PRIVACY POLICY

Last updated on 16 Feb 2024.

Welcome to www.paygro.in

CAPIZAL FINSERV PRIVATE LIMITED (CIN: U65990PN2020PTC196530), a private limited company incorporated under the provisions of Companies Act, 2013 having its registered office address at:Flat No.101,102, Kundan Heritage, Bopodi, Pune – 411003 (“Capizal”) is the sole owner of the domain name paygro.in and its associated website (“www.paygro.in”)and (“PayGro App”).

This Privacy Policy (“Privacy Policy”) for the Website and App belonging to Capizal sets forth Capizal’s policy with respect to personally identifiable data and other information that Capizal collects from you when you visit or use this Website or the App or avail our products and services (“Services”).

For the purpose of this Privacy Policy, wherever the context so mentions, “Users”, “Client”, “You” or “Your”, shall mean any natural or legal person who has visited this Website/ App and/or has accessed or availed the Services provided by Capizal on the Website and/or App (“Platform”).

Please read this Privacy Policy carefully before visiting the Platform or using our Services as this Privacy Policy applies to the processing, transfer, distribution and storage of Personal Data. By visiting the Platform or using the Services, you accept this Privacy Policy and you:

  • affirm that you are of legal age to accept this Privacy Notice; and
  • that you are agreeing either on your own behalf or on behalf of another individual for whom you have actual authority to legally accept this Privacy Policy.
  1. PERSONAL DATA:

      Capizal and/or its affiliates (“We”, “Us”, “Our”) may become privy to some of Your personal information (“Personal Data”), including such information which may or may not be of confidential. Capizal is strongly committed to protecting the privacy of its Users and has taken all necessary and reasonable precautions to protect the confidentiality of any User’s information.
  2. COLLECTION AND USE OF YOUR PERSONAL DATA:

    SMS Log and Image Access Disclosure

    Important Notice: Paygro app requires access to your SMS logs and images to enable certain features. Please read carefully before proceeding.

    What information do we collect?

    1. We may collect certain information from your SMS logs, such as sender/recipient details, message content, and timestamps, depending on the features you use.
    2. Only sms related to any spending or expenses etc is synced to your personal profile to generate expense history for suggesting releavant investment options.
    3. For specific features, we may also request access to your images and collect metadata like file type and creation date.For example for ID verification or KYC verifications.

    Why do we collect this information?

    • Expense Tracking: This feature requires access to SMS logs to generate and categories your spending and present and simple to understand summary of your monthy/weelly spending.Based ipon the info user can decided how which expenses to control or deduct and how much amount to save as per the predediced financial goals.
    • RoundOff Investment: This feature uses SMS log to to send notifiation for saving some amount equivilant of the spending.For example if you spend Rs 1000 on shopping, system will read the sms log from transaction message and create notification within app to suggest the amount for investing in digital gold or mutual funds.
    • Month end investment:- Similar to above point you an view your month spending, category vise and decide to invest somepercentage or fixed amout in one go at month end, to boost up your furture earnings,
    • Document Upload for KYC:- For investing in digital gold or mutual funds above some amount, sometimes PAN card verification or ID verifications are required along with copy of proofs as per the government norms.As a user you can upload them in image format for review and KYC clearance.

     

    We only collect data relevant to the feature and do not share it with third parties without your consent.

    How can you control access?

    You can grant, deny, or revoke access to your SMS logs and images at any time through the app settings. Simply navigate to mobile phone settings , app permissions and disallow any permission as required.

    Your privacy is important to us.

    We take data security seriously and only collect information necessary for specific features. You have complete control over what data is accessed and used.Below are other detail related to your personal data collection in detail.

    By continuing to use this app, you agree to the terms of this disclosure.

    1. Capizal may collect your Personal Data to provide Services on its Platform. While opening an account on the Platform, you may be asked for certain Personal Data of sensitive nature or any other information (as defined under the Information Technology Act, 2000) to complete your KYC (as per the ‘Know Your Client’ requirements set by SEBI) and as per the Prevention of Money Laundering Act, 2002.
    2. Access to your account and the usage of your account is subject to your compliance with all the terms and conditions set forth herein, read along with all documents, including but not limited to; applications, forms and undertakings signed by you during account opening, and any terms/consents/policies included on Capizal’s Platform, i.e., Paygro, including its Terms and Conditions accessible at its Website.
    3. Capizal may or may not, request for sensitive information from you at the time of account opening, which may be (i) setting up your password; (ii) financial information such as bank account or credit card or debit card or other payment instrument details; (iii) information such as name, contact number, gender, date of birth, residence and employment addresses, father’s/mother’s and spouses names, bank account details, scans/copies of document proofs of address & identity such as Photograph, PAN, passport, driver’s license, etc. (iv) uploading signature proof/photo, and (v) device information and location. Such information would be exclusively for the purpose of identity verification and background checks for opening of account as per KYC & anti-money laundering mandates, personalization of Services offered, keeping updating of information pertaining to our Services you’ve subscribed for, and for any legal and regulatory or audit purposes by implementation of legally approved methods and procedures.
    4. We collect Personal Data from you only when you voluntarily use the Services provided on the Platform, and/or enquire to begin an association with Capizal through the Platform and/or complete the process of opening an account on the Platform.We may collect the following information from your device that you may have disclosed to us by way of using our Platform–device location, communication information using phone number, SIM serial number, contacts/contact list, call logs, device information, media (including images and videos etc).
    5. We access your text messages received in your phone inbox after you provide us specific consent. Paygro may automatically read your SMS Text messages related to your expenses and balance in your account arising out of transactions done using cards, banks, wallets, UPI. We only access transactional messages received from your banking partners (including but not limited to retail outlets, financial institutions and utility companies). Reading these messages allow us to organize your expenses and help you with one view and provide analytics for the same.

      We would like to clarify that No personal SMSs or OTPs are accessed by Paygro.

      At any point in time while associated with Paygro, you could opt out of permissions given by you.

    6. With regard to security, we respect all information provided to us, and take all reasonable steps towards protection of the same. We have implemented technology and policies, with the objective of protecting your privacy from unauthorized access and improper use, and periodically review the same. We maintain procedural safeguards to protect the confidentiality and security of personally identifiable information transmitted to us.
  3. COLLECTING AND USING OF YOUR NON-PERSONAL INFORMATION:

      Capizal follows industry best practices, using open and known principles when transferring and storing your data. Capizal may from time to time collect information, i.e., non-personal information (“Non-personal Information”) which cannot be used to identify you personally, while you are using the Platform. Capizal may from time to time collect information such as Non-personal Information such as IP (internet protocol) addresses, browser types, the name of your ISP (internet service provider), information about a third-party link/URL from where you arrive to our Platform, which pages/URLs do you click on the Platform, and the amount of time spent on each.
  4. LINKS TO OTHER WEBSITES:

      This Privacy Policy applies only to the Services provided by Capizal. They may contain links to other web sites or services not operated or controlled by Capizal (“Third Party Sites”). The Policies and procedures we described here do not apply to the Third-Party Sites. The links from the Service do not imply that Capizal endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.
  5. CHILDREN:

      The Services are not intended for use by people younger than 18 (Eighteen) years of age. We do not knowingly collect Personal Data from children under the age of 18 (Eighteen). If you are under the age of 18 (Eighteen), please do not submit any Personal Data on the Platform. If you have reason to believe that a child under the age of 18 (Eighteen) has provided Personal Data on the Platform, please contact us at query@paygro.in and we will delete that information from our databases.
  6. USAGE OF COOKIES:

      The Platform may from time to time use cookies. Cookies are small data files that a website stores on your computer. Capizal may use persistent cookies which are permanently placed on your computer to store Non-personal (Browser, ISP, OS, Clickstream information etc.) and profiling information (age, gender, income etc.). While cookies have unique identification numbers, Personal Data (name, a/c no, contact number etc.) shall not be stored on the cookies. We will use the information stored in the cookies to improve your browsing experience on our website, by throwing up relevant content where possible. We will also use the cookies to store visitor preferences to ease visitor navigation on the Website.
  7. DISCLOSURE AND TRANSFER OF ALL COLLECTED INFORMATION:

    1. Capizal does not share any of your information with third parties except:
      1. with respect to providing the information or Services that you have requested earlier;
      2. with your express permission for sharing such information, or;
      3. with intermediaries who require such information as per regulatory requirements and procedure laid down by regulatory authorities, or;
      4. to prevent, detect and investigate potentially prohibited or illegal activities including fraud, and enforcing our terms, or;
      5. to confirm your identity if you are to exercise legal rights;
      6. to notify you about changes in this Privacy Policy, or;
      7. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
    2. Under no circumstances will we sell or rent your Personal Data to anyone, for any reason, at any time. Your Personal Data is stored with us in an anonymized form.
    3. Capizal has taken best and reasonable steps to ensure prevention of any unauthorized disclosure of your sensitive Personal Data.
    4. Disclosure for regulatory compliances: Capizal will share your information with judicial, administrative and regulatory entities to comply with any legal and regulatory requirements.
    5. Disclosures with your prior consent: If, at any time, you choose to utilize the integrated services of third-party service partners through us, we will share your information with these third-party service partners with your prior consent.
    6. Disclosure for provision of Services:Capizal will share your information with third party vendors of Capizal as necessary for the provision of Services. Authorized third party vendors are bound by the same standards of data security practices and procedures as we are under law and contract.
    7. All such information disclosures, whether of Personal Data or Non-personal Information is done while adhering to legal norms and regulations.
  8. PRIVACY STATEMENT AS PER APPLICABLE PRIVACY AND/OR DATA PROTECTION LAWS:

    1. Capizal shall only process any Personal Data we collect from you in accordance with the applicable data protection legislations and the provisions of this Policy.
    2. In case you are subjected to any data protection legislations, you would have the below stated rights:
      1. You may request your data be deleted or corrected;
      2. You may request for access of any data that has been stored by Capizal for providing you Services;
      3. You may request storable & readable data to be transferred to another party, this shall be done by Capizal to the maximum extent possible;
      4. As and where any data is requested, it would be taken only post your prior consent.
    3. We are permitted to process your Personal Data in compliance with data protection legislations by relying on one or more of the following lawful grounds:
      1. You have explicitly agreed to us processing such Personal Data for a specific reason;
      2. The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
      3. The processing is necessary for compliance with a legal obligation we have;
      4. The processing is necessary for the purposes of a legitimate interest pursued by us, which might be: to provide services to you; to ensure that your account on the Platform runs smooth and to provide error free provision of Services;
      5. To prevent, detect, investigate and prosecute fraud and alleged fraud, money laundering and other crimes and to verify your identity in order to protect our business and to comply with laws that apply to us and/or where such processing is a contractual requirement of the Services you have requested;
      6. to ensure that complaints are investigated;
      7. to evaluate, develop or improve our Services; or
      8. to keep our customers informed about relevant services, unless you have indicated at any time that you do not wish us to do so.
    4. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Platform.
    5. If under any specific applicable law, you require receipt of the information stored by us, you may write to us at query@paygro.in.
  9. SECURITY:

    1. We have implemented appropriate security controls within the Services to protect personal information from accidental or unlawful destruction or accidental loss, alteration, disclosure, or access.
    2. Information collected via the Services is encrypted before transmission to ensure that it will remain secure and confidential. The Services include various security measures to enhance the security of your profile and to prevent unauthorized access to, or disclosure of, personal information. Only those authorized by you or Us will have access to a User’s profile and only through unique IDs and passwords.
    3. Please be aware that the Services may be unavailable during periods of routine maintenance.
  10. INDEMNIFICATION:

    You shall indemnify and hold Capizal, its subsidiaries, affiliates, officers, agents or other partners, directors and employees, harmless from and against any claims and demand, including attorneys' fees, made by any third party due to or arising out of or relating to

    1. the Personal Data received by us and information that you submit or share with us;
    2. your violation of this Privacy Policy; or
    3. your violation of rights of other Clients.
  11. LIMITATION OF LIABILITY:

      Capizal including its affiliates or related companies shall not be liable for any damages, direct or indirect, incidental or consequential, and all liabilities (including for negligence, loss or damage such as loss of revenue, unavailability of system or loss of data) and for use of or inability to access or use the Services of any kind that is offered or to provide indemnity or any other remedy to you or any third party.
  12. GOVERNING LAW:

      This Privacy Policy shall be construed and governed by the laws of India. The courts in Pune, India shall have an exclusive jurisdiction over any disputes arising under this Privacy Policy.
  13. CORRECTION/UPDATING OR ACCESS TO PERSONAL DATA:

      In case of any changes with respect to any of your information, especially Personal Data has been changed or in case you would not like to continue the Services of Capizal, then you would be required to either update your Personal Information or unsubscribe from any updates / information with respect to notifications on the products/services that you had earlier utilized or enquired upon at Capizal via Platform. In case you would like to modify / delete any details with respect to your Personal Data / Non-personal Information, or to access your information in readable format, you would have to write to query@paygro.in or to the address as mentioned at the beginning of this Privacy Policy.
  14. CHANGES TO THE PRIVACY POLICY:

    1. This Privacy Policy is subject to change and may be updated or revised from time to time, without any prior notification to the User, at the sole discretion of Capizal. It is the responsibility of the User to periodically review the Privacy Policy to determine whether there have been any revisions or updates. The last updated date of the Policy has been mentioned above for the reference of the User.
    2. If you do not agree with the terms of this Privacy Policy or any changes made to this Policy, please stop using the Services provided by Capizal immediately and write to us at the email ID stated above.
  15. MARKETING AND PROMOTIONAL COMMUNICATIONS:

    1. Capizal may use your Personal Data to send you additional information on any of the additional Service, and any special or promotional offers, newsletters or customer survey forms and questionnaires.
    2. You may opt out of receiving any such communications from Capizal at any time by contacting us with your request at query@paygro.in.
  16. I admit and agree that I have understood this ‘Privacy Policy’ and hereby accept the same.