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 domestic help with a safe, efficient, and customized experience while using our Website and/or Gift-a-Pension WhatsApp Business Channel, to verify your or your domestic help’s identity and other information that you provide in order to enable you to complete the application formalities for financial instruments that your domestic help 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 domestic help 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 domestic help’s Personal Information. Before permitting you and your domestic help to use the Services, we may require you to provide additional information, including but not limited to your domestic help’s date of birth, PAN, mobile number or other personal information. We may use this information to verify your domestic help’s identity or other information you provide.
1.4 By providing your domestic help’s and your email ID and/or phone number to us, your domestic help and you are authorizing us, our representatives and our partners to communicate with you and your domestic help 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 domestic help have registered yourself under Do Not Disturb (“DND”) or Do Not Call (“DNC”) service, your domestic help 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 domestic help or you wish to opt-out of receiving such communication from us, you can do so by sending us an e-mail at firstname.lastname@example.org or calling our helpline at 080 2300 2000.
1.5 If your domestic help 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 domestic help 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 domestic help 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 email@example.com or call our helpline at 080 2300 2000.
2. Sharing of Personal Information
2.2 Disclosure of Information. Under no circumstance will we sell or rent your Personal Information or that of your domestic help 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 domestic help, our customer, for any unauthorized disclosure of sensitive personal information.
2.3 We may share your and your domestic help’s Personal Information:
- to transfer data, personal information etc. with any banking or financial entity or third-party service provider firm;
- to analyze 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 domestic help and you to apply for your chosen financial solutions;
- in relation to research, to effectively control against error, fraud or other criminal activity;
- to any person who has told us and who we reasonably believe to be your domestic help’s parent, carer or helper where your domestic help 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 domestic help or you. If the merger, transfer or sale consummates, the transferee or purchaser may use your or your domestic help’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 domestic help’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 domestic help 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 domestic help, 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 domestic help’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 firstname.lastname@example.org 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 domestic help about our solutions and services by telephone, post, email and SMS (or other reasonable method). If your domestic help or you ticked “yes” but no longer wish to receive such communications, please contact us on email@example.com or call our helpline at 080 2300 2000.
4.3 Your domestic 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 firstname.lastname@example.org 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 domestic help and you.
5. Grievance Officer
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 domestic help or you as applicable. Complaints received by us and not resolved within a specified timeframe are automatically escalated by us. If however your domestic help or you do not hear back from us within 7 days, please do write to us at email@example.com or call our helpline at 080 2300 2000 to escalate your specific complaint to the relevant grievance redressal officer.
6. Our Legal Obligations
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 domestic help’s and your Personal Information. Should there be any accidental disclosure of your domestic help’s or your Personal Information, your domestic help 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 domestic help or you would like a copy, do get in touch with us at firstname.lastname@example.org or call our helpline at 080 2300 2000.