PRIVACY POLICY

Vert One Private Limited (“Company”) values the users of our application named [insert name of the application] (“Platform”). Your privacy and trust are very important to us. We recognize that you may be concerned about our collection, use, and disclosure of the personally identifiable information (“Personal Information”) that we collect when you use the Platform and the services offered on the Platform. This privacy policy (“Privacy Policy”) governs the collection, use, disclosure, transfer or otherwise processing of personal data or sensitive personal data by the Company. By using the Platform you are accepting the practices described in this Privacy Policy and consenting to the use of your Personal Information by the Company in accordance with the terms set out in this Privacy Policy. If you have any questions or comments regarding this Privacy Policy, please contact us at info@vert-one.com. You may mark the mail to the grievance officer at grievances@vert-one.com.

1. TYPES OF INFORMATION THAT THE COMPANY COLLECTS

1.1   Sensitive Personal Data / Information: We collect sensitive personal data / information that you provide to us, such as your name, mailing address, phone number, email address, credit card number, permanent account number, TAN, income tax returns, aadhaar number, bank account number, passport details, driving license details, personal statements, reasons for seeking finance, income sources and financial information, or any other information.

1.2   Non-Personal Information: We also collect non-personal information from you, i.e., information that cannot be easily used to personally identify you, such as your browser type, the URL of the previous website you visited, your internet service provider, operating system, and your internet protocol (IP) address (“Non-Personal Information”).

1.3   Information and Alerts: We do not collect, read or store your personal SMS from your inbox. However, we collect and monitor only those SMS sent by 6-digit alphanumeric senders from your inbox which helps us in identifying the various bank accounts that you may be holding, cash flow patterns, description and amount of the transactions undertaken by you as a user to help us perform our activities and to provide you with our services. This process will also enable you to take financial facilities from the regulated financial entities available on the Platform. This financial SMS data also includes your historical data. While using the Platform, it periodically sends the financial SMS information to our affiliate server and to us. We would also be sending SMS to give alerts about the activities on the Platform or inform users of any promotions or updates on the Platform.

1.4   Device location and information: We collect and monitor the information about the location of your device to provide our services. This also helps us to verify the address.

Information that the Platform collects, and uses, depends on how you manage your privacy controls on your device. When you use the Platform, we store the information we collect with unique identifiers tied to the device you are using. We collect information from the device when you use the Platform and explicitly seek permissions from you to get the required information from the device. The information we collect from your device includes the hardware model, build model, RAM, storage; unique device identifiers like serial number, SIM information that includes network operator, roaming state, codes, WIFI information that includes device address and mobile network information to uniquely identify the devices and ensure that no unauthorized device acts on your behalf to prevent frauds.

We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behavior, thereby allowing us to improve our services and provide an enhanced customized user experience to you.

2. PROCESS OF COLLECTION OF THE INFORMATION

2.1   Providing Information to Us: We collect the sensitive /personal data / information from you when you provide it to us. For example, if you purchase a product or services we may collect your name, mailing address, telephone number, credit card number, permanent account number, aadhaar number, TAN, income tax returns, bank account number, passport details, driving license details, personal statements, income sources and email address. If you sign up to receive a newsletter, we will collect your email address.

2.2   Communications with Us: If you communicate with us regarding the Platform or the services offered by the Company, we will collect any information that you provide to us in any such communication.

2.3   Analytic and Reporting Technologies: Like the operators of most platforms, we use analytic and reporting technologies to record Non-Personal Information such as internet domain and host names, internet protocol (IP) addresses, devicesoftware, operating system types, clickstream patterns, and the dates and times that the Platform and the services offered by the Company are accessed. We are also in contract with several online partners to help manage, monitor and optimize our Platform and the services offered by the Company and to help us measure the effectiveness of our advertising, communications and how visitors use the Platform. To do this, we may use web beacons and cookies.

3. USES OF INFORMATION

3.1   Personal Information: We use Personal Information primarily for our own internal purposes, such as providing, maintaining, evaluating, and improving the Platform, fulfilling requests for information, verifying customer identity, and providing customer support. Your Personal Information shall also be shared with the other members of this Platform. Upon acceptance of these terms and conditions, you hereby grant an unequivocal and absolute consent to share your Personal Information (to the extent necessary in ordinary course of business of the Company) with third parties. The Companyis not required to seek your consent once again in respect of sharing your Personal Information with third parties. We would further share your Personal Information with marketing agencies and other businesses if we, in our sole discretion, understand that your information may be used to market the Platform or a product or service. We may also make public, your personal information in relation to any testimonials and feedback that you may provide us with and you hereby grant us the right to make such testimonials and feedback public on any public platform that we may chose. The term Personal Information shall include your name, address, e-mail id and mobile phone number, your images and photos, if any, but it shall not include any data in relation to your financial status, income statements, earnings, source of earnings, personal identification numbers, passwords, code numbers, bank account numbers, credit card numbers, expiry dates relationship numbers, CVV numbers, encryptions, cookies and other such electronic details.We shall also use the information to obtain credit reports and evaluate the creditworthiness for availing the loan/ facility from partnered non banking financial institutions, to ensure compliance with applicable laws and undertaking services, as required.

3.2   Non-Personal Information:  We use non-Personal Information to track the use of the Platform and the services offered by the Company and for other internal purposes, such as providing, maintaining, evaluating, and improving the services offered by the Company and the Platform.

4. DISCLOSURE OF INFORMATION TO THIRD PARTIES

4.1   Disclosure to Successors: We may disclose your Personal Information to any successor-in-interest of ours, such as a company that acquires us or our affiliates. In the event the Company goes through a business transition, such as a merger or acquisition by or with another company, or sale of all or a portion of our assets, your Personal Information will likely be among the assets transferred. You will be notified via email or by a notice on our Platform of any such change in ownership or control of your Personal Information.

4.2   Disclosure to Unaffiliated Third Parties:  We shall keep your Personal Information and sensitive personal data / information private and confidential. We may disclose your Personal Information and/or sensitive personal data / information to prevent an emergency, to respond to legal requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a summon or court order).

4.3   Disclosure to Third Party Service Providers and Online Partners:  We may contract with various third parties who help us provide, maintain and improve the Platform and the Company’s services. For example, we use a third party to process payments made to us, and may subcontract production, fulfillment, analytics, reporting or other operations. We also contract with several online partners to help manage, monitor and optimize our Platform and the services and to help us measure the effectiveness of our advertising, communications and how visitors use the Platform. We will use commercially reasonable efforts to prevent such third parties from disclosing your Personal Information, except for the purpose of providing services in question. We may also share the data / information with our technology service providers, partnered non banking financial institutions and outsourcing partners to perform credit and know your customer checks to facilitate a loan for the users from partnered non banking financial institutions as per applicable laws. We cannot guarantee that such third parties will not disclose your Personal Information. In no circumstances shall the Company disclose data in relation to your financial status, income statements, earnings, source of earnings, personal identification numbers, passwords, code numbers, bank account numbers, credit card numbers, expiry dates relationship numbers, CVV numbers, encryptions, cookies and other such electronic details.

4.4   Disclosure of Non-Personal Information:  We will disclose Non-Personal Information, in aggregate form, to potential strategic partners, advertisers, investors, customers, and others. You may opt-out of the sharing of this information by mailing the grievance officer. However, it cannot be easily used to identify you personally.

4.5   Internet Advertising:  We may use third party service providers to serve ads on our behalf across the internet and sometimes on the Platform. They may collect anonymous information about your visits to our Platform, and your interaction with our products and services. They may also use information about your visits to this and other platforms to target advertisements for goods and services. This anonymous information is collected through the use of a web beacon, which is industry standard technology used by most major platforms.

5. COOKIES AND WEB BEACONS

5.1   A cookie is a small file placed on the mobile browser of your device. Most platforms use cookies. We use cookies to track your use of the Platform and the Company, provide you with a more personalized user experience, and to allow you to login and begin use of the services offered by the Company automatically when you visit the Platform.

5.2   A web beacon is an often-transparent graphic image, usually no larger than a 1×1 pixel that is placed on a web page or in an e-mail that is used to monitor the behavior of the user visiting the Platform or receiving the e-mail.

5.3   Cooies and web beacons used by the Company and our online partners are not linked to Personal Information. This Privacy Policy covers the use of cookies and web beacons by the Company and does not cover the use of cookies or web beacons by any other third party, or advertiser.

6. PROTECTING PERSONAL INFORMATION

6.1   Personal Information: Whenever we obtain your Personal Information, we use commercially reasonable efforts to protect it from unauthorized access or disclosure. However, we are not insurers of the security of your Personal Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third party access or other acts of third parties, or acts or omissions beyond our reasonable control.

6.2   Application Content: The content that you store, post, or transmit on or through the Platform, such as storefront pages, and images on your products, may be accessed by other users, including people that you do not know. We are not responsible for the actions of others. Therefore, you should use care in communicating with other users and only disclose your Personal Information to other users that you know to be trustworthy. You should not assume that your content will be kept private.

7. REVIEW AND MAKE CHANGES TO PERSONAL INFORMATION

7.1   You can obtain a copy of and request that we correct errors in your Personal Information by emailing us at info@vert-one.com . You may mark the mail to grievance officer at grievances@vert-one.com.

7.2   For your protection, you will be required to provide proof of your identity to obtain a copy of your Personal Information. If your Personal Information changes or if you no longer want to use the services offered by the Company, you may correct, update or deactivate your Personal Information and/or your account through the account management screen. If you would like to deactivate or terminate your account you can also contact us at info@vert-one.com

7.3   Tell-A-Friend If you choose to use our referral service to tell a friend about the Platform or the Company’s services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Platform. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

7.4   SecurityThe security of your Personal Information is important to us. When you enter sensitive information such as a credit card number on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).

7.5   We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

7.6   Internet-based Transfers  Given that the internet is a global environment, using the internet to collect and process Personal Information necessarily involves the transmission of data on an international basis. By providing the Company with your Personal Information you acknowledge and agree that we may store your Personal Information and transfer it to and from our servers. We endeavor to protect all Personal Information collected through the Platform in a safe, confidential and secure manner.

8. THIRD PARTY WEBSITES

You may be able to access third party websites directly from the Platform. This Privacy Policy does not apply when you access third party websites. We cannot control how third parties may use Personal Information you disclose to them, so you should carefully review the privacy policy of any third party website you visit before using it or disclosing your Personal Information to its provider.

9. CHILDREN’S PRIVACY

The services of the Company are intended for users ages 18 and older only. Accordingly, we will not knowingly collect or use any Personal Information from individuals that we know to be under the age of 18. In addition, we will delete any information in our database that we know originates from an individual under the age of 18.

10. SECURITY PRECAUTIONS

10.1   The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.

10.2   The Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use SSL based encryption, for the transmission of the information, which is currently the required level of encryption in India as per applicable law. We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.   

10.3   In addition, the Platform implements ISO 9001 which is the international standard that details requirements for a quality management system (QMS). The Company uses the standard to demonstrate the ability to consistently provide products and services that meet customer and regulatory requirements with the requisite security protections.

10.4   We aim to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:

1. We use encryption to keep your data private while in transit;
2. We offer security feature like an OTP verification to help you protect your account;
3. We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
4. We restrict access to Personal Information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
5. Compliance & cooperation with regulations and applicable laws;
6. We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
7. Data transfers;
8. We ensure that aadhaar number, if collected, is not disclosed in any manner.

10.5   While data protection laws vary among countries, with some providing more protection than others, we or our affiliates maintain your information on servers located in India. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000 and rules and regulations made thereunder.

10.6  In case of formal complaints, we have in place a grievance redressal mechanism, available at grievances@vert-one.com.

11. OPT OUT

11.1   We provide you the opportunity to opt-out of having your Personal Information used for certain purposes. For example, if you purchase a product/service but do not wish to receive any additional marketing material from us, you can indicate your preference on our order form.
If you no longer wish to receive our newsletters and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at info@vert-one.com. We also offer you an opportunity to opt-out of certain communications through the account management screen. If you need assistance you may contact us at info@vert-one.com

11.2  If we choose to disclose your Personal Information to a third party in a manner that is not set forth in this Privacy Policy you will be notified so that you can make an informed choice about sharing your Personal Information with that third party.

11.3   All sensitive Personal Information collected by us will be retained only so long as it is necessary. Completion/ termination of any services of the Platform does not automatically rescind the consents provided to us by the user under this Privacy Policy and/or any other agreements executed between us and the users. 

11.4  We shall store customer information and/or data for such period as may be required by us to (i) enforce our legal rights and obligations; (ii) to ensure compliance with our obligations and responsibilities under applicable laws.

12. RIGHTS OF CUSTOMER

The customer has the following rights under this policy:

   12.1   Right of Access, Modification and Deletion: Customer can request at any time to review any Personal Information supplied. The customer may request for any Personal Information that has been found to be inaccurate during this review to be changed.

   12.2   Security and Confidentiality: reasonable security standards in compliance with applicable laws to protect the confidentiality and security of customer information.

13. CHANGES TO THE PRIVACY POLICY

We may make changes to the Privacy Policy from time to time. We will notify you of any changes as per applicable law by sending you an email, posting a notice on the home page of the Platform, or posting a notice in your account when you first login after we have made changes. We encourage you to periodically review the Platform for the latest information on our privacy practices. If you receive notification or a change in our Privacy Policy, you must review the new privacy policy carefully to make sure you understand our practices and procedures. You may not be able to receive notices from us if your cookies are not set to accept and/or are disabled. Continued access or use of the Platform constitute Your acceptance of the changes and the amended privacy policy.