PRIVACY POLICY
Please Read this Policy Carefully Before Using the Platform:
In order to provide our users (“you”, “your”) with the best quality services, we need to access and retain
certain information about you. The collection, handling, retention, and deletion of such information we
gather from you is governed by this Privacy Policy (“Policy”) as detailed below. This Policy refers to,
incorporates, and includes our Terms of Service available at https://triotech.co.in/terms. We may revise
this Policy as well as update our services and the Platform from time to time, so please keep visiting
this page regularly to take notice of any changes we make. If you do not agree with any part of this
Policy, please stop using our services immediately.
This Policy is an electronic record under the Information Technology Act, 2000 and the rules made
thereunder. This Policy is generated by a computer system and does not require any physical, electronic,
or digital signature.
The capitalized words used in this Policy and not defined shall have the meaning given to such words
in the Terms of Use.
1. NAME AND CONTACT INFORMATION:
The “FamApp by Trio” mobile platform/website (“Platform”) is hosted by Tri O Tech
Solutions Private Limited, a licensed pre-paid payments issuer incorporated under the laws of
India, having its registered office at 5th floor, Punj Essen House, 17-18, Nehru Place, New
Delhi, Delhi 110019 (“Triotech”), which issues the pre-paid payment instruments
(“Wallet(s)”) to you (which you can use through the Platform) (being referred to as “Data
Controller”). This Policy is a binding agreement. Throughout this document, we use the terms
“we”, “us” and “our” to refer to the Data Controller and the terms “you” and “your” to refer
to you, the user of the Platform.
2. WHAT DATA DO WE COLLECT:
2.1 We collect the information and data you provide only to ensure that we can provide you our
services in the best manner possible. We wish to keep such collection and usage of data as
transparent as possible. We have detailed the types of data we collect for your perusal below.
2.2 In order to create and maintain the Wallet Accounts, the following types of data may be
collected by the Data Controller and/or affiliate entities and the same constitutes “Wallet
Account Data”. The Data Controller will have the right to use the Account Data in accordance
with the terms of this Policy; it may share parts of this data with any third party from time to
time.
Sr. No.
Means of
Gathering Data
Data Collected
1.
Data you input
while signing up
and using our
services.
User profile data: This includes your name, phone
number, login name, profile picture (if any), and
birthdate, email address, nick name etc.
Demographic data: This includes your age, gender,
income, occupation, school/ college details and address
(including city), country of origin etc.
Address Book Contacts: This includes the names and
contact information from your address book to facilitate
invitations, social interactions and payments/transfers
to your contacts through our Platform and for other
purposes described in this Policy.
SMS data: This includes your messages/ SMS details.
Feedback data and other data: This includes the data that
you actively put into the Platform including without
limitation:
a. User feedback;
b. If you call our call centres, we may record calls
for quality and training purposes;
c. Details of customer support chat;
d. Documents and details shared in the customer
support chat;
e. Data you input when you participate in our
referral programs. For example, when a user
refers another person, we receive the referred
person’s personal data from that user;
f. Account users who request services for, or on
behalf of other users, or who enable such users
to request or receive services through their
accounts.
g. Other documents and details like PAN card
details etc.
2.
Data we collect
from your usage
of our services
a. Geolocation data: We collect the location data
from your mobile device if enabled by you to
do so. We may also collect this data when our
Platform is running in the background of your
mobile device. You will not be able to use
critical and essential features of the Platform if
you disable the location services.
b. Usage data: The Data Controller collects data
about how you interact with our services. This
includes data such as access dates and times,
Platform features or pages viewed, Platform
crashes and other system activity, type of
browser, and third-party sites or services used
before interacting with our services.
c. Device data: We may collect data about the
devices used to access our services, including
the hardware models, device IP address,
operating systems and versions, software,
preferred languages, unique device identifiers,
advertising identifiers, serial numbers, device
motion data, and mobile network data.
d. Cookies: We also collect information through
the use of “cookies”, tracking pixels, and
similar technologies to understand how you
navigate through the Platform to learn your
preferences. Cookies are small text files that
web servers place on your device; they are
designed to store basic information and to help
websites and apps recognize your browser. We
may use both session cookies and persistent
cookies. A session cookie disappears after you
close your browser. A persistent cookie remains
after you close your browser and may be
accessed every time you use the Platform.
3.
Information we
receive from other
sources
We may also be working closely with third
parties (including, for example, business
partners, technical sub-contractors, analytics
providers, search information providers) and
may receive information about you from such
sources. Such data may be shared internally and
combined with data collected on this Platform.
2.3 We may collect from you, data associated with your usage of your Wallet, such as your Wallet
transaction history, data in relation to you applying for and/or availing any services in relation
to the Wallet, loads, transfers and spends made using the Wallet, KYC data (including your
Passport, Visa, PAN, Aadhaar data etc.,), balances, payment details, for effecting transfer of
funds through various payment channels provided by us. Collectively this data will be referred
to as “Wallet Data”. We will have the right to use the Wallet Data in accordance with the terms
of this Policy.
2.4 In addition to the above, we may also ask you to provide certain additional information about
yourself on a case-to-case basis including your live photo which may be utilised by us for the
purpose of completing your KYC.
3. HOW AND WHY DO WE USE YOUR DATA?
3.1 Your data will be used for the fulfilment of the services and developing and enabling new
features. We have detailed the manner in which we use the collected data below:
3.2
Sr. No.
Reason of Use
Manner of Use
1.
Enabling our
services and
updating our
Platform features
We use the data collected to personalize, maintain, and
improve our services. This includes using the data to:
a. Create and update Wallet Accounts.
b. Enable Wallet and other services.
c. Enable features to personalize your Wallet Account.
d. Enable social features.
e. Perform internal operations necessary to provide our
services, including to troubleshoot software bugs
and operational problems; to conduct data analysis,
testing, and research; and to monitor and analyze
usage and activity trends
2.
For enabling
customer support
We use the information to provide customer support,
including to resolve your concerns arising from the use
of the services, and train our customer service
executives.
3.
For research and
development
We may use the data collected for research, analysis,
and product development to improve the UI/UX
experience, all of which will ultimately improve how
you experience the Platform. This also helps us develop
automated actions to be triggered in certain events, such
as when we need to implement dynamic pricing,
detecting fraud, account termination, amongst other
things.
4.
Enabling
communication
between users
We may allow you to share your Wallet transactions
with your friends (other Platform users in your phone
contact list) through the Platform.
5.
For marketing and
outreach
We may use the data we collect to market the Platform
and our services. This includes sharing your feedback,
ratings, screen names and photograph (if any) for purely
promotional and marketing purposes. Such promotion
and marketing may be done via hoardings, banners,
pamphlets, online advertising etc.
6.
Automated
decisions
We may use the data so collected to develop automated
decision-making capabilities.
7.
Legal compliance
and requirements
We may use the data we collect to investigate or address
claims or disputes relating to the use of our services, or
as otherwise allowed by Applicable Law, or as
requested by regulators, government entities, and
official inquiries
4. HOW DO WE SHARE THE COLLECTED INFORMATION?
4.1 The information we collect is shared only on a need basis, i.e., we do not sell your data to any
third parties for profit. However, we may enter into data-sharing agreements or disclose the
collected data to third parties in order to provide the services to you. We have detailed the
manner in which we share the collected data below:
4.2
Sr. No.
Person Shared
With
Purpose for Sharing
1.
Sharing with third
parties.
a. API and integration partners: If your connection to
the Platform is enabled through an integration with a
third-party service, we may share information about
your use of the Platform with that third-party. We
may share your information with our third-party
partners in order to receive additional information
about you. We may also share your information with
third-party partners to create offers that may be of
interest to you.
b. Service Providers: We work with third-party service
providers to perform services on our behalf, and we
may share your information with such service
providers to help us provide our Services through the
Platform.
c. Third-party services: The Platform may allow you to
connect with other websites, products, or services
that we do not have any control over. However,
usage of such third-party services is subject to their
privacy policies and not within our control. We
recommend that you have a look at their privacy
policies before agreeing to use their services.
d. Subsidiaries and holding companies: We share your
data with our subsidiaries and affiliates to help us
provide our services or conduct data processing on
our behalf.
e. Change in control: While negotiating or in relation
to a change of corporate control such as a
restructuring, merger, or sale of our assets, we may
have to disclose our databases and information we
have stored in the course of our operations.
f. Where appropriate to the context, the third parties
that we share or make available your personal data
are bound by contractual obligations to keep such
personal data confidential and use it only for the
purposes for which we disclose it to them and also
maintain at minimum the same level of data
protection that is adhered to by us.
2.
Sharing with law
enforcement
when needed
If any governmental authority or law enforcement
officers request or require any information and we
think disclosure is required or appropriate in order to
comply with laws, regulations, or a legal process.
5. HOW IS PAYMENT DATA HANDLED?
5.1 We may provide the functionality to load your Wallet through debit card, credit card or any
other payment mode and collect data in relation to such loading of your Wallet through these
payment modes (“Payment Data”) in accordance with applicable law. The information
regarding your Payment Data may be stored once you make the first payment by the card/other
payment mode and is protected against unauthorized access. For this purpose, a certified
payment provider is used whose systems meet the applicable security standards, such as for
example PCI-DSS (Payment Card Industry – Data Security Standard). The Payment Data is
stored by the contracted PCI-DSS-certified payment provider for recurring transactions. We do
not, ourselves, store your Payment Data and if we ever do, it will be only in abbreviated form
for analysis purposes or to prevent fraud and will be stored in accordance with the Applicable
Laws
5.2 In order to ensure that the debit/credit card/other payment mode is used by the legitimate owner
and to prevent cases of fraud, the Payment Data and card information is transferred to one or
more external payment security services. This transfer may also include additional personal
data. The external payment security services may process personal data on our behalf.
6. WHAT ARE YOUR RIGHTS TO CONTROL THE DATA?
6.1 It is important for us that you remain in control of your data. You alone are the owner and
manipulator of your data, and you shall have the right to restrict our usage of the data in the
manner provided below. You should also remain informed of your rights with regards to the
use of your data and information by us. Your rights with regards to your data are listed below.
Sr. No.
Your Right
Scope of Right
1.
Right to confirmation
You have the right to obtain a confirmation from
us as to whether your personal data (your name,
housing address, age, credit card information,
amongst other data) is being processed.
2.
Right to rectification
In the event that any personal data provided by
you is inaccurate, you shall have the right to
provide us with the accurate data and have us
rectify such data at our end immediately.
3.
Right to erasure
You have the right to demand us to erase your
personal data without undue delay and we will
do so without undue delay, provided that the
data is no longer required by us.
However, rest assured that we will delete your
personal data from our databases as soon as the
legal basis for processing such personal data
lapses. Do note that multiple legal basis for
processing your personal data may exist in
parallel and we may still have to retain some of
your personal data at any time
We may, however, reserve the right to retain and
store your personal information for our business
purposes, whether such personal information
has been deleted or not. After a period of time,
your data may be anonymised and aggregated
and then may be held by us as long as necessary,
to enable purchases of products and provision of
services or for analytics purposes.
4.
Right to the restriction of
data processing
You have the right to require us to restrict the
usage of data when the use of such data may be
illegal or when such data is inaccurate.
5.
Right to withdraw consent
You have the option, at any time while availing
our Services or otherwise, to withdraw your
consent given to us for processing your data. In
case of withdrawal of your consent, we reserve
the option not to provide the Services for which
such information was sought. For withdrawing
your consent, you may send an email to us at
support@triotech.co.in. Your withdrawal will
become effective upon the receipt of an
acknowledgment by you from us
6.
Right to opt-out
Marketing opt-outs: You may opt out of
receiving promotional emails from us by
writing to us at support@triotech.co.in. You
may also opt out of receiving emails and other
messages from us by following the unsubscribe
instructions in those messages. However, even
if you have opted out of receiving information
from us, we will still send non-promotional
communications.
Push notifications: You can opt out of receiving
push notifications through your device settings.
Please note that opting out of receiving push
notifications may impact your use of the
Platform.
Location Information: While you can prevent
your device from sharing location information
at any time through its operating system
settings, sharing such location is core to how the
Platform works and without it we cannot
provide our services accurately to you.
7. WHAT ARE OUR DATA SECURITY PRACTICES?
7.1 We process your Personal Information with consent. By using our Platform or services and/or
by providing your Personal Information, you consent to the processing of your Personal
Information by the Data Controller in accordance with this Privacy Policy. If you disclose to us
any Personal Information relating to other people, you represent that you have the authority to
do so and permit us to use the information in accordance with this Privacy Policy
7.2 We use appropriate technical and organizational security measures to ensure a level of
protection to your personal data which is commensurate to the risk, taking into account state of
the art technologies, implementation costs and the nature, scope, context and purposes of
processing as well as the risk of likelihood and the degree of risk. The transfer of personal data
between your end device and us is generally carried out in an encrypted form (TLS encryption).
You can identify an encrypted connection by the lock symbol in the address line of your
browser. If you communicate with us by email, access by third parties cannot be ruled out. In
the case of confidential information, we recommend using encrypted email communication
(PGP).
7.3 This Policy and the security measures and practices implemented by us to protect your
information shall be the reasonable security practices and procedures under section 43A of the
Information Technology Act, 2000.
8. CHILDREN’S PRIVACY:
8.1 We take the privacy of minors very seriously. Please make sure that you as the parent who
accepts these terms of this Policy on behalf of the minor, supervise the types of data that the
minor shares with us. To make sure data shared by minors is safe, we may (from time to time)
integrate new mechanisms and safeguards on our Platform.
9. COMMUNICATIONS FROM US:
We may from time to time send you service-related announcements when we consider it
necessary to do so (such as when we temporarily suspend the Platform for maintenance, or
security, privacy, or administrative-related communications). We send these to you via SMS or
email, as we deem fit.
10. LINKS TO OTHER THIRD – PARTY SITES AND COLLECTION OF
INFORMATION:
10.1 Our Platform may provide links to other third - party Platforms (“Third – Party Sites”) that
may collect your personal information including your IP address, browser specification, or
operating system. We are not in any manner responsible for the security of such information or
their privacy practices or content of those Third – Party Sites. Additionally, you may also
encounter “cookies” or other similar devices on certain pages of the Third – Party Sites and it
is hereby clarified that we do not control the use of cookies by these Third – Party Sites. These
third-party service providers and Third-Party Sites may have their own privacy policies
governing the storage and retention of your information that you may be subject to. This Policy
does not govern any information provided to, stored on, or used by these third-party providers
and Third-Party Sites. We recommend that when you enter a Third-Party Site, you review the
Third-Party Site’s privacy policy as it relates to safeguarding of your information. You agree
and acknowledge that we are not liable for the information published in search results or by any
Third-Party Sites.
11. PUBLIC POSTS:
11.1 You may provide your feedback, reviews, testimonials, etc. on the Platform on your use of the
services provided by us (“Posts”). Any content or information and Posts that you share or
upload on the publicly viewable portion of the Platform (on discussion boards, in messages and
chat areas, etc.) will be publicly available, and can be viewed by other users. Your Posts shall
have to comply with the conditions as mentioned in the Terms. Data Controller retains an
unconditional right to remove and delete any Post or such part of the Post that, in its opinion,
does not comply with the conditions in the Terms. Data Controller reserves the right to use,
reproduce and share your Posts for any purpose. If you delete your Posts from the Platform,
copies of such Posts may remain viewable in archived pages, or such Posts may have been
copied or stored by other users.
12. UPDATES TO THIS POLICY:
12.1 We may occasionally update this Policy. Use of our services after an update constitutes consent
to the updated Policy to the extent permitted by law. If we make significant changes, we will
notify you of such changes in advance. Please take the time to periodically review this Policy
for the latest information on our privacy practices.
13. GRIEVANCE OFFICER:
13.1 We have appointed a grievance officer to address your concerns regarding data safety, privacy
with regard to your Wallet Account. You may contact the Grievance Officer at:
Name: Ritwick Bhaduri
Office hours: 12 noon to 7 PM.
Email address: support@triotech.co.in
13.2 If your grievance is not resolved to your satisfaction, you may escalate the grievance to -
Name: Saransh Agarwal
Office hours: 12 noon to 7 PM.
Email address: grievanceofficer@triotech.co.in
