Your privacy matters to Convergesoft Technologies (the “Company”, “we”, “PayPass”, “us” or “our”).
This Privacy Policy (“Policy”) describes the policies and procedures on the collection, use, processing, storage, retrieval, disclosure, transfer and protection of your information, including personal information and sensitive personal data or information (“Information”), that PayPass may receive through your online access, interaction or use, of the PayPass mobile applications (“PayPass App”) or our website located at https://paypassapp.in, (the website and PayPass App are collectively referred to as the “PayPass Platform”) or through your offline interaction with us including through mails, phones, in person, etc., or while availing our Services.
The terms “you” and “your” refer to a Customer (defined below), a Vendor Partner (defined below) or any other user of the PayPass Platform and / or availing the Services (defined below).
The term “Services” refers to any services offered by PayPass in accordance with the terms and conditions applicable to you (and available on the PayPass Platform) whether on the PayPass Platform or otherwise.
Please read this Policy before using the PayPass Platform or submitting any Information to PayPass. This Policy is a part of and incorporated within, and is to be read along with, the terms and conditions applicable to the users of the PayPass App available on the PayPass Platform.
USER ACCEPTANCE
By accessing or using the PayPass Platform or the Services, you agree and consent to this Policy, along with any amendments made by the Company at its sole discretion and posted on the PayPass Platform from time to time.
Any collection, processing, retrieval, transfer, use, storage, disclosure and protection of your Information will be in accordance with this Policy and applicable laws including but not limited to Information Technology Act, 2000, and the rules framed thereunder (“Applicable Laws”). If you do not agree with the Policy, please do not use or access the PayPass Platform.
You hereby represent to PayPass that:
The Information you provide to PayPass from time to time, is and will be authentic, correct, current and updated and you have all the rights, permissions and consents as may be required to provide such Information to PayPass.
Your providing of the Information as well as PayPass's consequent storage, collection, usage, transfer, access, or processing of such Information will not be in violation of any agreement, Applicable Laws, charter documents, judgments, orders and decrees.
If you disclose to us any Information relating to other people, you represent that you have the authority to do so and to permit us to use such Information in accordance with this Policy.
DEFINITIONS
Unless otherwise provided in this Policy, the terms capitalized in the Policy shall have the meaning as provided hereunder:
“Customer” shall mean a person who wishes to receive services or Vendor Partners on the PayPass Platform.
“Device” shall mean computer, mobile or other device used to access the Services.
“Device Identifier” shall mean IP address or other unique identifier of the Device.
“Promotion” shall mean any contest and other promotions offered by us.
“Personal Information” shall mean such categories of information that could reasonably be used to identify you personally, including your name, e-mail address, and mobile number.
“TPSP” shall mean a third-party service provider.
“Usage Information” shall have the meaning assigned to the term in paragraph 3(II) hereto.
WHAT INFORMATION DO WE COLLECT?
INFORMATION YOU PROVIDE TO US
Personal Information: We may ask you to provide certain Personal Information to us. We may collect this information through various means and in various places for the provision of Services, including account registration forms, contact us forms, or when you otherwise interact with us. When you sign up to use the Services, you create a user profile. We shall ask you to provide only such Personal Information which is for lawful purpose connected with our Services and necessary to be collected by us for such purpose.
The Information you provide to us includes the following:
Account Information: Create or update your PayPass account which may include your email address, name, address, mobile number, gender, date of birth, photograph, login name, password, banking or payment related information (as permitted by Applicable Laws), etc.
Saved Information: While you use our Services, we may collect and store Information about you to process your requests and automatically complete forms for future transactions, including (but not limited to) your phone number, address, email address, billing information, etc.
Verification Information: If you are a Service Vendor Partner, we may collect location details, government issued identification documents such as GSTIN, Permanent Account Number and other details (KYC), certificate of registration, user settings.
Other Information: We collect additional Information you provide when you correspond with PayPass for customer support or report problems for troubleshooting. We also collect Information that you may submit electronically such as when you use in-app messaging, post on any message boards, provide ratings, reviews, or comments. In case you refer a friend, we may also collect, store, and use the name and contact information of your friend to promote our Services.
INFORMATION WE COLLECT AS YOU ACCESS AND USE PAYPASS APP
Location data:
Customers: We collect precise or approximate location data from your Device if you enable us to do so. PayPass collects this data to list services near your location and to search Services and any time the app is running in the foreground of your Device. We use this data to enhance your use of PayPass App, including to improve search result.
Usage Information: We, our TPSP and the Vendor Partner may use a variety of technologies that automatically (or passively) collect certain Information whenever you visit or interact with the PayPass Platform for obtaining the Services (“Usage Information”). This Usage Information may include the browser that you are using, the URL that referred you to our Services, all of the areas within our Services that you visit, and the time of day, searches and search results, or usage behavior on the PayPass App, etc.
Device Information: We collect Information by ourselves or through integration with third-party applications which consists of technical information and aggregated usage information, and may contain, among other things, Device Identifier of your Device, manufacturer, software, and model of your Device, Device type, operating systems and versions, your geolocation, etc., to enhance user interface and experience on PayPass Platform, facilitate the provision of software updates, product support and other services to you, etc. Any sensitive information about other programs that you are running on your Device, passwords, and activity across other applications are not collected and all the sensitive information are masked.
SMS/Text Messages: We may collect data from SMS/ text messages upon receiving Device access permissions from you for the purposes of (i) issuing and receiving one-time passwords and other device verification, and (ii) automatically filling verification details during financial transactions, either through us or a TPSP, in accordance with Applicable Laws. We do not share or transfer SMS/ text message data to any third party other than as provided under this Policy.
Other Information: We collect Information about how you interact with the PayPass App and any of our web sites to which the PayPass App links, such as how many times you use a specific part of the PayPass App over a given time period, the amount of time you spend using the PayPass App , how often you use the PayPass App, actions you take in the PayPass App and how you engage with the PayPass App, etc.
INFORMATION THIRD PARTIES PROVIDE ABOUT YOU
We may, from time to time, collect Information about you through PayPass Platform or while availing the Services and collect Information from our affiliates or third parties / TPSPs such as technical sub-contractors, business partners, analytics providers, search information providers, payment service providers, etc., and also from publicly available sources such as commercially available marketing lists, social networks and other related media.
USE OF INFORMATION COLLECTED
Our primary goal in collecting your Information is to provide you with an enhanced experience when using the Services. We may use your Information we collect in accordance with this Policy for the following purposes:
To enable you to access the PayPass Platform;
To verify your identity and/ or your capacity, under applicable law, to provide Services through the PayPass Platform;
To send you a welcome email/SMS to verify your username and password;
To provide you the correct app version depending on your Device type, for troubleshooting and in some cases, marketing purposes;
To help diagnose problems with our computer server, and to administer PasPass Platform;
To send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email. If you do not wish to receive them, you have the option to deactivate your account;
To prevent, discover and investigate violations of this Policy or any applicable terms of service or terms of use;
To identify and/or detect security breaches or attacks, errors, fraud, money laundering, abuse and other criminal activities, and investigating and taking appropriate remedial action;
We provide some of your Personal Information (such as your name, contact number) to the Service Vendor Partner who accepts your request for Services so that the Service Vendor Partner may contact and find you;
If you are a Customer, we use geo-location information for various purposes, including for you to be able to view the Services in your area that are close to your location to provide services to you, to automatically fetch your location when you open the PayPass App;
If you are a Service Vendor, we use the geo-location information for you to enable the Customers to search service based on locations and to share the exact location for the safety of the Customers, etc.;
We may use your Personal Information or Usage Information that we collect about you: (a) to provide you with information or services or process transactions that you have requested or agreed to receive including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (b) to enable you to participate in a variety of the Services’ features such as online or mobile entry sweepstakes, contests or other promotions; (c) to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or the Services’ policies; (d) for internal business purposes; (e) for inclusion in our data analytics; and (f) for purposes disclosed at the time you provide your Information or as otherwise set forth in this Policy;
To enhance your user experience in relation to the PayPass App or the Services, including customisation / personalization of the PayPass App or the Services;
To provide relevant offers or rewards to you, based on your consumption patterns;
To enforce our terms and conditions and this Policy, and resolve any disputes;
To provide functionality, analyse performance, fix errors, bugs, and improve the usability and effectiveness of the PayPass Platform;
To comply with Applicable Laws or requests received from regulators, government, law enforcement or judicial authorities under Applicable Laws or our contract with a third party;
To carry out our obligations and enforcing rights arising from any contracts between us;
To disclose to affiliates, our and their employees, agents and representatives on a need-to-know basis to facilitate provision of Services;
To deliver any administrative notices, alerts, advice, notifications and communication relevant to your use of the Services, through social media (including WhatsApp), SMS and other media;
If you sign up to use our Services as an employee or as a stakeholder of a third party with whom the Company has an arrangement and has offered discount coupons/ or extended certain promotional offers, the Company may share any information provided by you with such third party to be utilised by them for limited internal business purposes only; and/ or
To fulfil any other purpose for which you provide us the Information and/or for any other purpose with your consent. Please note, we do not use the information collected from you for targeted advertising.
HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES
We do not sell, share, rent or trade the information we have collected about you, other than as disclosed within this Policy or at the time you provide your Information. Following are the situations when Information may be shared:
WHEN YOU AGREE TO SHARE INFORMATION WITH THIRD PARTIES:
You may opt to receive information and/or marketing offers directly from third parties when you access third party links on the PayPass App. If you do agree to have your Personal Information shared, your Personal Information will be disclosed to such third parties and all Information you disclose will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communication from a third party, you will need to contact that third party directly.
THIRD PARTIES PROVIDING SERVICES ON OUR BEHALF
We may share the Information you provide with our TPSPs, business partners, and agents. Please refer to such third-party’s privacy policy for more details before using their services on the PayPass App.
We use TPSPs to facilitate our Services, provide or perform certain aspects of the Services on our behalf – such as host the Services, design and/or operate the Services’ features, track the Services’ analytics, process payments, engage in anti-fraud and security measures, perform background and identity verification, run criminal record checks, provide customer support, provide geo-location information to Service Vendor Partners, enable us to send you special offers, host our job application form, perform technical services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services‘ features), or perform other administrative services. These third parties will have access to Information, including Personal Information to only carry out the services they are performing for you or for us. We will require each of these TPSPs to ensure the same level of data protection as us and impose contractual obligations not to disclose or use Personal Information for any other purpose.
TPSPs providing analytics related services may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to Information about you.
We use a third-party hosting provider who hosts our support section of our website. Information collected within this section of our website by such TPSP is governed by our Policy.
CONTESTS AND PROMOTIONS
We may offer Promotions through the Services that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, you agree that your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
ADMINISTRATIVE AND LEGAL REASONS
We cooperate with Government and law enforcement officials and private parties to enforce and comply with the Applicable Laws. Thus, we may access, use, preserve, transfer and disclose your information (including Personal Information, IP address, Device Information or geo-location data), to government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any Applicable Law, regulation, subpoenas, Governmental requests or legal process; (ii) to protect and/or defend the terms and conditions applicable to use of the PayPass App or the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Company, our Services or any third party; (iv) to protect the safety of the public for any reason; (v) to detect, prevent or otherwise address fraud, security or technical issues; and /or (vi) to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity.
AFFILIATES AND BUSINESS TRANSFER
We may share your Information, including your Personal Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons, including business and operational purposes. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.
MARKET STUDY AND OTHER BENEFITS
We may share your information, including your Personal Information and Usage Information with third parties for any purpose, including but not limited to undertaking market research/ study, conduct data analysis, determine and customize product or service offerings, to improve the products or Services or to make any other benefits/products/ services available to you.
THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES
The Services may contain content that is supplied by a third party, and those third parties may collect website usage information and your Device Identifier when web pages from any online or mobile Services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and controlled by third parties that we do not control, in which case our Policy will no longer apply. We are not responsible for the privacy practices employed by any of these third parties. For example, if you click on a banner advertisement, the click may take you away from PayPass App onto a different web site. These other web sites may send their own cookies to you, independently collect data or solicit Information and may or may not have their own published privacy policies.
Information (including Personal Information) may be collected by third-parties if there is content from the PayPass App that you specifically and knowingly upload to, share with or transmit to an email recipient, online community, website, or to the public, e.g. uploaded photos, posted reviews or comments, or information about you or your ride or booking that you choose to share with others through features which may be provided on our Services. This uploaded, shared, or transmitted content will also be subject to the privacy policy of the email, online community website, social media or other platform to which you upload, share or transmit the content. We are not responsible for the privacy practices employed by any of these third parties.
Our online and mobile Services may include social media features or interactive mini-programs that run on PayPass App. These features may collect Information including your IP address, photograph, which page you are visiting on our online or mobile Services, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our online Services and/or PayPass Platform. Your interactions with these features and widgets are governed by the privacy policy of the company providing them and we will not be responsible or liable for any acts or omissions of such third parties.
In particular, remember that certain third-parties may be located in or have facilities that are located in a different jurisdiction, hence, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which such service provider is, or its facilities are located. We encourage you to note when you leave web pages or links controlled by PayPass App Services and to read the privacy statements of all third party web sites or applications before submitting any Information to such third parties. We will not be liable for any acts or omissions of the third-party service providers.
INFORMATION COLLECTED BY VENDOR PARTNERS
This Policy does not cover the usage of any information about you which is obtained by the Vendor Partners while providing you a Transportation, Delivery, Package or Rentals Services, or otherwise.
CHANGE OF INFORMATION AND CANCELLATION OF ACCOUNT
You are responsible for maintaining the accuracy of the Information you submit to us, such as your contact information provided as part of account registration.
If your Personal Information or Information you provide to us changes, or if you no longer desire our Services, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through the email address mentioned on PayPass Platform, We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
You may also cancel or modify the communications that you have elected to receive from PayPass by following the instructions contained within an e-mail or by logging into your user account and changing your communication preferences.
If upon modifying or changing the Information earlier provided to Us, we find it difficult to provide access to our Services to you due to insufficiency/ inaccuracy of the Information, we may, in our sole discretion terminate your access to the Services by providing you a written notice to this effect on your registered email address.
If you wish to cancel your account or request that we no longer use your Information to provide you services, contact us through email address of the PayPass Platform Please note, we may not be able to provide some or all of the Services in case you disable access to any of your Information as described under this Policy.
We will retain your Information including Personal Information for as long as your account with the Services is active and as needed to provide you services. Even after your account is terminated, we will retain some of your Information including Personal Information and Usage Information ( transaction history) for such statutory time-period as needed to comply with Applicable Laws, to resolve disputes, conclude any activities related to cancellation of an account, investigate, or prevent fraud and other inappropriate activity related to your account, to enforce our agreements, or for other business reasons, etc. After completion of such statutory period, your data may either be deleted from our database or be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes.
SECURITY
The Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your Information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that Information you supply won't be intercepted while being transmitted to us over the Internet or wireless communication, and any Information you transmit to us, you do at your own risk. We recommend that you not disclose your password to anyone.
INFORMATION OF CHILDREN
We do not knowingly solicit or collect Information from children under the age of 18 years. Use of the PayPass App is only available for persons who can enter into a legally binding contract under Applicable Laws.
CHANGES TO THE PRIVACY POLICY
We reserve the right to update / modify, from time to time, this Policy to reflect changes to our Information practices. Any changes will be effective immediately upon the posting of the revised Policy on the PayPass Platform. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the PayPass App prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your use of the PayPass App or availing the Services after an updated Policy becomes effective will indicate your acceptance of the updated Policy.