Privacy Policy

Introduction

Your privacy and keeping your personal information secure are extremely important to us. We are committed to protecting Your privacy and handling Your information in an open and transparent manner.

This Privacy Policy (“Policy”) explains the following things:

1. What we do with your personal information
2. what we do to keep it secure;
3. with whom do we share your information
4. your rights in relation to the personal information we hold about you
5. and whom you can contact for more information.

We will amend or update this Policy regularly to reflect changes in our practices with respect to the processing of personal information, or changes in applicable law. We encourage you to read this Policy carefully and to regularly check this page to review any changes we might make to the terms of this Policy.

Terms & Definitions

To help clarify our meaning, we have used certain capitalized terms in this Policy. These terms and their meaning are:

1. “The Information Technology Act, 2000 (IT Act)” is a law in India that provides a legal framework for electronic governance and electronic commerce. The act provides for the protection of personal data and sensitive personal data of individuals.
2. “Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research, and events. This list is not exhaustive.
3. “Services” means the services provided by the Prabhu Money Transfer that we may introduce from time to time.

We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Data Protection as set out in this Policy.

The personal information we collect and use may include, amongst other things:

• Your name
• Your contact information such as Your email address, postal address, and telephone number
• Your demographic information such as age, education, gender, and Employment
• Your Aadhaar Information (in masking form) and the captured finger data in encrypted form.
• The reason for your transfer request
• Your Beneficiaries information such as Name, Mobile, Address, and Account Details
• Your payment details and other financial data (for example, Your bank or payment method)
• Information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, though, and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

How we collect your personal information

Information You give to us when You use our services. If You use our services You will need to provide certain information including Your name, address, and Aadhaar Number, as well as the name and other details of the recipients of the money transfers that you instruct us to carry out.  This information must be complete and accurate, and if not, we may have to take additional steps to complete the transaction.

Other information You give to us. This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when you communicate with us by phone, e-mail, or otherwise. It includes, for example, information You provide when You register on the website for us to contact You when You inquire about any of our Services when You sign up to receive notifications, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address. We may also record our telephone conversation with you for training and monitoring purposes.

Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn, and Instagram, you might give us permission to access information from those accounts or services.

Other Sources. We may receive information about You from other sources, including publicly available databases, and combine this data with information we already have about You. This helps us to update, expand and analyze our records and provide services that may be of interest to You.

Information we collect about You

Like most websites, we use “cookies” to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They are small text files that websites transfer to Your computer (or phone/tablet). They improve website use and speed – for example by automatically filling in Your name and address in text fields. Please see our Cookies Policy for further information.

Log Files. In addition, with regard to each of Your visits to our site, we will automatically collect certain information (for example, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically- collected log information with other information we collect about You.

How we use your personal information

Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customized experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.

We use Your information for the following specific purposes:

1. to carry out our obligations arising from any contracts entered into between You and us or from applicable law such as anti-money laundering laws, and to provide You with the Services in accordance with our terms and conditions and with this Policy
2. to register You as a customer with us
3. to fulfill Your Transaction Request
4. to send You confirmations or other notifications
5. to notify You about temporary or permanent changes to our services or other service-related messages
6. to prevent fraud, money laundering, and any other illegal activity
7. to ensure that content from our site is presented in the most effective manner for You and for Your computer
8. to promote our business
9. to send You Marketing communications
10. to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes
11. to consider and investigate any concerns or complaints you may have

Whom we might share your personal information with

Your personal information is very important to us. However, there are circumstances where it is necessary for us to share your information for legitimate business, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your personal information to:

• Our affiliates – we share your information with our affiliates, the Bank, and other companies with whom we have been tied up (by doing agreement).
• for our internal business, operational, management, and service needs
• for compliance, regulatory, and audit activity and in connection with legal, regulatory, and tax claims and investigations
• to understand and support our customers and other individuals who use our services, and visit our sites
• to send Marketing communications.

Third-party processors include organizations or individuals with whom we do business or who provide services to us. We may disclose your personal information to respond to legal requirements (for example, as part of our “Know Your Customer” and due diligence obligations), enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, understand the nature of the transaction You have made, provide our services, and protect our rights and property. If we engage a third-party processor to process your information, the Processor will be subject to binding contractual obligations to: only use the personal information in accordance with our prior written instructions; and use measures to protect the confidentiality and security of the personal information, together with any additional requirements.

Protecting your own information (in terms of Agents)

It is important to keep your password secure to prevent fraudulent use of your account. Do not disclose your password to anyone else and especially anyone who requests it from you by telephone or email. Prabhu Money Transfer will never ask you to provide your password or personal information via email. Please be aware of the following:

• Change your password regularly and avoid using the same password on other websites to prevent hackers from access to your account
• Avoid simple passwords that can easily be guessed
• Be aware that public WIFI networks are risky and hackers may capture your online transactions and personal information. Only connect to a network you can trust
• If you use a shared computer, make sure you log out immediately after you have finished using the website
• Beware of ‘phishing’ where criminals may attempt to steal your information by sending you bogus emails.

How long will we keep your personal information for

We take every reasonable step to ensure that your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, we will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date, and still required.

In addition, after you have ceased to be a customer, we may take steps to delete your personal information or hold it in a form that no longer identifies you (for example, we may still use your data in an anonymized format for research and other business purposes).

The period for which we will retain information about You will vary depending on the type of information and the purposes for that we use it. In general, unless applicable law requires a longer retention period, we will keep our records for as long as you are our customer and for 6 years after the end of your relationship with us.

Your Rights

Subject to applicable law, you may have a number of rights regarding our processing of your relevant personal information, including:

1. the right not to provide your personal information to us (however, please note that we may be unable to provide you with the full benefit of our site, our Mobile App, or our services if you do not provide us with your personal information)
2. the right to request access to your personal information, together with information regarding the nature, Processing, and disclosure of that personal information
3. the right to request the correction of any inaccuracies in your personal information
4. the right to request the erasure of your personal information. This is also known as the right to be forgotten. We will keep a note of your name if you ask for your personal information to be erased
5. the right that restricts our use of your personal information
6. the right to object to our use of your personal information. Wherever we use legitimate interest as the ground for processing your personal information you can object to our use of it
7. the right to have certain personal information transferred to another Controller, in a structured, commonly used, and machine-readable format, to the extent applicable
8. where we use your personal information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal basis)
9. the right to lodge complaints with a Data Protection Authority regarding the use of your personal information by us or on our behalf.

We may require proof of your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute; therefore, exemptions or limitations may apply. For example, we can refuse to provide information if fulfilling your request would reveal the personal information about another person, or if you request that we delete information that we are required to retain by law, have compelling legitimate interests to keep, or need access to fulfil our legal obligations.

Identity Verification

We will only process your data subject rights request where we are satisfied that we have successfully verified your identity, and that you are the one asking for your personal data to be processed. We will not process personal data where we are in doubt about the identity of the requestor. You may be asked to prove your identity when making a data subject request.

Requests made by third parties

In line with our privacy practices and to protect your rights and freedoms, we are unable to process a data subject rights request made by a third party (such as Rightly) where; there is doubt that the third party has the appropriate authority to act on your behalf; and where we are not satisfied adequate evidence has been provided in support of identity verification. We would always aim to ensure that a third party has the appropriate consent or authority to act on your behalf, and most significantly that you are fully aware that the third party has made contact specifically with us, regarding exercising your data subject rights.

Before we can process a data subject rights request made by a third party on your behalf, we require as a minimum from the third party:

• a copy of an identity document for you
• evidence of your address
• a physically signed authority by you; or a verbal authority provided directly to us from you and noted on your account; and if provided electronically the authority is to come directly from your email address that matches our records.

We will not access or process your personal data without being confident we are acting on your specific instructions.