We value the trust you place in us and recognize the importance of information privacy. The protection and security of the information shared by you is one of our top priorities. This policy (“Privacy Policy”) applies to the use of the Platform (as defined under POP “Terms”). This Privacy Policy articulates how Poptech Growth Private Limited (“POP” or “we” or “our” or “us”) collects, uses, shares or otherwise processes its users’ (“you” or “user”) Personal Information. By using our Services, you agree and acknowledge to be bound by this Privacy Policy and you hereby consent that we will collect, use, process and share your Personal Information in the manner set out herein below. This Privacy Policy extends to you and your customers, where applicable, using our Platform and Services. It is clarified that the Terms that are provided separately, form an integral part of your use of our Platform and should be read in conjunction with this Privacy Policy. All capitalized terms not defined in this document shall have the meanings ascribed to them in the Terms. Collection of Information “Personal Information” for the purposes of this Privacy Policy means any information that you provide to us which personally identifies you to be contacted or identified, including but not limited to your name, phone number, email address, address. In accordance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, we hereby disclose the SPDI we collect: Virtual Payment Address (VPA) / UPI ID – collected solely to enable secure UPI transactions.This information is stored in encrypted format and is never shared with third parties, except as required by law or authorized by you. The information that we collect may differ based on the products and services you avail on the Platform. For ease of reference, the types of information collected basis the products or services availed have been set out hereinbelow.
For availing the POP UPI services on the App, we will be collecting the following information from you: Your personal information as may be required for registration and usage of POP UPI; Data that is provided by you during registration on the App including without limitation, name, age, email id, VPA assigned to you etc.; your Short Messaging Service (“SMS”) that are stored on your device for the purposes of, including but not limited to, registering you and your device for payments, OTPs for logins and payments, enhancing your security, and any other legitimate uses with your explicit consent; Device data relating to devices used to access the App and Platform, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers etc.; Transaction data collected while using POP UPI which includes date and time of transaction, amount transacted, type of transaction, your VPA, status of your transaction. We do not collect or retain bank account details linked to your VPA; Loyalty and rewards transaction data; Any other information that is provided by you to us on the Platform.
We further track your use of the Platform through our own proprietary tools or the use of third-party technologies. By using the Platform, you consent to us using such technology to track your usage of the services made available on the Platform. The tools used for tracking does not collect any Personal Information and are used to track your activities during use of the Platform and during promotional activities to better tailor your experience on the Platform for your needs. We ensure that the collection of your information, such as order details and transaction details, including Personal Information is limited to fulfilling the purposes identified below. If we intend to use your information for any other purpose, we will seek your consent prior to such use. We maintain reasonable physical, electronic and procedural safeguards to protect your information. Once your information is in our possession, we adhere to our security guidelines to protect it against unauthorised access. Your personal information will be stored and processed in India.
For providing certain services, we may require supplementary information, including but not limited to your credit/debit card details, financial information and details of financial transactions. Where you opt to provide any device permissions such as contacts, photos, camera, location, microphone, messages, storage, phone calls etc., we may retrieve, retain and use the data sourced through such device permissions and use the same as per this Privacy Policy. You can revoke the aforementioned access by amending access permissions within the device's settings. This information may be utilized towards credit evaluation, obtaining bank accounts details, bill identification details, payment details and other uses and services permitted under applicable laws.
A. E-Commerce
B. UPI
C. General
We may use trusted third-party service providers to perform certain services on our behalf, including for the purposes of data storage, data management, web hosting, web analytics, marketing and mailing. These service providers only receive Personal Information if such information is required to perform their function(s), and they are not authorized to use any Personal Information for any other purpose(s) other than the purpose(s) set forth by us. We may disclose your Personal Information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Terms and this Privacy Policy; (c) comply with legal obligation or process, such as a search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, or that of our Partners and Customers or (e) protect ourselves against a legal liability. Please note that we are not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive. In addition to the above, in case of POP UPI services availed by you, we may utilize your personal information for the following purposes: analyzing transaction behavior. Validating and authenticating the official verification documents provided by you. Validating your preferred bank account. Analyzing customer behaviour, conducting research into customer behaviour and contacting the customers for the said purpose, and to automate our marketing and outreach efforts. Detection and flagging of fraud. We may also be required to share your information with any governmental authority or with law enforcement officers on request or require any information from you where we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process
If we are involved in a merger, acquisition or asset sale, the information shared with us may be transferred. POP will provide notice before any such information is transferred and becomes subject to a different Privacy Policy.
In the event you do not wish that we retain your Personal Information, you are requested to inform us regarding the same. You have an option to withdraw your consent that you have already provided by writing to us at the contact information provided below. If you opt for the said option of withdrawal, you may lose access to certain services or functionalities on the Platform. We take every reasonable step to ensure that your personal information that we process is accurate and, where necessary, kept up to date. If you believe that any information belonging to you that is in our possession is inaccurate (having regard to the purposes for which they are processed) you may write to us to get it modified. You shall have the option of reviewing the information provided by you.
We shall retain the information shared with us in accordance with appliable laws, for a period no longer than is required for the purpose for which it was collected or as required under any applicable law. However, we may retain data related to you if we believe it may be necessary to prevent fraud or to enable us to exercise our legal rights and/or defend against legal claims or if required by law for other legitimate purposes. We may continue to retain your data in anonymised form for analytical and research purposes.
The Platform may contain links to other sites. The linked sites are not necessarily under our control. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to read the privacy policies of each and every website that collects personally identifiable information. If you decide to access any of the third-party sites linked to the Platform, you do this entirely at your own risk. Any links to any of our partners should be the responsibility of the linking party, and we will not be responsible for notification of any change in name or location of any information on the Platform.
We may use data collection devices such as “cookies” on certain pages of the Application to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. Cookies are small pieces of information saved by your browser onto your computer. Cookies are used to record various aspects of your visit and assist us to provide you with uninterrupted service. POP does not use cookies to save personal information.
We extend an option to all our Users to petition for the deletion of their account via the support section of the POP application. Upon receiving such a request, all information corresponding to the specific account, including but not limited to profile details, order specifics, and UPI will de-linked. There might be scenarios where we may not be able to execute account deletion, such as if there exists an outstanding dispute, transactions suspected to be fraudulent, unresolved claims attached to your account. Notwithstanding, upon resolution of the obstruction preventing deletion, the relevant information is promptly deleted and cannot be retrieved thereafter. We may continue to retain certain information if deemed necessary for regulatory compliance, legitimate business interests like fraud prevention, enhancing user safety and security, or to fulfill our legal and contractual obligations. In addition to this, you have the opportunity to request an account deactivation/archival. This will provisionally inhibit your access to POP application until you forward a re-activation request to support@popclub.co and successfully reactivate your account.
POP maintains reasonable physical, electronic and procedural safeguards to protect information shared with us. Whenever you access your account information, we offer the use of a secure server. Once your information is in our possession, we adhere to our security guidelines to protect it against unauthorized access. We understand that as effective as our security measures are, no security system is impenetrable. Hence, as part of our reasonable security practices, we undergo strict internal and external reviews to ensure appropriate information security encryption or controls are placed for both data in motion and data at rest within our network and servers respectively. The database is stored on servers secured behind a firewall; access to the servers is password-protected and is strictly limited. Further, when you log out of the App or use a separate device for utilizing the POP UPI, you will be required to authenticate the new device utilizing an OTP shared with you. Further to ensure that your information is safe and secure, we urge you to protect all your passwords, PINs and other log-in details and to not share the same with any other person.
The use of our Services is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. We do not knowingly solicit or collect personal information of children under the age of 18 years. If you have shared any personal information of children under the age of 18 years, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.
Our Privacy Policy is subject to change at any time without notice. To make sure you are aware of any changes, please review this Privacy Policy periodically. These changes will be effective immediately on the users of our Services. Please note that at all times you are responsible for updating your Personal Information, including to provide us with your most current e-mail address.
In accordance with the Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:
Name: Mr. Kishor P Kshirasagar
Designation: Customer Support Head
E-Mail Address: kishorp@popclub.co
Your use of our Services will be governed by and construed in accordance with the laws of India. You agree that any legal action or proceedings arising out of your use may be brought exclusively in the competent courts/ tribunals having jurisdiction in Mumbai, Maharashtra in India and you irrevocably submit yourself to the jurisdiction of such courts/ tribunals.
We shall always cooperate with regulatory authorities and investigating agencies in the matter of treatment of your Personal Information.