4. Purpose of collection

    1. We collect Your Personal Data for providing Services or for any other request raised by You. The list of purposes for which we may process Your Personal Data is given below:
      • Setting up Your Escrow Account;
      • Undertaking User’s Know Your Customer (“KYC”) and Know Your Business (“KYB”);
      • Collection of Platform Fee;
      • Facilitation of payment of Transaction Amounts to the Escrow Account;
      • Implementing automated processes to deliver Our Services;
      • Addressing complaints, inquiries, User feedback and disputes with respect to the Terms of Use, the Services or this Policy;
      • Identification, prevention and resolution of any technical issues;
      • Monitoring the usage of Our Services;
      • Communicating updates made on the Platform including information about other services or products; and
      • Ensuring compliance with legal and regulatory requirements.
    2. We collect Personal Data which is necessary and adequate, without being excessive, to provide You with the Services or to fulfill any other User requirement. In order to safeguard Your privacy, please refrain from providing any Personal Data which has not been expressly requested by Us or You prefer not to disclose. Should additional, optional information be necessary for the provision of the Services, You will be informed of such requirements at the time of collection.
    3. We undertake processing of Personal Data only on valid grounds as provided under applicable laws. Accordingly, We process Personal Data only on one or more of the following conditions:
      • Performance of a Contract We undertake processing of Personal Data in order to fulfill Our legal obligations under different contracts, including but not limited to Facility Document, Terms of Use, contracts entered by the Company to provide You with the Services.
      • Legal Obligation other than Contracts: Processing of Your Personal Data might be required in order to allow Us to adhere to legal obligations under applicable laws, government orders, judicial decisions, or to safeguard the essential interests of Our users. For example, We may be required to retain certain Personal Data including but not limited to the history of transactions completed through the Platform for a specified period of time to comply with applicable laws.
      • Consent: In certain specific circumstances, We may request Your consent for processing Your Personal Data. However, We will only use the said collected Personal Data for the limited purpose communicated to You at the time of collection and will not use the Personal Data for any purpose materially different or incompatible from the purpose for which the Personal Data was collected. Please note that the decision to furnish requested Personal Data is Your sole discretion. Nonetheless, failure to provide such information and/or data may result in our inability to furnish specific services or features of Our Services or Platform. Consequently, your utilization of the Platform and Our Services may be restricted.

5. Type of Personal Data collected

  1. For the purposes set out in Section 4 above, We may collect Personal Data that may include, but not limited to:
    • Identity details such as your first and last name, gender, title, etc.;
    • Contact details such as phone number, email id;
    • Residential address, office address, Location Information;
    • Constitution details and supporting documents such as certificate of incorporation, registration certificate of firm, etc.;
    • Details / nature of business and goods and services offered;
    • KYC information including documents issued by the government such as Aadhaar, PAN Card, Voter ID, Ration Card, etc.;
    • Financial information such as bank account number, bank IFSC, etc. and other details in accordance with Deal Agreement;
    • Transaction details, including details of Services you have availed, and details of Transaction Amounts paid through the Platform;
    • Account details including Your username and password and preferred account settings such as the language and time zone, etc.;
    • Invoicing details, including banking details such account number, bank name, branch, etc.;
    • (xi) Statistical or analytical data, behavioral and usage data regarding Your interactions with the Platform and the Services, including the pages visited by You, links and advertisements engaged with, search queries, and other actions undertaken in relation to the Platform and the Services; and
    • Technical Information such as Your IP address, referring web page, timezone.
  2. Financial information shall be collected using third-party intermediary PCI-DSS compliant service providers. The payment information is provided directly by You, via the Platform, into the PCI/DSS-compliant payment processing service to which the Company subscribes, and the Company does not, itself, process or store the payment information, except as stated herein.
  3. If You are a passive User of the Platform and do not register for the Services, then the Platform may still collect, process, and store Your Non-Personal Information.

6. Sharing of Personal Data

  1. The Company reserves the right to involve third parties to collaborate with or work on behalf of the Company, and who may require access to Personal Data to fulfill their duties. However, any third parties engaged by the Company are provided access to Personal Data on a need-to-know basis and are strictly prohibited from using any such Personal Data for any other purposes.
  2. You acknowledge and hereby grant consent for the transfer of Personal Data to any third-party user for the purpose of providing the Services or any collaboratively developed or marketed services, encompassing payment processing, fulfillment of Services, customer support, data analysis, information technology services, and any other services to enable Us to provide Services through the Platform.
  3. We do not share or sell Your Personal Data with any third parties without Your express consent, to the extent it is essential for our legitimate professional and business operations, to facilitate the access of the Platform, provide Services, fulfillment of User requests, or as mandated by applicable laws. Please note that Your Personal Data may be shared without Your express consent with government agencies which are required to obtain such Personal Data under applicable laws.
  4. We may disclose Your Personal Data and Non-Personal Data: (i) if mandated under applicable law; (ii) to Our subsidiaries or affiliates or service providers on a need-to-know basis to fulfill the intended purpose for which the Personal or Non-Personal Data, as the case may be, was provided; and (iii) for any other purpose disclosed by Us when You provide the information.
  5. In the event of any change in control of the Company, We may disclose or transfer Your Personal Data to relevant third party acquiring or inheriting the assets and business of the Company. In such circumstances, We will strive to instruct the transferee to handle Your Personal Data in accordance with this Policy.

7. Transfer of Personal Data

  1. We will undertake all reasonable measures to guarantee the secure treatment of Your Personal Data in accordance with this Policy. We will ensure that no transfer of Your Personal Data will occur to any organization or country unless adequate controls are established, encompassing data security and the protection of other Personal Data.
  2. Your Personal Data may be transferred to Escrow Banks or to third parties on a need-to-know basis, subject to obligations of confidentiality of the Deal Agreement, Facility Documents, for the provision of Services.

8. Retention of Personal Data

  1. We undertake retention of Personal Data only for the duration for which it is reasonably required or otherwise mandated by applicable laws or regulatory requirements. However, We may retain your Personal Data for as long as it is essential to fulfil the purposes for which the said Personal Data was collected, which may include any legal, administrative, accounting, or any other reporting requirements.
  2. Users have the right to request for deletion or erasure of their Personal Data, subject to the restrictions imposed by applicable law. In some cases, we may retain only Non-Personal Data indefinitely or to the extent allowed by applicable law.
  3. In multiple instances, We may be obliged by applicable law to retain all, or a portion, of Your Personal Data to adhere to Our legal obligations, settle disputes, enforce agreements (not limited to Deal Agreement or Facility Document), safeguard against fraudulent, deceptive, or illegal activity, or for other legitimate business purpose.

9. Third party links

  1. The Platform may include links to websites or mobile applications owned or operated by third parties. These links are separate from the Company, and the Company holds no authority over the content on those websites, even if it provides information or services to the owner of such websites.
  2. The Company does not provide any representations, endorsements, or assume responsibility for the content or usage of any third-party website. Furthermore, We are not responsible or liable for any damages or losses incurred due to the use of any third party website.

10. Security Measures

  1. We implement suitable and reasonable security protocols for the protection of Personal Data against unauthorized access, alteration, disclosure, or destruction. We employ specific physical, managerial, technical, or operational safeguards in accordance with industry standards and recognized best practices, in accordance with applicable laws, to safeguard the Personal Data We collect. However, We shall not be held liable for any data breaches occurring due to actions beyond our control by third-party cloud service infrastructure providers.
  2. If You have an account registered with the Company, Your Personal Data is safeguarded by the password You utilize to access Your account on the Platform. Please note that it is crucial that You uphold and maintain the security of Your account.
  3. We regularly assess Our practices for collection, storage, and processing of Personal Data. However, despite the effectiveness of these measures, no security system is entirely impervious. We cannot guarantee the absolute security of Our database, nor can We ensure that Your Personal Data will not be intercepted during transmission to Us over the internet. In the event of a system compromise or any unauthorized breach resulting in the disclosure of Your Personal Data, We will notify You as soon as possible, but no later than 48 hours from the time We detect such an incident. You accept and acknowledge the inherent security risks associated with data transmission over the internet. Accordingly, Your use of the Platform will be at Your own risk. If you have any concerns, please feel free to contact the Grievance Officer as per the details set out under Section 13 below.

11. Your rights

  1. You retain several rights in relation to Your Personal Data as provided under applicable law. You can exercise the following rights by writing to Us at the address mentioned under Section 13:
    • access, confirm, and review Personal Data You may have provided;
    • correct Personal Data that may be inaccurate or irrelevant;
    • deletion and erasure of Your Personal Data from the publicly available pages of the Platform;
    • receive Personal Data We hold about You in a portable format;
    • object to or restrict any form of processing You may not be comfortable with;
    • opting out of marketing or promotional communication;
    • withdraw Your consent provided under this Policy.
  2. In case You request Us to delete any Personal Data We will take reasonable measures to delete such Personal Data from Our records. However, We will keep certain records/information pertaining to payment or Service matters wherever necessary in order to ensure compliance with applicable laws or to exercise, defend or establish Our rights.
  3. If You want to withdraw Your consent or raise any objection to the use of Your Personal Data for receiving any direct marketing information to which You previously opted-in, You can do so by contacting our customer support at above mentioned addresses. If You withdraw/object Your consent, Our use of Your Personal Data before You withdrew/objected shall still be lawful.

12. Children

Our Platform and Services are not meant for use by anyone who has not attained 18 (eighteen) years of age (“Child”/ “Children”) and We knowingly do not collect Personal Data of/from Children. If it comes to Our notice that We have collected Information from/of Children, We shall take steps to remove that Personal Data from Our servers. If You believe that We might have any Personal Data that may have been collected from a Child or has been provided by a Child, please write to us at the address mentioned under Section 13 and We will remove such Personal Data from Our servers.

13. Grievance Redressal

If You are concerned regarding the management of Your Personal Data, or if You have any complaints or inquiries regarding Your Personal Data or Our Policy, please reach out to Our designated grievance officer at:
support@truupe.com

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