Privacy Policy

This Gift-a-Pension Privacy Policy ("Privacy Policy") describes the way pinBox Inclusion Private Limited or its affiliates or product partners ("We", "Us", "Our") collect, store, process, transfer, use and deal with your ("you", "your", "client", “applicant”, “giftee”) Personal Information. You expressly accept this Privacy Policy by visiting and using our website or our Gift-a-Pension WhatsApp Business Channel and/or availing any of our Services.

For the purposes of this Privacy Policy, “Personal Information” shall mean any information that identifies or can be used to identify, contact or locate the person, to whom such information pertains, including, but not limited to, name, address, date of birth, mobile number, email address, PAN number, Aadhaar card image, Aadhaar number, driving license/ passport/ voter ID card/ government issued ID card image or number, financial profiles like monthly or annual income, net worth, copies of identification documents, e-KYC, demographic information, photographs, biometric information, photo of signature, photo of cancelled cheque or bank passbook, digital signature keys, bank account number, bank IFSC code, UPI ID, nominee details, occupation and other personal information.

You have full rights to not provide your Personal Information or the Personal Information of your giftee on our website or our Gift-a-Pension WhatsApp Business Channel. However, we will be able to provide you and your giftee the Services only when you disclose Personal Information required to activate or operate an account with the Gift-a-Pension financial product partners. If you voluntarily choose to use our Services, and our website and/or Gift-a-Pension WhatsApp Business Channel, you must do so solely at your own discretion and volition and after fully reading and confirming your consent to this Privacy Policy and its specific terms and conditions.

We are committed to keeping your Personal Information and the Personal Information of your giftee confidential and will only give it to others for the purposes set out in this Privacy Policy. Our Privacy Policy is regularly reviewed to make sure that we continue to serve your privacy interests. We reserve the right to update this Privacy Policy and these changes will be posted on our website. We will notify you of any changes to this Privacy Policy. The date of last revision appears at the top of this Privacy Policy document and all changes take effect immediately upon posting.

1. Collection and Use of Personal Information

1.1 When you use our Gift-a-Pension WhatsApp Business channel or Website, we collect and store the Personal Information provided by you from time to time, in compliance with applicable laws. The primary aim in doing so is to provide you and your giftee with a safe, efficient, and customized experience while using our Website and/or Gift-a-Pension WhatsApp Business Channel, to verify your or your giftee’s identity and other information that you provide in order to enable you to complete the application formalities for financial instruments that your giftee voluntarily chooses to buy using our Website or Gift-a-Pension WhatsApp Business Channel, to enable us to maintain a record of your transactions, and to generate and send reminders, alerts and notifications to you and your giftee for transactions, upcoming contributions, etc.

1.2 If you opt to open an account on our website or our Gift-a-Pension WhatsApp Business Channel and use our Services, you will be required to supply your giftee’s Personal Information. Before permitting you and your giftee to use the Services, we may require you to provide additional information, including but not limited to your giftee’s date of birth, PAN, mobile number or other personal information. We may use this information to verify your giftee’s identity or other information you provide.

1.3 We also collect information about your giftee from third parties such as UIDAI and KYC registration and/or verification service providers. This information we collect from such third-party sources is governed by your giftee’s privacy policies agreed with those sources and with your giftee’s consent. By providing such third-party information by way of authorizing us to access such information, your giftee and you agree that we may collect, store, process and share such information in accordance with this Privacy Policy.

1.4 By providing your giftee’s and your email IDs and/or phone numbers to us, your giftee and you are authorizing us, our representatives and our partners to communicate with you and your giftee through various modes like call or email to offer our Services or the Solution opted by you, and information about new solutions and services offered by our partners. Irrespective of the fact that you or your giftee have registered yourself under Do Not Disturb (“DND”) or Do Not Call (“DNC”) service, your giftee and you are still authorizing us, our representatives and our partners to communicate with you for the abovementioned purposes. There is no DNC check required for a number you leave on our website or Gift-a-Pension WhatsApp Business Channel or with our agents. If your giftee or you wish to opt-out of receiving such communication from us, you can do so by sending us an e-mail at helpdesk@giftapension.com or calling our helpline at 080 2300 2000.

1.5 If your giftee or you send us personal correspondences such as emails or letters or if other users or third parties send us correspondence about your activities or postings on the Website, we may collect such information into a file specific to you.

1.6 If your giftee or you telephone us, we may also record and/or monitor calls for quality checks and staff training. Such recordings may also be used to help us combat fraud.

1.7 In the event that your giftee or you want to review and/or update your information as provided to us, or obtain a copy of the same, please write to us at helpdesk@giftapension.com or call our helpline at 080 2300 2000.

2. Sharing of Personal Information

2.1 We will keep your Personal Information and that of your giftee confidential and only share it with others for the purposes explained in this Privacy Policy. We have trusted relationships with carefully selected banking and financial entities (to whom we provide services) or other third parties (who perform services on our behalf). Examples of service providers we use are payment processors, email service providers, WhatsApp Business, SMS gateways, providers of hosting services and providers of call-center and helpline services. Examples of regulated entities to whom we provide services include pension fund managers, mutual funds and insurers whose products and services your giftee or you opt to use and their regulated, authorized partners like the central record-keeping agency (CRA) and Points of Presence (POPs) for National Pension System and the registrar and transfer agent (R&T) for mutual funds. All service providers and product partners are required to maintain the security of your Personal Information and to use it only as permitted by you and us and they must comply with the security practices and procedures as laid out under applicable laws and regulations and as maintained by us as set out in this Privacy Policy.

2.2 Disclosure of Information. Under no circumstance will we sell or rent your Personal Information or that of your giftee to anyone, for any reason, at any time. Just like any other financial services company, we use authorized third-party service providers who are bound by the same standards of data security practices and procedures as we are under law and contract. They are subject to the same penalties as we are for the unauthorized disclosure of your personal information. However, under Indian law, pinBox Inclusion remains liable to you and your giftee, our customer, for any unauthorized disclosure of sensitive personal information.

2.3We may share your and your giftee’s Personal Information:

  • to transfer data, personal information etc. with any banking or financial entity or third-party service provider firm;
  • to analyse usage of our website or Gift-a-Pension WhatsApp Business Channel or to improve the Service as provided by us;
  • to send communications relevant to your use of Service or solutions as offered by us;
  • to enable your giftee and you to apply for your chosen financial solutions;
  • in relation to research, to effectively control against error, fraud or other criminal activity;
  • to enforce our terms of use;
  • to any person who has told us and who we reasonably believe to be your giftee’s parent, carer or helper where your giftee is unable to handle his or her own affairs because of mental incapacity or other similar issues;
  • to any person to whom we sell or transfer (or enter into negotiations to sell or transfer) or with whom we merge our business or any of our rights or obligations under any agreement we may have with your giftee or you. If the merger, transfer or sale consummates, the transferee or purchaser may use your or your giftee’s Personal Information in the same way as us; and
  • to regulators, ombudsmen or other authorities, including tax authorities, where we are requested by them to do so.

2.4 The Personal Information shared by you shall be used to perform background checks on your giftee’s identity to avail the Services offered by us on our Website or Gift-a-Pension WhatsApp Business Channel.

3. Security Precautions

3.1 Security measures (physical, electronic and managerial) are in place to protect your giftee and you against the loss, misuse, and alteration of the Personal Information under our control. We store Personal Information in encrypted form on computers and control access via secure web pages. We employ firewalls and other security technologies to protect our servers from external attack. Access to our Website’s servers is restricted to authorized personnel and shared with employees strictly on a ‘need to know basis’. Our employees are bound by strict confidentiality obligations and subject to stern disciplinary action, including termination, civil liability, and criminal prosecution, if they fail to meet their confidentiality obligations. We shall also promptly notify you if any security breach is made known to us in relation to unauthorized access to your Personal Information.

3.2 Our security systems meet or exceed industry standards and we are constantly monitoring internet developments to ensure our systems evolve as required. However, while we strive to use commercially acceptable means to protect your Personal Information, and that of your giftee, no method of transmission over the Internet, or method of electronic storage, is 100 percent secure. Therefore, by using this Website and/or our Gift-a-Pension WhatsApp Business Channel you agree that we will have no liability for disclosure of your or your giftee’s Personal Information due to errors in transmission, infrastructure failures by us or any intermediary (including telecom and internet service providers), or unauthorized acts of third parties.

4. Opting Out

4.1 We will generally retain your Personal Information for as long as needed to provide you with services and solutions. If you change your mind, and don’t wish to remain on our contact list, just let us know at helpdesk@giftapension.com or call our helpline at 080 2300 2000.

4.2 As part of the digital application process, we ask you whether we may contact you or your giftee about our solutions and services by telephone, post, email and SMS (or other reasonable method). If your giftee or you ticked “yes” but no longer wish to receive such communications, please contact us on helpdesk@giftapension.com or call our helpline at 080 2300 2000.

4.3 Your giftee and you have the right to withdraw consent to our use of your Personal Information at any time where we rely on your consent to use or process that information by sending an email to helpdesk@giftapension.com or calling our helpline at 080 2300 2000. In such case, pinBox Inclusion will unfortunately not be in a position to continue providing the Services to your giftee and you.

5. Grievance

5.1 In accordance with the Information Technology Act, 2000 and the rules made thereunder, in the event your giftee or you have any questions or complaints regarding our Privacy Policy or practices, you may contact us at helpdesk@giftapension.com or 080 2300 2000.

5.2 We are committed to providing a first response within 24 hours of receiving a complaint, and we aim to resolve all complaints within 3 (three) business days. Any delay in the resolution time shall be proactively communicated to your giftee or you as applicable. Complaints received by us and not resolved within a specified timeframe are automatically escalated by us. If, however your giftee or you do not hear back from us within 7 days, please do write to us at helpdesk@giftapension.com or call our helpline at 080 2300 2000 to escalate your specific complaint.

6. Our Legal Obligations

6.1 This Privacy Policy is published on the website in compliance with Regulation 4 of the (Indian) Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011.

6.2 We are bound by the (Indian) Information Technology Act, 2000, and comply with all its provisions available at http://deity.gov.in/content/it-act-2000-dpl-cyber-laws. Under Section 43A of the (Indian) Information Technology Act, 2000, giftapension.com, and all its service providers are obliged to maintain reasonable security procedures to safeguard your giftee’s and your Personal Information. Should there be any accidental disclosure of your giftee’s or your Personal Information, your giftee and you have the right to claim compensation from us.

6.3 Under Regulation 5 of the Information Technology (Reasonable Security and Procedures and Sensitive Personal Data or Information) Rules, 2011, we are obliged to provide every Gift-a-Pension account holder with a readable copy of the Personal Information you have provided us. If your giftee or you would like a copy, do get in touch with us at helpdesk@giftapension.com or call our helpline at 080 2300 2000.

Gift-a-Pension is a national initiative led by pinBox Inclusion - India's only social enterprise committed exclusively to pension and social security Inclusion for informal sector women and youth.

Contact: 080 2300 2000

Email: helpdesk@giftapension.com

© pinBox Inclusion Pvt. Ltd. All rights reserved. Gift-a-Pension is licensed for use in India exclusively to pinBox Inclusion Private Limited.