INTRODUCTION
We at TRANSBNK Solutions Pvt. Ltd (TRANSBNK) are committed to protecting the privacy and security of its users (“user(s)”, “your”, or “you”). User and their customers privacy is important and maintaining User trust is paramount to us. This Privacy Policy (“Privacy Policy”) explains how we collect, use, process, and disclose, User or their customers information. By using our website/ app/ platform and affiliated services, User consent on their and their customers behalf to the terms of our privacy policy (“Privacy Policy”) in addition to our ‘Terms of Services.’
General Definitions
“Act” shall mean the Information Technology Act, 2005, and Rules thereunder as amended from
time to time and the Consumer Protection (E-Commerce) Rules, 2020.
“Information” shall mean and include Personal Information and Sensitive Personal Data and
Information as may be collected by TRANSBNK.
“Personal Information (PI)” shall have the same meaning as under Rule 2 (i) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 as amended from time to time. For ease of reference Rule 2 (i) of the Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 is re-produced under Schedule 1.
“Rules” shall mean the Information Technology (Reasonable security practices and procedures
and sensitive personal data or information) Rules, 2011 as amended from time to time.
“Registered User” shall mean such user whose registration is accepted by TRANSBNK.
“Sensitive Personal Data and Information (SPDI)” shall mean and include information under
Rule 3 of the Information Technology (Reasonable security practices and procedures and
sensitive personal data or information) Rules, 2011 as amended from time to time. For ease of
reference Rule 3 of the Information Technology (Reasonable security practices and procedures
and sensitive personal data or information) Rules, 2011 is re-produced under Schedule 1.
“Services” for the purpose of this Privacy Policy shall mean any person who by way of
registration has sought or in any manner has requested the services of TRANSBNK.
All words and expressions used and not defined in this document but defined in the Act or the
Rules shall have the meanings respectively assigned to them in the Act or the rules.
"User" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
We encourage User to read this privacy policy to understand the collection, use, and disclosure information from time to time, to keep Users updated with the changes and updates that we make to this policy.
WHAT INFORMATION DO WE COLLECT?
Users may use TRANSBNK’s website to access Information, learn about its products and services, read publications and check career opportunities etc. without providing any PI/SPDI. However when a User agrees to use our services then they will have to share their or their customers information with us.
TRANSBNK may collect and process PI/ SPDI provided by User in the following forms:
(a) Should User opt to access such services of TRANSBNK, which are available only to
Registered Users, certain Information is required to be provided by User at registration
as specified below. Providing additional information beyond what is required at the time of
registration is entirely optional and can be altered or removed by User at any time.
Registered Users are given access to the web portal/business applications based on
the password-based authentication which is chosen by them and securely stored in
TRANSBNK servers for the purpose of authentication of the Registered Users at the time
of login;
(b) Information that User provide directly to TRANSBNK via email or electronic ommunication;
(c) Information that User provide to TRANSBNK through any mode/medium include telephone. TRANSBNK may make and keep a record of such information shared by User;
(d) Information that TRANSBNK has access to from third parties on behalf of the User so that they can provide services;
(e) Information that User provide to TRANSBNK in physical form whether sent through post or courier or handed over to a TRANSBNK representative in person; and
(f) PI/SPDI collected by TRANSBNK from its employees, suppliers or onsite consultants for
the purpose of employment, availing their services and recording their attendance
etc.
(g) PI/SPDI collected by TRANSBNK from its partners for the purpose of providing services to its Registered Users or enabling services for a set of customers.
TRANSBNK will try to minimize the PI/SPDI collected for a User. However, if PI/SPDI has been shared with TRANSBNK and certain services are availed basis that PI/SPDI than the same cannot be removed from the platform.
This Privacy Policy applies to:
Information that User may provide to us voluntarily as mentioned above for using our Services, including but not limited to, full name, mobile number, email address, password, photograph, audio file, location, date of birth, gender, Permanent Account Number (PAN), Aadhar details, e-KYC through UIDAI, CKYC through CERSAI, income/salary information, marital status, sexual orientation, biometric data, health status and nominee details. We may also hold financial information, including but not limited to, billing address, bank account details, bank statements, bank transaction details, credit/debit card details, payment related details, payment method data, debit instructions, e-mandates, standing instructions or any other personal/financial information as required by various applicable laws and regulations from time to time to process the Services (“PI/SPDI”).
Certain additional information about User or their customers on a case-to-case basis. Further, when User visit our Platform, we may log certain non-personal information such as their IP address, cookie information, browser type, mobile operating system, manufacturer and model of their mobile device, geolocation, preferred language, access time and time spent.
Any information that is freely available, accessible in the public domain, furnished under the Right to Information Act, 2005 or any other law for the time being in forced, where such information shall not be regarded as sensitive personal data or information. We may also retrieve from records available with third party Know Your Customer (KYC) Registration Agency (KRA), information such as KYC details, KYC status, father’s name, occupation, address details and related documents. We may also verify KYC information from third party resources to ascertain that the information provided by User is correct.
Please note that our Platform may link to third-party websites/apps (“Third-Party Sites”), that may collect User or their customers personal information, for which the Company is not in any manner responsible for the security of such Third-Party Sites or their privacy practices or content. Nonetheless, we seek to protect the integrity of the App and our Platform and welcome any feedback about these websites.
HOW DO WE USE INFORMATION?
We use the PI/SPDI provided by User:
To create User or their customers account, verifying User or their customers identity and process User or their customers transaction(s) on the Platform;
To share with Banks, NBFCs and other partners to enable them to provide services.
To assist Banks, NBFCs and other partners to complete KYC requirements, generate necessary agreements, generate necessary documents, and verify any specific information.
To provide User or their customers Advisory Services on the Platform;
To collect statistics about User or their customers usage of the Platform and its effectiveness;
To improve and personalize User or their customers experience of the Services, as well as customize our interactions with User or their customers to further expand the scope of the Platform;
To resolve disputes, provide customer support and troubleshoot problems that arise from using our Platform;
To help promote a safe service on the Platform and protect the security and integrity of the Platform, the Services and the users;
To collect the applicable fees from User or their customers in relation to the Services;
To inform User or their customers about online and offline offers, campaigns, programs, products, services and/or updates;
To customize User or their customers experience on the Platform or share custom marketing material with User or their customers;
To detect, prevent and protect the Company from any errors, frauds, and other criminal or prohibited activity on the Platform;
To enforce and inform User or their customers about our Terms of Service;
To process and fulfil User or their customers request for Services or respond to User or their customers queries on the Platform;
To contact User or their customers;
To allow our business partners and/or affiliated entities to present customized messages to User or their customers;
To communicate important notices or changes in the Services offered by the Company, use of the Platform, and the terms/policies which govern the relationship between User or their customers and the Company and with our affiliates; and
For any other purpose, for which User or their customers have granted access to such information to us, based on User or their customers interaction with Platform.
We may send User or their customers text messages on User or their customers registered mobile number that User or their customers share with us.
DISCLOSURE OF INFORMATION?
We may disclose User or their customers PI/SPDI, to the extent necessary:
To statutory and regulatory authorities to comply with applicable laws and to respond to lawful requests and due legal process;
To protect the rights, property and safety of the Company, our business and services partners and the users, including to enforce the Terms of Service;
To share with Banks, NBFCs and other partners to enable them to provide services.
To assist Banks, NBFCs and other partners to complete KYC requirements, generate necessary agreements, generate necessary documents and verify any specific information. To our subsidiaries and affiliates, in the ordinary course of business;
To third-party websites;
To third-party service partners, including business partners, affiliates, service providers, authorized payment gateways, collecting banks, KRAs, credit bureaus, etc. for the purpose of billing and collection, providing content, products, customer support etc.;
In case of a corporate sale, merger, acquisition, sale of business, reorganization, dissolution, insolvency or such similar events;
To third parties to market their products/services/campaigns/programs, subject to whether users have either consented or not opted out of these disclosures;
To fulfil the purpose for which the user provided such information;
For any other purpose for which the User provided it;
HOW DO WE RETAIN INFORMATION?
We may store and retain User or their customers PI/SPDI, to the extent necessary:
To carry out the Services for the user/affiliates/partners and others on the Platform.;
Retain and use the information collected as necessary to comply with our legal obligations, resolve disputes or for other business purposes;
Retain PI/SPDI for 60 months after User or their customer cancel/ deactivate/ unsubscribe User or their customers account with us, as our business practice; and
Where we have no continuing legitimate business need to process User or their customers PI/SPDI, we will securely store User or their customers personal data and isolate it from any further processing until deletion is possible.
HOW DO WE PROTECT THE INFORMATION WE COLLECT?
We are dedicated to guarding the security of User or their customers information and our Platform has several industry-standard security technologies and procedures devised to help protect User or their customers data from unauthorized access, use, destruction or disclosure, including technical and organizational security measures to protect the security of User or their customers personal data both online and offline. The App receives regular security scans and penetration tests. In addition, we actively prevent third parties from getting access to the personal information of Users that we store and/or process on the servers. We will implement reasonable security measures every time User or their customers (a) enter, submit, or access User or their customers information, (b) register, or (c) access the App.
HOW DO USER OR THEIR CUSTOMERS UPDATE INFORMATION?
User specifically consent and agree that the Personal Information pertaining to User or their customers account on the Platform shall be both accurate and current. As per the existing legal regulations, specific data fields (such as name, Aadhar number, address etc.) in User or their customers Personal Information would be locked in our systems once User or their customers enter that information in our Platform.
We will respond to all requests in accordance with the applicable laws.
HOW DO USER DELETE/DEACTIVATE ACCOUNT?
TRANSBNK does not sell, trade, or otherwise transfer to outside third parties any Personal Information. Please note that (i) if we delete User or their customers Personal Information as requested, we will no longer be able to provide our Services to User or their customers and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. Users also have the option to request for an account deactivation instead. This will temporarily block user access to the App and the Platform until they send a re-activation request and successfully re-activate their account. Kindly note that deletion of Personal Information will be decided on a case-to-case basis as there may be cases owing to certain reasons, we cannot delete any account.
We may retain User or their customers’ personal information in accordance with appliable laws, for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. However, we may retain data related to User or their customers if we believe it may be necessary to prevent fraud or future abuse, to enable TransBnk to exercise its legal rights and/or defend against legal claims or if required by law or for other legitimate purposes. We may continue to retain User or their customers data in anonymized form for analytical and research purposes.
WILL WE UPDATE THE PRIVACY POLICY?
We reserve the right, at our sole discretion, to revise, change or modify this Privacy Policy from time to time and such modifications shall be binding upon User or their customers’. Therefore, we urge User or their customers to review the Privacy Policy periodically to ensure that User or their customers agree with our latest information on our privacy practices.
COPYRIGHT POLICY
The contents of this website and the Platform may not be reproduced partially or fully, without due permission from TRANSBNK, as per the Copyright Act, 1957. If referred to as a part of another publication, the source must be appropriately acknowledged. The contents of this website cannot be used in any misleading or objectionable context.
GOVERNING LAW
This Privacy Policy shall be governed by the law of the republic of India, without respect to its conflicts of laws principles. Each of the parties to this Privacy Policy consents to the exclusive jurisdiction and venue of the courts located in New - Delhi, India for any actions not subject to Dispute Resolution and Arbitration provisions as set forth below in (Dispute Resolution).
DISPUTE RESOLUTION
Any claim, dispute or difference relating to or arising out of this Terms of Service and Platform Privacy Policy shall be referred to the arbitration, of a sole arbitrator appointed mutually. The arbitration shall be subject to the Arbitration and Conciliation Act, 1996 as may be amended from time to time. The seat and venue of arbitration shall be New - Delhi, India. The proceedings shall be undertaken in English. The arbitration award shall be final and binding on the parties.
PRIVACY QUESTIONS
To ask questions or comment about this Privacy Policy and our privacy practices, please contact us at:
Email: admin@transbnk.co.in
Address: M-32 (Market), First Floor, Greater Kailash 2, New Delhi - 110048
GRIEVANCE REDRESSAL MECHANISM
In accordance with the Information Technology Act, 2005 and the rules made thereunder, i.e. Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 and Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 the name and contact details of the Grievance Officer are provided below. Any complaints, abuse or concerns with regards to the use, processing, deletion and disclosure of Information provided by User or their customers or breach of these terms should immediately be informed to the designated Grievance Officers as mentioned below via in writing or through email signed
Name: Srishti Agarwal
E-mail: Srishti.agarwal@transbnk.co.in
Address: M-32 (Market), First Floor, Greater Kailash 2, New Delhi - 110048
Telephone: +91 11-41415558
We request User to please provide the following information in their complaint/Grievance: -
a) Identification of the information provided by User;
b) Clear statement as to whether the information is personal information or sensitive personal information;
c) User address, telephone number or e-mail address;
d) A statement that User have a good-faith belief that the information has been processed incorrectly or disclosed without authorization, as the case may be;
e) A statement, under penalty of perjury, that the information in the notice is accurate, and that the information being complained about belongs to User;
The Company may reach out to User to confirm or discuss certain details about Users complaint and issues raised.
The Company shall not be responsible for any communication, if addressed, to any non-designated person in this regard.
In accordance with the Consumer Protection (E-Commerce) Rules, 2020, the name and contact details of the Customer Care Service and Grievance Officer of Transbnk solutions Private Limited are provided below:
Phone: +91 11-41415558
Email: admin@transbnk.co.in
Name: Srishti Agarwal
E-mail: Srishti.agarwal@transbnk.co.in
Address: M-32 (Market), First Floor, Greater Kailash 2, New Delhi - 110048
Telephone: +91 11-41415558
For any complaints or grievances received, our Grievance Officer shall acknowledge the receipt of the consumer complaint within forty-eight (48) hours and redress the complaint within one (1) month from the date of receipt of the complaint.
Schedule 1
Rule 2 (i)
“Personal information" means any information that relates to a natural person, which, either
directly or indirectly, in combination with other information available or likely to be available
with a body corporate, is capable of identifying such person.
Rule 3
Sensitive personal data or information of a person means such personal information which
consists of information relating to:-
(i) password;
(ii) financial information such as Bank account or credit card or debit card or other payment
instrument details ;
(iii) physical, physiological and mental health condition;
(iv) sexual orientation;
(v) medical records and history;
(vi) Biometric information;
(vii) any detail relating to the above clauses as provided to body corporate for providing service; and
(viii) any of the information received under above clauses by body corporate for processing,
stored or processed under lawful contract or otherwise:
provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of these rules.