Purpose:
The purpose of this document is to define broad policy applicable to protection of "Privacy" of
individuals whose information directly or indirectly processed or collected from you through the
"Jupiter Edge" mobile application by LivQuik Technology (India)
Private Limited ("Company" or "LivQuik"). This policy will also be reflected in the website of
the
Company when available. It will also be reflected in the Privacy Practice Statement that may be
shared with business associates where
required.
Scope, Purpose, Nature and period of the data collected:
-
This Policy applies to Jupiter Edge customers who has visited Jupiter Edge mobile
application and/or has agreed to or has enquired to open an account/or initiated process
to
open a account with Jupiter Edge.
-
LivQuik may collect non-personal information and “Personal Information” will inter alia
include any information which is directly or indirectly available with us to identify or
verify individual identity. This may also include sensitive personal data
which inter alia includes phone number, financial information such as bank account,
credit
and debit card details, biometric information.
Jupiter Edge process/collect data received (a) directly from you through Jupiter Edge or
through
different communication channels or the services or product you entail to use and when you
provide your details in forms, surveys, online applications or
similar online fields (b) indirectly from third party sources including but not limited to
credit institution companies, market research, publicly available information, payment
gateway
companies, business partners, financial institutions.
All these data are processed in
regard
to providing you better services and product, managing our relationship with you, fulfilment
of
contractual and regulatory obligations.
Privacy Commitment
LivQuik values privacy rights of individuals whose personal information is generated, processed,
transmitted, stored or otherwise accessed by LivQuik or any of its employees of the Company as a
part of our activities and are committed to protection of
the privacy rights of such individuals as required under law.
In particular, LivQuik has put
in
place reasonable managerial, operational, technical, legal, behavioral control measures to
comply
with the provisions
of the Privacy and Security obligations as required under law.
No Personal Information is either used or disclosed by LivQuik except as required or as
permitted or as authorized and this policy is strictly binding on all the employees of the
Company
as well as the business associates.
Changes
LivQuik reserves the right to change the privacy practices at its sole discretion. Whenever a
material change is made to the privacy practice, a revised Privacy Policy will be posted on the
website. Where feasible, stakeholders will also be informed through
electronic means. Continued access or use of the Jupiter Edge or its services constitutes your
acceptance of the changes and the amended Privacy Policy.
Company uses commercially
reasonable
efforts to ensure
that the collection of Personal Information is limited to that which is necessary to fulfill the
identified purposes. In case of use of information in a manner different than the purpose for
which
it is collected, then consent will
be obtained prior to such use.
Transfer of Information
You expressly consent to share your Personal Information with our business partners, third
party,
collection agencies, regulated entities (including but not limited to NBFCs and Banks) for the
purpose of improving existing services, data enrichment, generate
affluence score, outsourcing relationship management activity, collection of overdues, launch of
ancillary service or product.
Company may share your Personal Information when required by
law
enforcement, regulatory
bodies, government officials, fraud detection agencies, financial institutions or other third
parties as and when we are compelled to do so under applicable laws, courts, judicial and quasi-
judicial authorities and tribunals, arbitrators
and arbitration tribunal. You further understand that we may use your Personal Information that
is
collected by us to market our product and services including product and services of our
business
partners, independent service providers
and/or our group entities and affiliates and to notify you about offers, sponsorships, marketing
programmes and similar marketing campaigns.
Company may also process and analyse your
information that we have of you to understand
your usage trends and preferences, and to develop and market (either ourselves or through our
group
companies, our business partners or any other third parties) new products, services, features
and
functions to you based on such analysis
of your Personal Information.
Enforcement
LivQuik is responsible to facilitate RBI, NPCI, PCI DSS, ISO and other agencies nominated by
RBI/
NPCI, to access the data, information, systems of technology service provider related to Wallet
and
carry out audits as and when required by RBI and NPCI
Cookies
LivQuik may use third-party companies to serve advertisements on our behalf. These companies may
employ cookies and action tags (also known as single-pixel gif or web beacons) to measure
advertising effectiveness. Any information that these third parties
collect via cookies and action tags is completely anonymous.
Who can access Personal Information?
LivQuik follows a strategic principle whereby, access to Personal information is restricted only
to
such of employees or third party entities including but not limited to NBFCs and Banks, who are
required to access the information for the purpose of delivering
whatever services are committed to be delivered by LivQuik
Compliance, Grievance and Nodal Officer
The Company has designated the following person as the Privacy and Information Security
Complianc,
Grievance and Nodal Officer for implementation of all compliance and grievance requirements
under
this Information Security Policy.
Name: Madhur Karnik
Contact Details:
madhur.karnik@livquik.com
Confidentiality
Personal Information is regarded as confidential and therefore will not be divulged to any third
party except as set forth in this and any other term of use applicable to our services.
How we Secure Personal Information
Data is secured in the facilities of LivQuik under a well-developed information security policy
as
well as an IT Act 2008 compliance policy. Sensitive data both in storage and transmission are to
be
encrypted with appropriate encryption tools with strong
cryptographic algorithms. Currently the recommended algorithm is AES/3DES 128 bit encryption or
above or similar to the same as approved by organization. All transmission must be under secure
transmission protocol i.e. HTTPS/SSL. Winzip
to be employed to create secure encrypted format of files before transmission.
Exceptions where necessary are properly authorized and monitored.
Personal information
no
longer required is destroyed subject to requirements of archival guided by the Company internal
policies.
Information in process is closely monitored through appropriate technical means to ensure
that
there is no accidental or intentional compromise of security.
Any accidental access to
personal
information is recorded as a security
incident and managed as per the Information Security Incident Management Policy.
How we use or Disclose Information
Personal Information is used or disclosed strictly in accordance with the provisions of law and
as
authorized by the data owner/customer.
DATA RETENTION
Notwithstanding anything to the contrary mentioned elsewhere in this policy, LivQuik may
store/retain your Personal Information for as long as the same is required for the fulfilment of
purposes for which we collected it. The retention of the information
by LivQuik is determined by considering compliance with legal (contractual, statutory or
regulatory
requirements), accounting and compliance reporting requirements. Retention of your combined
information will also be applicable pursuant
to cancellation/ deactivation/ non-subscription of your account with us or with our business
partners.
YOUR RIGHTS
LivQuik seeks to provide reasonable assistance to cater to request from you regarding the
processing of your Personal Information and the right to amend and withdraw permission to
the
processing of your Personal Information. In accordance with applicable
laws and as per our policies, you can exercise the following right:
Access to your information |
You may request record of your Personal Information being processed by us, upon
the
verification of your identity and other information as per the Company internal
policy
|
Review, Correct and Rectify your information |
You may review, correct or rectify the inaccurate Personal Information that is
stored with us |
Withdrawing your consent |
(a)You may withdraw a consent to processing that you have given us and prevent
further processing of your Personal Information subject to the terms of this
Privacy
Policy; (b) You may also withhold your consent prior to
the collection and processing of your combined information |
You can exercise any of the aforementioned rights by submitting a request to
edge-support@jupiter.money.
These rights are limited in some
situations, such as, where we are legally or otherwise bound to
process or retain your Personal Information. This may also affect our ability to
provide you service and therefore may lead to discontinuation of the service you procure
from
LivQuik.
Grievance Redressal Framework and Resolution Mechanism
LivQuik is a transparent and ethical company & expects that its ethics and values are
intentionally
upheld all across. All grievances involving but not limited to rights conferred, compensation,
refunds, and other claims through this policy will be resolved
through our Grievance Redressal Mechanism set forth in our Terms of Service and Information
Technology Rules, 2011 and Master Directions issued by RBI thereof in this regard.
LivQuik
shall
ensure adherence to
all regulatory guidelines / requirements of card networks / wallet in terms of reconciliation on
T+1
days nearby the Auto reconciliation if any dispute raised at time of reconciliation, we will
follow
the TAT of positions at daily
/ weekly / monthly frequent basis.
LivQuik shall also adhere to all dispute resolution and
customer grievance redressal mechanisms as prescribed by Regulatory Authorities. LivQuik shall
also
provide an Online Dispute Resolution
(ODR) system for resolving customer disputes and grievances pertaining to digital payments,
using a
system-driven and rule-based mechanism with zero or minimal manual intervention.
LivQuik
initiate action to resolve all customer
complaint / grievance expeditiously, preferably within 48 hours and endeavor to resolve / reply
the
same not later than 30 days from the date of receipt of such complaint / grievance, also LivQuik
shall display its approved policy,procedure
along with the details of grievance escalation matrix in its website for wider dissemination.
Escalation
The CTO of the Company shall be the appeal authority in respect of any grievance which remains
unresolved beyond 20 days from the date of receipt of grievance at the level of the Compliance
Official.
Name: Yudhajit Nag; email: yudhajit.nag@livquik.com