Privacy Policy of Newbazaar Technologies Pvt Ltd

This Privacy Policy is published and shall be construed in accordance with the provisions of Indian laws and regulations including but not limited to the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under the Information Technology Act, 2000, the Aadhaar Act, 2016 and its amendments, including the Aadhaar Regulations; that require publishing of the privacy policy for the collection, use, storage, transfer, disclosure of Personal Information. If you do not agree with this Privacy Policy do not, in any manner, use our Services or download, install and/or use the Sites.

General

• Newbazaar Technologies Pvt Ltd.(‘ShopSe’, 'we', 'our' or 'us') recognizes the importance of protecting personal details and information and provides this Privacy Policy with respect to the access and use of www.getshopse.in and mobile Application ('Sites / Platforms ') as owned and operated by us and/or our affiliates and payment facilitation services including bill payment services provided by us ('Services'). The term Sites will also include all pages that are sub-domains or are associated or within each Site and all devices, applications, features, technologies, functionalities and other services that ShopSe operates or offers through such Sites.
• For the purpose of this Privacy Policy, the user of Services may be merchants/sellers/billers, customers/buyers/consumers, or any other persons using Services or accessing Sites ('User', 'you' or 'your'). This Privacy Policy will help you understand our policies and procedures regarding the collection, handling and use of your personal information.
• By using our Services through the Sites, you signify your assent to this Privacy Policy and consent to the processing of your Personal Information. Personal Information means and includes all information that can be linked to a specific individual also includes Sensitive Personal Information (all Personal Information which requires heightened data protection measures due to its sensitive and personal nature), both, hereinafter referred to as “Personal Information”, excluding any information that is freely available or accessible in the public domain. Please note, we offer our Sites or Services under our Site only in India

Information Collection

• We collect such information about you which is essential to operate our business and to enable us to deliver and improve our Services. We may obtain the following information about you and your device from which you avail Services

Profiling Information

• For providing Services we require certain information for registration such as your name, physical addresses, postal addresses, location, telephone, mobile and fax numbers; and certain information about your personal identity such as gender, age, photograph etc. For User Identification we may need your PAN card number, KYC related information such as videos or other online/ offline verification documents as mandated by relevant regulatory authorities, your business-related information. Aadhaar information including Aadhaar number or Virtual ID for the purposes of e- KYC/Offline KYC authentication with the Unique Identification Authority of India (UIDAI). Note that submission of Aadhaar information is not mandatory for e-KYC authentication, you can also use other types of information for completing your KYC. Further, we also collect and store your usernames, passwords, email addresses, OTP, your device details such as device identifier, internet bandwidth, mobile device model, browser plug-ins, and cookies or similar technologies that may identify your browser/ our application and plug-ins, and time spent, and IP address and other security-related information that you use for our Sites in relation to our Services.

Service Usage and Transactional Information: For enabling you to make payments using our Services, we may, upon your consent, collect, your financial information such as your bank account or details mentioned on your credit cards or debit cards, or other payment instrument details etc. that are required for a successful transaction. Further, for certain Services, including our bill payment service, we require your bill payment account information such as your account number, payment history, your account history with us etc. We also store transaction details such as amount spent, merchant name, transaction ID, date and time of the transaction, of your transactions. Further, we may also store information relating to your income, employment and lifestyle levels.

Correspondence Information: We collect the content, information about your correspondence, the destination/origin of communications between you and any other person using our Services, which include email communications, blog, chat room and discussion board communications, instant message communications, experts forum communications, facsimile mail communications, membership of mailing lists etc.

Stored Information: We may collect any data or information relating to you which is either created by you or by a third party while availing various ShopSe services, or data which you wish to store on our servers such as usernames, image files, documents, etc. or which may be required to display information to you through our Service.

One Time Password ('OTP'): OTP is a one-time password which is provided by your issuing bank in order to carry out the second-factor authentication of your debit/credit card. If you opt for our 'one tap' feature, you understand that we will be able to retrieve your OTP from the message received on your mobile and populate and submit the OTP on the issuer's page for second factor authentication of your debit/credit card.

Information from other sources: We collect information about your navigation using our Services, for example, the URLs of websites from which you reach our Site, websites or pages of merchants you visit using our Services. Further we may also collect certain information from your sms sent by alphanumeric senders. We and our service providers or business partners may also collect your Personal Information from third parties or information made publicly available including but not limited to:

• credit score, financial history and other information for the purpose of verifying and authenticating a transaction request you place with us to prevent suspicious transactions, or to comply with court judgements and orders, from credit reference and fraud prevention agencies:
• your demographic and photo information including but not limited to Aadhaar number, address, gender, and date of birth as a response received from UIDAI upon successful Aadhaar e-KYC/Offline KYC. Information may be collected at various stages of your usage of the Sites such as:
• visiting our Sites
• registering on the Site as an “user” or “merchant” or any other relationship that may be governed by terms and conditions listed on the Site
• transacting or attempting to transact on the Site
• accessing links, e-mails, chat conversations, feedbacks, notifications sent or owned by ShopSe and if you opt to participate in our occasional surveys
• otherwise dealing with any of the ShopSe affiliates / entities / subsidiaries / associates.

Purpose and use of information

• We understand the importance of your Information and ensure that it is used for the intended purpose.
• By accepting the terms of use you agree that we may use and store your Information, in accordance with the applicable law, as long as you subscribe to or use our Services subject to the limitations set out in this Privacy Policy.
• We require the profiling information which includes details such as identity details, contact details, usernames and passwords in order to manage our relationship with you, creation of your account and verification of your identity and access privileges and provide Services offered by us or services offered by merchants, third party service providers, our business partners or our subsidiaries, affiliates, associates.
• To conduct the KYC compliance process as a mandatory prerequisite as per the requirements of various regulatory bodies, including UIDAI under the Aadhaar Act and its Regulations; to validate, process and/or share your KYC information with other intermediaries, Regulated Entities (REs) or financial institutions or with any other service providers as may be required; to process payments on your behalf and on your instructions; communicate with you for your queries, transactions, and/or any other regulatory requirement, etc.; to authenticate any transaction processed through the Site.
• To carry credit checks, screenings or due diligence checks as lawfully required by us for providing the Services or processing the loan/credit lines/EMI transactions; detect and protect us against error, fraud, money laundering and other criminal activity.
• To enforce our terms and conditions; to meet legal obligations.
• To resolve disputes; troubleshoot problems; technical support and fixing bugs; help promote a safe service; to identify security breaches and attacks; investigating, preventing, and taking action on illegal or suspected fraud or money laundering activities and conducting forensic audits as part of internal or external audit or investigation by ShopSe or government agencies located within India or outside the Indian jurisdiction.
• To improve our Services, we need to constantly update and alter our business and marketing strategies for which we require the navigational and log information to determine and analyse the merchants, markets, technology, operating systems, browsers, devices, locations from which our Services are used most or used least. For example, such information and its analysis will help us focus more on your needs by providing you a wider range of Services, or developing updates for particular operating systems and mobile application versions, etc. Further, the information collected helps us offer you other products, programs, or services that we believe may be of interest to you. In addition, such information collected will help us alert you in case of software compatibility issues.
• We want to serve you better and therefore we require your correspondence information in order to enable us to learn about the information and content of communications by you such that we can deduce your feedback from such communications, analyse, endeavour to improve, ask you for further feedback, reply.
• The data collected by cookies helps us track, analyse and understand User trends so as to enable us to understand lacunas (such as slow response time on our website page) and improve your interactive experience of using our Services, our web design, features and functionalities.
• We will use your Information for marketing purposes. To inform you about online and offline offers, products, services, and updates; customizing and improving your experience by marketing, presenting advertising, and offering tailored products and offers.
• We access data or information stored by third parties in case required for providing you uninterrupted and satisfactory Services or in case consented by you.
• For enabling you to make quicker transactions and relieving you from the hassle of copying/ keying in the 6 digit OTP, we have developed advanced technologies which would automatically retrieve the OTP and the mention the same in the relevant column of the transaction page.
• Combinations of the information collected as mentioned in this Privacy Policy such as physical address, device information, email address when coupled with information which is not Personal Information such as speed of typing, the maximum screen area usage, other patterns and data help us detect and protect Users and ourselves against errors, fraud, or other criminal activity.
• Further, we may use the data and Information collected/ stored as mentioned above for improving our services, improving user experience, risk checks, strengthening our security checks, for analysis, for offering you new features in the existing services you are availing or offering altogether new product/ service which may be relevant for you and such other purposes. We collect and use some of your Information in an aggregated form to compile statistical and demographical profiles for our business and marketing activities and to customise our Services to you. It is clarified that the consolidated Information of all Users which has been collected by us or provided to us, is the property of ShopSe and we may use it, in whole or in part, at our sole discretion and without any compensation to you, for any legitimate purpose and you hereby confirm that you have no objection to the aforesaid use of your Information.
• While we may also process your Personal Information for other legitimate business cases, we ensure to take appropriate steps to minimize the processing to the extent possible, making it less intrusive to your privacy.
• Consent for Marketing and Analytics: By using our services, you consent to the collection and use of your personal data for marketing purposes, including receiving promotional communications and offers tailored to your preferences. You also consent to the use of your data for analytics purposes, helping us improve and personalize our services. Transparency and Data Use: We are committed to being transparent about how your data is used. Below is a list of the tools and services we utilize:
  1. Communication
     • Webengage
     • Infobip
     • Whatsapp / Facebook
     • Sendgrid
     • Kapture CRM
     • Ozonetel
  2. Hosting
     • AWS
  3. Analytics
     • Google Analytics
  4. Payment partners / Banks / NBFCs
     • Easebuzz
     • Cashfree
     • Lyra payment network
     • NTT Data Payments system
     • Lenders
     • HDFC
     • Kotak
     • ICICI
     • IDFC
     • DMI
     • Moneyview
     • Karza technologies

Cookies or Similar Technologies:

We use data collection devices such as "cookies” or similar technologies on certain pages of the Sites to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. "Cookies" are small files placed on your device hard-drive/storage that assist us in providing our services. Cookies do not contain any of your Personal Information. We offer certain features that are only available through the use of a "cookie" or similar technologies. If your web browser settings permit, cookies can be sent to your web browser for recording information about your online preferences and allowing us to cater to your interests in a better manner. You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. If you do accept a cookie, you thereby agree to our use of information collected by us using that cookie. We also use cookies to allow you to enter your password less frequently during a session. Most cookies are "session cookies," meaning that they are automatically deleted from your device hard- drive/storage at the end of a session. You are always free to decline/delete our cookies or similar technologies if your browser/device permits, although in that case you may not be able to use certain features on the Sites and you may be required to re-enter your password more frequently during a session. Additionally, you may encounter "cookies" or other similar technologies on certain pages of the Sites that are placed by third parties. We do not control the use of cookies by third parties.

Sharing or Disclosure of Information​

• Your Personal Information is shared as allowed under applicable laws, after following due diligence and in line with the purposes set out in this Policy.
• We may share your Personal Information in the course of your transaction with different categories of recipients such as business partners, service providers, merchants, affiliates, associates, subsidiaries, legally recognized authorities, regulatory bodies, governmental authorities, financial institutions, internal teams such as marketing, security, investigation team, etc.
• We do not disclose or share your Information with any third party until essential for providing you Services; or for the below purposes in accordance with this Privacy Policy Information security is critical to us and we will not share your Information with any other third parties except, and only to the extent necessary.
• Personal Information will be shared, as applicable, on need-to-know basis, for the following purposes:
• for facilitating the services between you and the service provider, as requested
• for the Aadhaar authentication process by submitting Aadhaar information to Central Identities Data Repository (CIDR) and National Securities Depository Limited (NSDL)
• for complying with applicable laws as well as meeting the Know Your Customer (KYC) requirements as mandated by various regulatory bodies, whose regulated service/product you opt through our Services/Sites
• for completing a payment transaction initiated by you on a merchant site, where based on your instructions, the merchant requests to fetch your Personal Information from us
• for the purpose of processing your financial product/service requests placed with us and ensuring that these requests reach the relevant financial institution whose service/product you have opted for
• if it is required by financial institutions to verify, mitigate, or prevent fraud or to manage risk or recover funds in accordance with applicable laws/regulations
• enforce our Terms 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
• for grievance redressal and resolution of disputes
• with the internal investigation department within ShopSe or agencies appointed by ShopSe for investigation purposes located within or outside the Indian jurisdiction
• You acknowledge and agree that in the interests of improving personalisation, for analysis, for offering new features in the existing services you are availing, offering new products/ services which may be relevant for you and Service efficiency, we may, under controlled and secure circumstances, share your Information with our subsidiaries, affiliates or associates. We do not share, disclose or distribute any of your Information to any third party unless required under an arrangement between ShopSe and the third party for product enhancement, analysis, risk and security purposes, communication purpose, etc. For example, ShopSe may, itself or through third parties, send you e-mails, SMS, such other means to communicate, send reminders for payment, advertise its services, promote new products and activities or for your invaluable feedback.
• If, by usage of some functionalities of our Service, you receive Information about other User(s), you agree to keep the same confidential and only use it in connection with the Services, without disclosing the same to another user or third party.
• In order to ensure that all our Users comply with the user rules, we may monitor your Information to the extent that this may be required to determine compliance and/or to identify instances of non-compliance.
• We may disclose the Information pursuant to applicable laws, a directive or order of a government entity or statutory authority or any judicial or regulatory authority or to law enforcement agencies in any official investigation including but not limited to cyber incidents, prosecution and punishment of offences. You agree that ShopSe has the right to monitor and to disclose Information as may be necessary to satisfy any law, regulation or other governmental request. We may transfer Your Information or other information collected, stored, processed by ShopSe to any other entity or organization located in India or outside India only in case it is necessary for providing Services to You in connection with Application. We will cooperate with the appropriate law enforcement authorities in investigating claims of illegal activity.
• We will only disclose your Information in accordance with this Privacy Policy. If we want to use it for any other purpose, we will obtain your consent.
• If you decline to submit Information to us, then we will unfortunately not be in a position to provide the Services to you.
• If all or some of the business, stock or assets of ShopSe are acquired or merged with another business entity or there is any amalgamation, demerger, reorganization, or corporate restricting in any form, we will share all or some of your information with this entity to continue to provide the Service to you.
• ShopSe does not control the acts of its Users. All Users should be aware that, when they disclose Information such as their name, e-mail address, etc. to third parties, the Information may be collected and used by others to send unsolicited e-mail from other parties, who may or may not be Users. In the event that you encounter any person improperly collecting or using information about Users, please contact us by emailing at care@getshopse.com.
• While the information is shared with third parties as per purposes set out in this Policy, processing of your Personal Information is governed by their policies. ShopSe ensures stricter or no less stringent privacy protection obligations are cast on these third-parties, wherever applicable and to the extent possible. However, ShopSe may share Personal Information with third-parties such as legally recognized authorities, regulatory bodies, governmental authorities, and financial institutions as per purposes set out in this Policy or as per applicable laws. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.

Storage and Retention

• To the extent applicable, we store Personal Information within India and retain it in accordance with applicable laws and for a period no longer than it is required for the purpose for which it was collected.
• However, we may retain Personal Information related to you if we believe it may be necessary to prevent fraud or future abuse or if required by law such as in the event of the pendency of any legal/regulatory proceeding or receipt of any legal and/or regulatory direction to that effect or for other legitimate purposes. We collect, store or retain the Personal Information in compliance with the applicable laws and regulations. Some Personal Information (for e.g., Aadhar XML file) may be collected and stored only for a short duration and some Personal Information(for e.g., Credit or debit card numbers) may not be stored at our end, but directly transferred to third parties who are required and authorised to use, store or transfer the Information. Once the Personal Information has reached its retention period, it shall be deleted in compliance with applicable laws.
• We collect, store or retain the Personal Information in compliance with the applicable laws and regulations. Some Personal Information (for e.g., Aadhar XML file) may be collected and stored only for a short duration and some Personal Information(for e.g., Credit or debit card numbers) may not be stored at our end, but directly transferred to third parties who are required and authorised to use, store or transfer the Information.
• Once the Personal Information has reached its retention period, it shall be deleted in compliance with applicable laws.
• The specific retention periods for different categories of data are as follows: Personal Identifiable Information (PII), Bank account details, Employment Details: Retained for 10 years to facilitate transactions, customer support, and marketing communications. After the applicable retention period has expired, PII will be securely deleted or anonymized according to our data destruction protocols.

Data Destruction Protocol

• This policy outlines the principles and procedures for the retention and secure disposal of data in compliance with applicable laws. ShopSe is committed to safeguarding sensitive information and ensuring the secure destruction of data when it is no longer required.
• a) No storage of sensitive authentication data i.e. CVV, CID, CAV2, CVV2, CVC2, PIN, PIN block and Track data to be retained locally post authorization and under any circumstances except for issuing services with documented business justification.
• b) All transaction data will be stored for 8 years as prescribed by RBI and this will subject to change depending on regulatory changes, legal and business compliance from time to time.
• c) Data is disposed as soon as the specified retention period completes it retention period.
• d) If sensitive authentication data (CVV, PIN, magnetic stripe data, track data etc.) is being received, then the data is not stored and is deleted in a secure manner which makes the data unrecoverable.
• e) The ShopSe Team is responsible for the retention and secure disposal of storage media. A log is maintained showing what media were disposed of, and when. As required, the asset inventory is adjusted once the asset has been disposed of.

Incident Management Policy

• ShopSe will prioritize complying with all relevant legal and regulatory requirements for incident notification. In case of a major security breach, the specific authorities, partner banks will be notified within 6 hours following the confirmation of the incident. The nature of the incident will also be considered. For example, data breaches involving personal information might require notification to Legal and Regulatory authorities.

Security of Information

• ShopSe is an ISO 27001 and PCI DSS certified entity. We work to protect the security of your information during transmission by using appropriate software, which encrypts information you input. This encrypted information is stored on secure systems/computers. Further, the database is stored on servers secured behind a firewall and we ensure that the number of employees involved in the management of the data centre who have physical access to these computers is limited. Also, we use advanced security technology to prevent our computers from being accessed by unauthorized persons.
• We have also implemented information security practices and standards and have in place information security programmes and policies containing managerial, technical, operational and physical security measures that are in compliance with the Indian laws including Aadhar Regulations, so as to protect the Information provided to us from unauthorized access, use, modification, damage, disclosure or impairment.
• No data transmission over the internet is fully secure, so we cannot ensure or warrant the security of any information you submit to us. Further, we do not guarantee in any way, the security of any Information that you transmit or share on the Site; and you do so at your own risk.
• If any security breach comes to our knowledge, then we may take all steps required to protect misuse of such Information and may attempt to notify you electronically so that you can take appropriate protective steps.
• Any of your information which you provide when you use our Services to an open, public environment or forum including (without limitation) any blog, chat room, community, classifieds or discussion board, (a) will not be considered confidential, (b) will not be considered as Information, and (c) is not subject to protection under this Privacy Policy. Since such public environments are accessible by third parties, it is possible that third parties may collect or use such information for their own purposes. You should accordingly be careful when deciding to share any of your Information in such public environments. Please note that we are not liable to you or any third party for any damages that you or any third party may suffer on account of your disclosure of Information in any public environment.
• Further, you are responsible for maintaining the confidentiality and security of your login id and password. Please do not share your login, password, and OTP details with anybody. It shall be your responsibility to intimate us in case of any actual or suspected compromise to your Personal Information.

Third-Party Products, Services, or Websites

• When you are availing products and services of service providers on the Site, Personal Information may be collected by respective service providers and such Personal Information shall be governed by their privacy policy. You may refer to their privacy policy and terms of service to understand how your Personal Information will be handled by such service providers.
• Our services may include links to other websites or applications when you visit our Site. Such websites or applications are governed by their respective privacy policies, which are beyond our control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser or on the m-site you are redirected to), use of any Personal Information that you provide on these websites or applications is governed by the privacy policy of the operator of the application/website, you are visiting. That policy may differ from ours and you are requested to review those policies or seek access to the policies from the domain owner before proceeding to use those applications or websites. We do not accept any responsibility or liability for usage of your Personal Information by these third parties or their policies.

Your Consent

We process your Personal Information with consent. By using the ShopSe Site or services and/or by providing your Personal Information, you consent to the processing of your Personal Information by ShopSe in accordance with this Privacy Policy. If you disclose to us any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

Changes to the information

If you are a User and would like to view the information we have collected from you or you want to correct your information or details, please send us your request by email on the care@getshopse.com

Choice/Opt Out

• The User can at any time while availing the services or otherwise, withdraw his/her consent given previously to ShopSe for collecting, receiving, possessing, storing, dealing or handling Information of the User or ask for deletion of Personal Information or User account, by sending us your request by email on care@getshopse.com. In such case, ShopSe will unfortunately not be in a position to provide the Services to you. However, ShopSe will be able to retain such Information for the time period in accordance with the applicable laws.
• We provide all users with the opportunity to opt-out of receiving non-essential (promotional, marketing-related) communications from us, after setting up an account. If you want to remove your contact information from all our lists and newsletters, please click on the unsubscribe button on the emailers or write to us at care@getshopse.com. For the above requests, ShopSe may need to request specific information from you to confirm your identity and ensure authentication. This is a security measure to ensure that Personal Information is not disclosed to any person who does not have a right to receive it or is not incorrectly modified or deleted.
• In cases where you need any further information specific to the product/ services that you are availing, we request you to read through the Terms and Conditions specific to the product/service which is easily accessible through the Sites. For seeking any further information on the same, you can write to us at the details mentioned in the ‘Contacting ShopSe’ section of this Policy.

Children Information

• We do not knowingly solicit or collect Personal Information from children under the age of 18 and use of our Sites is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are under the age of 18 years then you must use the Sites or services under the supervision of your parent, legal guardian, or any responsible adult.

Changes to the Privacy Policy

• ShopSe reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, ShopSe shall update the same on the website. Users should periodically review this page for the latest information on our privacy practices. Once posted, those changes are effective immediately, unless stated otherwise. Continued access or use of the Services constitutes your acceptance of the changes and the amended Privacy Policy. However, if you do not agree with the changes, please do not continue to use the Services, or submit Information to us.

Contacting ShopSe

If you have any questions, queries, concerns or feedbacks about this privacy policy, the processing of your Personal Information or our privacy related practices, please feel free to email us at care@getshopse.com. We are committed to resolve your queries within the reasonable time limit. Any delay in the resolution time shall be proactively communicated to you. Details of our Grievance/Nodal Officer is included in our Grievance Policy available on the Site.