Privacy Policy

Last Updated: 24/11/2022 (Version 1.2)
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Overview
1.1 Rupifi Technology Solutions Private Limited (Rupifi) is engaged in the business of providing technology services and products to various merchants, in addition to certain data processing services/ credit risk and other evaluations to Partner Banks and Non-Banking Financial Companies.

1.2 This Privacy Policy ("Policy”) is an integral part of the RUPIFI terms of use (“Agreement”) and is incorporated therein by reference for access and use of this website. Capitalised terms not defined in this Privacy Policy shall have the meaning ascribed to them in the Agreement. This Privacy Policy shall be read in conjunction with the Agreement.
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1.3 Rupifi Technology Solutions Private Limited provides this privacy policy in connection with an individual’s use of any of RUPIFI’s products or services or its website. (“RUPIFI’s Privacy Policy”).

1.4 For the purposes of RUPIFI’s Privacy Policy, the term “you” or “your” relates to the individual (i)who applies for, or obtains, any of RUPIFI’s products or services (ii) who visits the website. The term “RUPIFI,” “we,” or “our” refers to Rupifi Technology Solutions Private Limited, its affiliates and subsidiaries.

1.5 Under this Policy we inform you regarding the manner in which we collect, store, use, disclose, transfer and process your Personal Information when you use our website, or avail any products or services which we may operate or offer to you either directly through our Websites or Platforms or through a merchant or partner platform; including the steps we take to protect your Personal Information.

1.6 RUPIFI’s Privacy Policy applies to personally identifiable information about you, which we refer to as “your information”. In connection with RUPIFI’s treatment of your information, RUPIFI’s Privacy Policy describes the policies and procedures (including a summary of the relevant security controls) that RUPIFI’s uses when collecting, maintaining, using, or transmitting (or “disclosing”) to others any of your information. Please carefully read RUPIFI’s Privacy Policy before use of its services/ platform.

1.7 You should be aware that this website is not intended for, or designed to attract, individuals under the age of 18. We do not collect personally identifiable information from any person we actually know is an individual under the age of 18. Further, the terms of use/ Agreement and this Privacy Policy is updated from time to time, we encourage you to be abreast with the current versions by returning to this page to read the updated policy, from time to time.
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Information we collect

2.1 “Personal information” means any information that relates to an individual, which directly or indirectly, in combination with other information available or likely to be available with us, is capable of identifying such individual. Such information may include information such as your mobile telephone number, email address, residential address, nationality, photo, employee ID number, tax identification number, Aadhaar number, personal identification proof (Driving License and/or passport), PAN number etc.

2.2 “Sensitive Personal Information” means any Personal Information of an individual, which consists of information relating to financial information such as bank account, credit card, debit card or other payment instrument details; and subject to the nature of the transaction and where permitted for diversity and monitoring purposes, we may collect information concerning your gender, information about your employment or marital status or personal characteristics, such as whether you are employed, place of work, and the number of days you work in a month etc.;

2.3 However, information freely available or accessible in public domain is not treated as Sensitive Personal Information. As a matter of principle, we do not collect certain special categories of Personal Information about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health or any genetic and biometric information).

2.4 Depending on who you are (e.g., a merchant, customer, cardholder, consumer, supplier or business partner) and how you interact with us (e.g., through Website, Platform, telephone, IVR, online or offline), we may collect, use, receive, store, analyze, combine, transfer or otherwise process different categories of your Personal Information (including Sensitive Personal Information) whether directly:-

  1. provided by you on an application to us or from data we collect from transactions you conduct using our services; or
  2. from your devices when you use your device to connect to RUPIFI’s Services, we receive information about that device, including IP address, hardware model, operating system, and other technical information about the device. We also use cookies or similar tracking technologies to collect usage statistics and to help us provide and improve our services.
  3. from your financial institutions when you link your primary bank account to RUPIFI’s Services, we may collect several categories of your information, including Account information, including your financial institution’s name, the account type you use (such as a “checking account” or “savings account”), account number(s), and the institution’s routing number; Information about any balance or transactions in your account; and Information about the account owner(s), including name, email address, phone number, and mailing address information.
  4. from other sources including our service providers. We currently use the following agencies to collect data:-
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    (i) Signzy Technologies Pvt Ltd
    (Ii) Karza Technologies Private Limited
    (iii) Digiotech Solutions Pvt Ltd
    (iv) CRIF High Mark Credit Information Services Pvt Ltd
    (v) Experian Credit Information Company of India Pvt Ltd

2.5 The Website or Platforms may include links to third-party websites, plug-ins and applications (including cookies, tracking technologies and widgets by third party advertisers), it is important that you understand that by clicking on those links or enabling those connections, you may allow third parties to collect or share data about you. Rupifi is not responsible for use of your Personal Information or Sensitive Personal Information by such third parties and it is advisable to read such third party’s privacy policy under which your data will be processed.


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Why we collect, use and store the personal data
3.1 Verification, Authentication and Processing of Application purposes:
‍We process your Personal Information (including Sensitive Personal Information) for creating login credentials or establishing an account based relationship, doing KYC evaluation and risk assessments in order to authenticate and authorize your use of our products or services depending on if you are a merchant, consumer, borrower, service provider or business partner, and your choice of services or products. The type of Personal Information (including Sensitive Personal Information) typically required is Identification Information, Identity, and Account Log-In Information, Contact Information and Financial Information. This is necessary to fulfil our legal obligations under certain applicable laws of India.To provide product/s or service/s made available by Rupifi or the merchant or a third party service provider, including financial institutions or in combination of all or any of the above.

3.2 To do internal risk assessments and analysis
‍We may process your Personal Information (including Sensitive Personal Information) for the purposes of risk assessments and evaluations including or KYC checks, to improve our services, reduce fraud rates, build risk models, etc. We may also share such analysis with our business partners who may rely on the same to make decisions regarding whether to offer their products or services to you. Such analysis as described above does not usually utilise any Sensitive Personal Information about you and mostly your Personal Information is used for these purposes.

3.3 Collection of Personal Data for propagating business.
‍From time to time, we may request aforementioned Personal Data from you to process your applications, and to get valuable feedback from your experience. In addition, we may also use your Personal Data for other business purposes or in order to help serve you better, such as informing you of new services, or alliances that could help you in your career or business. We will take reasonable steps to ensure that your Personal Data is accurate and complete.

3.4 Disclosure to third parties
‍We may disclose Personal Data to third parties. This disclosure may be required for us to check your eligibility for, provide you access to, and enable fulfilment of any services being provided to you, or to comply with any legal obligations, to enforce user agreements, to facilitate any marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to any services being provided to you. You expressly consent and agree to such disclosures to third parties. We may disclose your personal information to third parties, such as business partners, service providers. This disclosure may be required for us to provide you access to our products and services; for enhancing your experience; for providing feedback on products; to collect payments from you; to comply with our legal obligations; to conduct market research or surveys; to enforce our Terms of Use; to facilitate our marketing and advertising activities; to analyse data; for customer service assistance; to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our product and services. We do not disclose your personal information to third parties for their marketing and advertising purposes without your explicit consent. We may disclose personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process. We may disclose personal information to law enforcement agencies, third party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce our Terms of Use or Privacy Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our users or the general public. We and our affiliates will share / sell some or all of your personal information with another business entity should we (or our assets) plan to merge with, or be acquired by that business entity, or re-organization, amalgamation, restructuring of business. Should such a transaction occur that other business entity (or the new combined entity) will be required to follow this Privacy Policy with respect to your personal information.

3.5 Collecting Personal Data for online surveys
‍At times, we conduct online surveys to better understand the needs and profile of our visitors. When we conduct a survey, we will inform you about how we will use the Personal Data prior to your taking the survey. If you do not want to participate in the survey, you may refrain from contributing to it at your own discretion.

3.6 Use of cookies
‍The Company tracks information provided by visitor’s browser, including the website the visitor came from (known as the referring URL), the type of browser used and other information that does not personally identify any visitor of the RUPIFI’s website. This may include installation of cookies and collection of other session data.

3.7 IP address The RUPIFI website uses Internet Protocol (IP) Addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a “dynamic” address). We use your IP address to report aggregate information on use and to help improve our services.

3.8 To protect our business and to ensure compliance with the law
‍We process your Personal Information (including Sensitive Personal Information) to meet the requirements of applicable laws, regulations, standards, rules, codes and the requirements as may be applicable on non-banking financial institutions and other codes with which We must comply. This includes:
  • authenticating and validating your access to your account or to mitigate and protect against identity theft or fraud. To do this, some of your Personal Information (including Sensitive Personal Information) and non-Personal Information may be collected by us or these may be directly or indirectly delivered to us by merchants, group companies or other business partners. We  will use this Personal Information (including Sensitive Personal Information) for the purpose of anti-fraud systems and this may be retained by us for our future use for reference and cross-reference of information;
  • consulting and reporting your Personal Information (including Sensitive Personal Information) and behaviour on monetary obligations to legitimately constituted financial, commercial or service risk centres, or to other financial institutions, under applicable laws of India or in furtherance to contracts;
  • verifying your identity and comparing your Personal Information (including Sensitive Personal Information) to verify accuracy for reporting obligations under applicable laws or payment scheme rules or KYC norms;
  • processing your information for the purpose of ensuring compliance under applicable laws and for resolving or contesting any claims made by or against you against us or our group companies, our business partners or any other third party;
  • processing or using your Personal Information (including Sensitive Personal Information) if you exert your right of refusal for any of our services or any services provided by us or our group companies, our business partners or any other third party; and
  • processing (including storing or using) your Personal Information (including Sensitive Personal Information) to ensure business continuity of our businesses and appropriate disaster recovery for the Websites and Platforms, services and products.
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How do we use this information
We use the information we collect to operate, improve, and protect the services we provide, and to develop new services. For example, we use your information to:

i provide RUPIFI’s Services;
ii improve, modify, add to, or further develop RUPIFI’s services;
iii protect you, RUPIFI’s service providers, or RUPIFI from fraud, malicious activity, or other privacy and security-related concerns
iv provide customer service to you
v investigate any misuse of RUPIFI’s Services; and
vi develop new services.
vii connect with you and assist you
viiiprovide merchants with statistical insights and reports
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Our steps to protect your information
5.1 The security of your Personal Information and Sensitive Personal Information is important to us. We take steps designed to protect your information that we collect, maintain, or disclose. These steps include maintaining information security controls, such as encryption technologies when transferring data or even when storing data, firewalls, and controls over the physical access to our systems. We regularly evaluate the security controls that we use, as well as the controls that our service providers use, for protecting the security and confidentiality of your information. Our goal is to maintain effective security controls, as measured by relevant industry standards or by independent security auditors, for all of the ways that you can use RUPIFI’s Services. We take all measures to to prevent alteration, loss or fraudulent or unauthorized access of your Personal Information (including Sensitive Personal Information). We have put in place procedures to deal with breach of Personal Information and will notify you and any applicable regulator or authority of a breach where we are legally required to do so.

5.2 RUPIFI may keep your information for as long as necessary to fulfil the purpose for the information is collected. In addition, for some types of your information, RUPIFI may apply a longer retention period, such as for research or statistical analyses, except when storing or using that information for longer periods of time is not permitted under applicable law. As permitted under applicable law, even after you stop using the RUPIFI’s services or terminate your account with RUPIFI, we may retain your information.
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Your Consent to Rupifi to share/ process/ use and store your Personal Information
We process Sensitive Personal Information only when we have obtained your consent in manner provided hereinunder. For collecting, processing (including using and storing), disclosing or sharing your Sensitive Personal Information as described in this Policy, we hereby through this Policy, seek your consent and give you a notice regarding collecting, processing (including using and storing), and sharing your Sensitive Personal Information for one or more of the purposes detailed herein. For any purposes, where, as per applicable laws of India, a specific consent is required, we will seek such specific consent from you from time to time. In relation to information obtained from third parties or group entities, we rely on the consent taken herein in our favour for us to process the information. You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some or all of the features and functionalities of the Websites and the Platform. This may also affect our ability to process your Personal Information (including Sensitive Personal Information) and may therefore lead to the non-availability or discontinuation of the services for which such Personal Information (including Sensitive Personal Information) are to be used or was being used, at our sole discretion.
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Our rights to disclose your information
RUPIFI makes various types of disclosures of your information to other persons as permitted by law. Our disclosures of your information may apply to some or all of the categories of your information that we collect. For example, RUPIFI may disclose all of the types of your information with your financial institution, consistent with your consent or instruction. RUPIFI also discloses, or reserves the right to disclose, your information:

  • With RUPIFI’s service providers or contractors in connection with the services they perform for RUPIFI;
  • To the extent permitted by law, it will be necessary for us to verify the details you have supplied. Such verification could be done through third party service providers, who shall be bound by the obligation of confidentiality and data protection.
  • If RUPIFI believes in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process (such as a court order or subpoena);  
  • In connection with a change in ownership or control of all or a part of RUPIFI’s business (such as a merger, acquisition, or bankruptcy);
  • Between and among RUPIFI and RUPIFI’s future affiliates (such as subsidiaries or other companies under common control or ownership); or
  • With your consent (by any reasonable method, including when you orally give your consent), unless you timely revoke your consent.
  • We may collect, use, process, or disclose your information in an aggregated or anonymized manner (i.e., in a manner that does not identify you personally) for any purpose permitted under applicable law.
  • As a convenience to our visitors, this RUPIFI website may contain links to a number of sites that we believe may offer useful information. The policies and procedures we described here may not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.
  • We will process, disclose or share your Personal Data only if required to do so by law or in good faith belief that such action is necessary to comply with our contractual obligations, legal requirements or legal process served on us.
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Withdrawal of consent
If you change your mind after opting-in, you may withdraw your consent to contact you, for the continued collection, use or disclosure of your information, at any time, by mailing us at contact@rupifi.com However, if you have availed any of our services, we shall have the right to continue processing your information till such engagement persists.

However, we shall not retain your data and information if it is no longer required by us and there is no legal requirement to retain the same. Do note that multiple legal bases may exist in parallel and we may still have to retain certain data and information at any time.  
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Right to rectification
In the event that any personal data provided by you is inaccurate, incomplete or outdated then you shall have the right to provide us with the accurate, complete and up to date data and have us rectify such data at our end immediately. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our services is uninterrupted.
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Contacting Rupifi
If you have any question about this Privacy Policy or wish to contact us for any reason in relation to the Personal Data processing, please contact us by mailing /write to us at contact@rupifi.com or call us at 080 4705 5161.
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Contacting our Data Protection Officer (DPO)
Rupifi Technology Solutions Private Limited has appointed a Data Protection Officer (DPO) to oversee privacy matters. If you have any questions about this Privacy Policy or wish to contact us regarding the processing of your Personal Data, you can reach out to our DPO Jahangeer Wani at jahangeer.wani@rupifi.com.